With Title V Permits close at hand, sources face a host of questions. The EPA has done much to explain the wide range of monitoring options available to sources. They have discussed the need to document monitoring in a comprehensive plan. However, they have not spent time defining the quantity or quality of data required for a defensible claim of compliance.
Many sources believe a single stack test is an adequate determination of compliance.
Yet EPA believes they have no choice but to require a number of data points each day. It is the only enforcement shield EPA will allow. Analysis - The language in a Title V permit defines exactly how a source must demonstrate compliance. The language must be analyzed carefully in terms of the process, existing instrumentation, available monitoring, operations and plant preferences. Since sources will have established Periodic Monitoring long before CAM takes effect, most believe CAM has limited impact.