CAIR Frequent Questions – Monitoring
Q: CAIR/CAMR do not have the same tiered approach to modifications to test methods and monitoring that Part 60 and 63 uses (minor, intermediate, and major). Both CAIR and CAMR have provisions that allow petitions for any modification to a monitoring requirement; however, these essentially require concurrent approval from EPA and the state, and the issue of modifications to test methods is not addressed. EPA has indicated that states are responsible for observing QA testing, which includes stack tests and RATAs. State investigators will be performing these field observations. Will the State staff have the authority to approve minor changes to test methods that might arise during the field testing?
A: Both CAIR and CAMR require Part 75 continuous emission monitoring, and the requisite certification and quality assurance compliance cited in the regulation. Both CAIR and CAMR, as well as the Acid Rain Program (Title IV) and the NOx SIP call, have provisions whereby a source may petition EPA regarding monitoring regimes, including possible modifications to monitoring requirements and test methods. Quality Assurance testing requirements under Part 75 and Part 60 differ. There should be a limited need for test method modification at the time of testing. Most necessary modifications can be identified before the test period and addressed through petitions to EPA as needed. Part 75.22(c)(1)(i) states that "performance tests shall be conducted and data reduced in accordance with the test methods and procedures of this part unless the Administrator [CAMD] specifies or approves, in specific cases, the use of a reference method with minor changes in methodology" Furthermore, CAMD monitoring staff is available to answer questions and provide guidance to observers in the field if, for example, infrequent, minor modifications to a test method seem to be necessary. The State should not approve changes to test methods in the field without contacting, and receiving concurrence from, EPA. This process is consistent with the approach that has been used for more than10 years with the Acid Rain Program as well as the NOx trading programs under the OTC and NOx SIP call. Additionally, there is a policy manual that helps explain the application of various provisions of Part 75 in a particular situations. CAMD also periodically provides general training in Part 75 requirements and is planning to do additional training specifically targeted at the monitoring requirements in CAMR since they are new.