Title V Permits must be renew  ervery 5 years. Sources can use these renewals as opportunities to increase operational flexibility and get a return on their enviromental investments. CleanAir specializes in answers to questions like: "What are my options for emissions monitoring and reporting?"

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.

The answer: sources need a defensible monitoring system -- one built upon the realities of instrumentation, information technology, and strong process engineering. 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. 

CAM - The recently finalized Compliance Assurance Monitoring rule is intended for large sites and will become effective for most sources when their current Title V permit expires (in 5 years or so). Since sources will have established Periodic Monitoring long before CAM takes effect, most believe CAM has limited impact.

Process Engineering - Before selecting a monitoring approach, it is essential to have a clear understanding of the process.  Transitions, startups and shutdowns can be defined outside compliance requirements. Monitoring can often be simplified with process changes. EPA intends monitoring be made an essential part of process control. 

Documentation, QA/QC and Management - The 1990 Clean Air Act Amendments redefines monitoring as a system, encompassing not only the hardware but also documentation, QA/QC, and management.   It includes all the elements needed to successfully defend a claim of compliance. 

Reporting - Title V requires each source to collect sufficient data to determine compliance on a continuous basis. By requiring certification of compliance reports, EPA has placed the full weight of the law behind accurate and timely reporting. Additionally, reports will be readily available to the public. 

Check out the Clean Air Download Library for more Title V resources.