Voluntary Superior Monitoring FAQ's
What is particulate matter?Particulate matter (PM) are particles found in the air, including soot, dust, smoke, and liquid droplets.
What are some health effects and who is at risk?Particulate matter can cause coughing, painful breathing, can aggravate asthma, and increase the risk of premature death. Those at risk are the elderly, children, and people with existing lung disease.
What are some environmental effects of particulate matter?Making lakes and streams acidic, changing the nutrient balance in coastal waters and large river basins, depleting the nutrients in soil, damaging sensitive forests and farm crops, and affecting the diversity of ecosystems.
Can sources with emissions monitoring for particulates participate in the Voluntary Superior Monitoring Program and what is superior monitoring for particulate sources?Yes, depending on what PM monitoring is required, superior PM monitoring can be bag leaks, PM CEMS, etc.
What are the benefits of using Voluntary Superior Monitoring?VSM allows more flexibility in process operations and developing emissions monitoring, allows industry to operate and maintain processes and control equipment more efficiently, potentially reduces emissions, provides better data for emissions inventories, and streamlined permits.
What are the incentives for those industries who participate in the Voluntary Superior Monitoring Program?There are many potential incentives to implementing VSM. The incentives include, but are not limited to: eliminating or reducing existing emissions monitoring, reducing record-keeping and reporting issues, reducing performance testing frequency, refocusing emissions limits, reducing chances for inspections, possibly providing tax credits, and reduces costs in the long run. These incentives will not be final until the rulemaking is final.
Can your company save resources by using Voluntary Superior Monitoring?At this present time, we are still in the information gathering and evaluation stage, so the information is tentative. However, we believe that the use of VSM can save your company resources. By giving more accurate and updated data you can save money on equipment and fines you would get for being out of compliance. VSM can also save on time, because you will not need to do stack testing as often or to record numerous parameters. There is also less time in testing start-up or shut down, because the monitoring will already be in place. This requires less need for inspections.
What can Voluntary Superior Monitoring do for the environment?We believe that better emissions monitoring will help reduce the amounts of pollution in the environment, which will assist the industry in gaining the confidence of their respective community.
Is Voluntary Superior Monitoring really superior?Yes, Voluntary Superior Monitoring is clearly better than the emission monitoring required in each rule. It offers options in exchange for implementation of a better monitoring technique. There are some questions now regarding the consistency of emission monitoring requirements among states. We are trying to work out these kinds of issues in the rulemaking process.
Who is eligible for Voluntary Superior Monitoring?All those subject to the NSPS, NESHAP, and MACT standards, Parts 60, 61, and 63. We are however, investigating how other EPA programs such as SIP and NSR may allow others to participate.
Who would approve these requests?We hope to approve these requests through the Title V permit program. We plan on delegating the responsibility to the states, although some approvals may have to be made at the EPA Regional Headquarters level.
How will Voluntary Superior Monitoring be enforced?Once a source has an approved VSM program, then that emission monitoring would be the applicable requirement. The data generated by a VSM source would be used for compliance and enforcement.
What is the difference between monitoring required by regulation and Voluntary Superior Monitoring?Monitoring required by regulation was often developed many years ago and is now inadequate to characterize the emissions from some industries. Many regulations require industry to do testing a few times a year. However, VSM will help ensure industry is in continuous compliance. Voluntary Superior Monitoring is "better" monitoring than what is required in the underlying regulations. We are working on how to define or describe what is "better."
Are the emission monitoring requirements in State Implementation Plan (SIP's) the same as the applicable monitoring in the regulation such as in the NSPS or NESHAP?Not necessarily, the monitoring requirements will be determined by the structure of the rule the state develops to attain the National Ambient Air Quality Standards.
Will EPA provide guidance to support a VSM regulation?Yes. Guidance is being developed to show what VSM is. Examples of superior monitoring will be given for different regulations. Examples of supporting information and data requirements will be given. We hope that this information can be updated when we learn more from industry and state/local agencies as time progresses.
Still have questions about this program? Contact the EMC expert Tom Driscoll at firstname.lastname@example.org .