OCR Text |
Show PROPOSED ENHANCED MONITORING In the proposed Enhanced Monitoring Program, if the best established monitoring was not proposed, then the owner or operator was required to identify all technologically feasible monitoring methodologies in order to select as demonstrate that the proposed enhanced monitoring was· the best other monitoring methodology for providing sufficiently representative, accurate, precise, reliable, frequent and timely emissions data. Cost was not a factor in determining whether or not a proposed enhanced monitoring protocol was the best other monitoring methodology. For example, a CEMS would be considered the best established monitoring for nitrogen oxide emissions from an industrial boiler. In order for the owner or operator to use a PEMS, the owner or operator would have to identify all technologically feasible monitoring and justify why the selected monitoring technology is the best for the situation without cost being a factor. The proposed Enhanced Monitoring Program required that potentially a large number of reference test runs would need to be utilized to demonstrate that a PEMS meets relative accuracy requirements. For each parameter which is known to affect emissions, a minimum of three test runs would need to be performed at representative points in addition to performing three test runs at three process operating loads. For a PEMS which utilizes eight process sensors, twenty-four test runs would have to be performed for the eight process sensors and then three additional test runs at three process operating loads for a minimum of thirty-three test runs. The cost associated with these type of requirements would prevent PEMS from being used under the proposed Enhanced Monitoring rule. In July 1995, Pavilion formed a workgroup consisting of current PEMS owners, environmental consultants and others knowledgeable about PEMS in order to convince EPA to change the proposed Enhanced Monitoring rule. 3 . |