3. SOURCE TYPES WITH CEMS REQUIREMENTS
Fossil Fuel-Fired Steam Generators
Cement Plants
Municipal Waste Combustors
Nitric and Sulfuric Acid Plants
Petroleum Refineries
Copper, Zinc, and Lead Smelters
Steel and Ferroalloy Plants
Kraft Pulp Mills
Glass Manufacturing Plants
Magnetic Tape Production
Phosphate Plants

36. William T. “Jerry” Winberry, Jr.
Continuous Emission Monitoring and Compliance Assurance Monitoring Dateline
William T. “Jerry” Winberry, Jr.
EnviroTech Solutions

37. The Clean Air Act of 1970 proposed CEMS applications for five source categories (nitric, sulfuric, FFFSG, Portland Cement and refineries) for criteria pollutants
December 23, 1970
40 CFR 60 Subpart D proposed (Opacity, SO2, NOx CEMS for FFFSGs)
August 17, 1971
December 21, 1971
FRM 1-8 promulgated
Emission limits were based upon good operations of control equipment
40 CFR 51 Appendix P: SIP Requirements for CEMS (nitric, sulfuric, FFFSGs and refineries)
December 23, 1971
Emission limits promulgated with CEM monitoring required

38. No “Excess Emissions” policy by EPA
Start-ups/shutdown reviewed on “case-by-case” basis by EPA for allowing excess emissions
August 25,1972
Emission “Minimization” Guidance issued by EPA
Compliance through initial Performance Test
May 2, 1973
September 11, 1974
Minimize emissions through monitoring of emissions by CEMS
40 CFR 51 Appendix P, CEMS for Source Categories Promulgated
40 CFR 60 Appendix B: PST 1, 2, 3 Promulgated, Excess Emission Reports (EER) established, Definition of “F-Factor,” On-site Case-by-Case Cert.
October 6,1975

39. Promulgated Excess Emission Policy by EPA for copper smelters
Excess emissions during start-ups/shutdowns
Allowed excess emissions 1.5 %
CEMS as Compliance Test Methods
November 1, 1977
December 21, 1977
EPA: “Use of CEMS to Achieve Continuous Reduction”
“Never-to-Violate” policy issued by EPA (Beginning of Continuous Compliance Policy by EPA)
July 8, 1978
EPA issues memo: “CEMS Used As Indicators for Continuous Compliance”
EPA develops guidance for implementing CEM as “Compliance Indicators.”
October 6,1975

40. Subpart Da promulgated where CEMS are defined as the “Compliance Method”
Continuous Compliance (18 hr/d for 22 days)
% reduction for SO2, Qt. Audits
30 day rolling average allowed
Other Compliance Methods (FRM 6A/6B; CSA), Annual Relative Acc.
Initial Performance Test, Daily Drift
July 11, 1979
February 20, 1980
Proposed PST 4 for CO CEMS
Revisions to App. A/B implies Appendix F, Procedure 1 requirements
January 26, 1981
June 10, 1981
Kathleen Bennett memo: “Develop Regulations/Continuous Compliance”

41. LIDAR promulgated as Reference Method (FRM 9A) for Opacity
October 28, 1981
Kathleen Bennett memo EPA’s uses of CEMS as:
Source Compliance Test Methods
Where Compliance Method is not identified
Promoted within State regulations
CEMS as O/M (Part 60.11)
August 12, 1982
December 1, 1982
Promulgated FRMs 6A/6B for SO2
March/July 1983
Promulgated PST 1/2/3 revisions; PST 5 Promulgated

42. October 21, 1983
Proposed revisions to Subpart D:
30-day rolling average
Required % monitor availability
Method 6B as CEMS
Appendix F, Procedure 1 implied
Ed Reich memo: “Continuous Compliance Tools”
FSA; FRM 6B; CEMS; Unannounced Inspections; portable Instruments, EER’s; and Baselining
January 13, 1984
March 14, 1984
Proposed Appendix F, Procedure 1:
Source must implement QA/QC
Calculate daily zero/span drifts
Quarterly Audits: GCA, RATA, RAA
CEM “Out-of-Control” Conditions

43. Excess Emission Report (EER) Guidance issued by EPA
Periodic Source Compliance Status Guidance issued by EPA
March 18, 1984
Proposed Subpart Db (29-73MW)
NOx/Opacity: CEMS
Particulate Matter: FRM 5
June 19, 1984
October 5, 1984
Excess Emission Review Policy issued by EPA
Proposed Rulemaking for Instrumental Test Methods 3A (CO/CO2); 6C (SO2), and 7E (NOx)
February 28, 1985
March 6, 1985
Proposed rulemaking to allow use of gas cells/cylinders during PST if < 50% of emission standard

44. CSA Guidance Document Issued by EPA
PST 4 (CO) promulgated and applicable to refineries
August 5, 1985
September 10, 1985
Opacity CEMS proposed for Portland Cement Plants
Opacity concurrent with VE during initial compliance
October 1, 1985
Promulgated SO2 CEMS for Subpart LLL, On-shore Natural Gas Processors for % SO2 Reduction
June/July 1986
FRMs 3A, 6C, and 7E Promulgated (Instrumental Reference Methods)
Better Precision then FRMs
Promulgated Gas Cells and Gas Cylinders as Part of PST 2

45. Promulgated rulemaking for Subpart Db (>29MW) Required Continuous Compliance Tools Implemented
November 25, 1986
March 9, 1987
Proposed Rulemaking for Continuous Emission Rate Monitoring Systems (CERMS)
PST 6 for Rate Monitoring Systems Proposed
June 4, 1987
Promulgated Appendix F, Procedure 1
Source must implement QA/QC
Calculate daily zero/span drifts
Quarterly Audits: GCA, RATA, RAA
CEM “Out-of-Control” Conditions
March 6, 1988
Promulgated PST 6 for CERMS’s

46. EPAMemo states:
CEMS/CSA are self-monitoring tools
CEMS Used as Enforcement Tools for Subparts Da, P, Q, R, GG, LLL
CEM data uses include: Direct Compliance; General Compliance Tools (i.e., Screen Sources, Select Sources for Further Action, Compliance Test)
EER CEM Data for Follow-up Action and Notice of Violation
March 31, 1988
July 5, 1988
SO2 Continuous Compliance Strategy Issued by EPA including: CSA & O/M of control equipment, CEMS & parameter Monitoring, FRM 6A/6B
June 9, 1989
Subpart Dc Requirements Promulgated
<29MW but >2.9 MW

47. CEMS system (SO2) Promulgated for Compliance for Subpart Dc (>29MW), Small Industrial Steam Generating Units
September 12, 1990
September, 1990
NESCAUM guidance for CEMS PS and QA Requirements for Municipal Waste Combustion Facilities
October 2, 1990
PST 7 (H2S) for Refinery Gas Promulgated
October 7, 1992
40CFR51, Appendix M, Method 203- Proposed Draft Specifications for COMS for Continuous Compliance

48. November 15, 1990
Clean Air Act Amendments (CAAA) of 1990 Promulgated:
Limits SO2 and NOx Emissions at Power Generating Facilities (>25MW) On A National Bases
Title I: Enhanced Ozone Monitoring
Title III: HAPs
List of 188 HAPs
10-6 Risk Levels
Control Through MACT Program
Technology-based Limits
Title IV: Acid Rain
Use CEMS for Annual Emission Rates. CEMS Used For Emission Accountability
Compare Emissions Against Allowances
Allow Trading of Credits on Open Market

49. Clean Air Act Amendments (CAAA) of 1990 Promulgated (Cont’d):
Title V: Operating Permits
All Federally Enforceable Requir.
Use of CEMS, COMS, PEMS etc.
Title VII: Enhanced Monitoring
November 15, 1990
February 11, 1991
CEMS (SO2, NOx, CO) Used for Compliance For Subpart Ea (New Municipal Waste Combustors) and CEMS (SO2, CO) for Existing Municipal Waste Combustors
Promulgated BIF Regulations
Continuous CO Monitoring For Good Combustion Practices for PIC
CEMs (CO, O2, THC) Used for Compliance During Hazardous Waste Combustion
February 21, 1991

50. Part 75 Allowance Trading CEM Rules Promulgated:
Subpart A: General
Subpart B: Monitoring (CEMS)
Subpart C: O/M Revisions
Subpart D: Missing Data
Subpart E: Alternative Monitoring
Subpart F: Recordkeeping
Appendix: QA/QC, Missing Data
January 11, 1993
February 19, 1993
Part 503 Sewage Sludge Incinerator CEM Rules Promulgated
EPA’s Acid Rain Policy Manual Reviewed
March, 1993
May 5, 1993
Part 75 Acid Rain Policy Manual issued

51. Acid Rain Policy Manual Update #1
May, 1993
September 30, 1993
Draft Enhanced Monitoring Reference Document Issued by EPA:
Chapter 1: Overview
Chapter 2: Applicability
Chapter 3: Protocol Requirements
Chapter 4: Identification/Selection
Chapter 5: Permit
Chapter 6: Performance Testing
Chapter 7: Certification
Chapter 8: Examples
October 22, 1993
Proposed Part 64 Enhanced Monitoring (EM) Regulations Issued (Draft)

52. Acid Rain Policy Manual Update #2
November, 1993
September, 1994
Acid Rain Policy Manual Update #3
November, 1994
Acid Rain Policy Manual Update #4
November 15, 1994
Enhanced Monitoring Rules Submitted, then Withdrawn from Office of Management and Budget

53. Proposed Revisions to 40CFR60, Appendix B, PS 1 Promulgation Coordinated with part 51, Appendix M, Method 203
November 25, 1994
December 11, 1994
EPA Request Additional Comments on proposed Enhanced Monitoring Regulations
December 15, 1994
PS 8 Promulgated for VOC CEMS
PS 9 Promulgated for GC CEMS
March 15, 1995
Proposed Enhanced Monitoring Rule Package Re-submitted to OMB

54. Acid Rain Policy Manual Update #5
March, 1995
April 4, 1995
The Re-Submitted Enhanced Monitoring Rule Withdrawn from OMB for Restructuring
May 17, 1995
Part 75 CEM Direct Final Rule Published
Part 75 CEM Interim Final Rule Published
May 30, 1995
40CFR51, Appendix M, Method 25 Performance Method for Dilution Systems When Conducting Compliance Testing

55. Compliance Testing Assurance Monitoring (CAM Stakeholders) Meeting in Washington, DC for Restructuring New Rule
May 31, 1995
July 17, 1995
Part 75 CEM Direct Final Rule Effective
July 31, 1995
Acid Rain Policy Manual Update #6
September 13, 1995
Draft CAM Rule and Guidance Document Published

56. Second CAM Stakeholders Meeting in Durham, NC
September 22, 1995
November 30, 1995
Acid Rain Policy Manual Update #7
February 13, 1996
Draft PS 11 (PM) To Evaluate Perspective PM-CEMS-OSW
Draft PS 12 (Hg) To Evaluate Perspective Hg-CEMS-OSW
March 8, 1996
Acid Rain Policy Manual Update #8
Proposed PS 10 Multi-metals CEMS
Proposed PS 12 total Mercury CEMS
April 19, 1996

57. Part 75 CEM Regulation: Withdrawal 7-Day Notice Requirement for RATA Rescheduling
May 22, 1996
June 27, 1996
Acid Rain Policy Manual Update #9
August 2, 1996
Draft CAM Rule
August 13, 1996
CAM Rederal Register Notice
Pollutant-specific Provisions CAM
General CAM

58. Draft CAM Technical Guidance Document
September 3, 1996
September 10, 1996
CAM Stakeholders
October 11, 1996
Acid Rain Policy Manual Update #10
November 20, 1996
Part 75 CEM Regulation
Revisions and Technical Corrections to May 17, 1995 Interim Rule

59. Any Credible Evidence (ACE) Rule Promulgated
Non-reference test data (i.e, CEMs) used for enforcement in Title V
Put sources and Agencies On Same Evidentiary Basis
February 24, 1997
Acid Rain Policy Manual Update #11
March 18, 1997
March 31, 1997
Proposed method 318: Extractive FTIR Method for Mineral Wool and Wool Fiberglass Industries
April 8, 1997
Draft PS 15: Extractive FTIR CEMS
Draft Method 320: FTIR Method for Vapor Phase Organic and Inorganic Emissions

60. Draft CAM Impact Analysis
Cost To Affected Sources
Regulatory Flexibility
April 11, 1997
May 14, 1997
Pre-Proposal Draft Revisions to Part 72 and part 75
October 3, 1997
Final CAM Rule Promulgated (40CFR64)
August 17, 1998
CAM Guidance Document

61. September 30, 1999
Promulgated PS 9 for GC CEMS
February, 2000
Promulgated PS 15 for Extractive FTIR CEMS
Promulgated PS 9 for GC CEMS
Promulgated PS 8 for VOCs CEMS
July 31, 2000
Promulgated PS 9 for GC CEMS
April 16, 2001
Draft Supplement to CAM Document: Case Studies

62. September, 2002
Promulgated PS 8A for Total Hydrocarbon CEMS
December 23, 2002
CAM Printing and Flexible Packaging Facilities Support Document
February 27, 2003
Clean Sky Act of 2003 Drastically Reduce Power Plant Emissions for SO2, NOx, and Hg by Setting National Caps on Each Pollutant
Voluntary Superior Monitoring (VSM) Under Consideration by EPA/EMC
July 21, 2003

63. January 12, 2004
Promulgated PS 11 and Procedure 2 for Particulate Matter (PM) CEMS
January 30, 2004
Clean Air Rules of EPA Proposes New Air Rules for Reducing Emissions of SO2, NOx, and Hg Covering 29 Eastern States in the US
EPA Proposed Utility Mercury Reduction Rule
Municipal Waste Combustion Rule
Hospital/Medical/Infectious Waste Incinerator Rule
January 30, 2004
Proposed PS 12A for Total Vapor Phase Mercury CEMS

64. April 30, 2004
EPA Publishes Frequently Asked Questions Associated with the CAM Regulations on EMC Web Site

65. ’60 Little Federal Focus; State Directives
’70 Proper O/M of Control Equipment
Technology-base Limits/Performance Demo
CEM
CEMS
’75 Performance-base Regulations NSPS
Performance Specifications Promulgated
Indication of Compliance
COMS
‘79 Risk-based Regulations NESHAP
’87 Mass Emission Stds/Excess Emission Policy
CERMS
’90-’92 Technology-base MACT
PEMS
’97 Continuous Compliance/Market-base Trading
CAM
’03 Compliance Monitoring
VSM
Determination of Compliance

66. Three CEMS Enforcement Programs
Excursion monitoring and reporting
Direct compliance monitoring
Emission Accounting

67. Excursion Monitoring Required by most NSPS and SIP rules
No explicit data validation
Monitoring against emission limits with short averaging time
Report only excursions

68. Direct Compliance Required by few NSPS and SIP rules
Data validation requirements
Monitoring against emission limits with long averaging time
Report all rolling averages
Data legally documents compliance or violation

69. Emission Accounting Required by special regulatory action
Very extensive data validation and CEM certification
Missing data procedures to provide accountability of emissions
No emission limits

70. CEM Data As Credible Evidence
Rule promulgated Feb. 24, 1997
Eliminates reliance on FRMs
Non-reference test data can be used in enforcement action
Rule based in CAAA of 1990
Does not change emission limits

71. THE 3’Rs OF CEMS Repeatability- Daily Drift Test
Representativeness- Siting Requirements
Reproducibility- Required Relative Accuracy Test