Draft Compliance Assurance Policy for Continuous Emission

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					 Draft Compliance Assurance Policy for
Continuous Emission Monitoring Systems
      (CEMS) on Combustion Units

  Air Quality Technical Advisory Committee
          Meeting, October 30, 2008

                Ron Gray
           Bureau of Air Quality
 PA Department of Environmental Protection
             Harrisburg, PA
                 Revises the
        Enforcement Policy - CEMS and
        Coal Sampling/Analysis Systems
                 July 1, 1985

Draft revisions to the policy were discussed during
         the March 27, 2008 AQTAC Meeting

Notice of proposed revisions and 30-day comment
 period published in the Pennsylvania Bulletin on
                 October 11, 2008
               Proposed CEMS and
Coal Sampling/Analysis Systems Enforcement Policy

 Establishes uniform criteria for assessing penalties for
  violations reported from Continuous Emission
  Monitoring (CEM) Systems

 Extends its scope to all averaging periods, air
  contaminants and combustion units subject to
  Continuous Source Monitoring requirements

 Incorporates the March, 1992 Interim CSMS Penalty
  Guidelines, Hourly-based Emission Standards.
 Base penalty amounts are adjusted for inflation.

 Penalty provisions are revised -
   – to reflect improvements in source performance
     relative to emissions since 1985, and
   – to provide consistent statewide considerations in
     conformance with the Department’s more recent
     Compliance Assurance Policies for Continuous
     Source Monitoring Systems, Revision Number 8 to
     the Department’s Continuous Source Monitoring
     Manual, (274-0300-001), and Federal CEM
     enforcement guidance.
    Additional amendments are proposed, based on
 comments received from AQTAC and Department staff:

 Added reservations of the right to take enforcement
  action beyond that specified –

   – When Emissions contribute to violations of ambient
     air quality standards (Section1.I.B.6);


   – When emissions result in the creation of air pollution
Revised Gaseous Emissions Penalty Criteria for 30-day
rolling average emissions, to conform with applicable
  Federal requirements and enforcement guidance:

A daily penalty assessment will be calculated whenever
  emissions exceed a 30-day rolling average standard.

                   Section 2.III.A.4
             “Purpose” Section 1.III refined:

 Clarifying that the Compliance Assurance Policy is to
  be used to calculate penalties for settlement
  agreements, and should not be used to develop
  penalties for litigation or unilateral assessment.

 Clarifying which Air Pollution Control Act Section 9.1
  considerations are applied in report processing, and
  which ones Region Air Quality Program staff will
  consider during review and resolution of violations.
The proposed revised guidance document will be
effective January 1, 2009, and will be applied to
Continuous Source Monitoring System Quarterly
Reports for the first quarter, 2009 and thereafter.

Questions regarding the draft technical guidance
document should be directed to:
              Ron Gray, (717) 772-4482
           or Doug Haulik, (717)772-3976.
Notice of Draft Technical Guidance - Substantive
  Revision, published in the October 11, 2008
              Pennsylvania Bulletin

   Interested persons may submit written
      comments by November 10, 2008.

Copies of this document are available on the
   Department’s eLibrary under Technical
          Guidance Draft Documents

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