It is important to note that the majority of the Title V permits that were evaluated in this periodic monitoring analysis were issued prior to the EPAs September 15, 1998, periodic monitoring guidance memorandum. Although the permits already issued are not likely to undergo revision to correct deficiencies in periodic monitoring until the permits are renewed or revised, new permits issued by the local permitting authorities are likely to follow the EPAs guidance much more closely than permits issued in the past. For similar sources combusting natural gas, periodic monitoring requirements vary from nothing to daily Method 9 observations. However, the majority of permitting authorities define adequate periodic monitoring somewhere between the two extremes. The concept of developing adequate periodic monitoring for gapped requirements involves an evaluation of a source's emissions, the likelihood of violating the standard, and the reasonableness of potential monitoring options. For the majority of sources, simply documenting limited hours of operation or adherence to a particular operating scenario is not adequate to demonstrate compliance with an applicable requirement. At least some data directly representative of a source's compliance is needed. As specified in the periodic monitoring for many of the Title V permits analyzed in this article, all periodic monitoring does not necessary have to follow EPA test methods. For natural gas fired units, a reasonable middle ground for many sources is a visual observation for opacity made on a weekly or monthly basis. If visible emissions are observed, then additional monitoring is required to demonstrate compliance (Method 9) with the applicable standard. This type of two-tiered approach is adequate to demonstrate compliance with opacity standards without subjecting a source to excessive monitoring, such as daily Method 9 testing. In reviewing the periodic monitoring requirements for general opacity standards in Title V permits issued by various permitting authorities, the differences in interpretation of what constitutes sufficient periodic monitoring is apparent. The depth of periodic monitoring ranges from nonexistent to overly burdensome. Accepting a permit with no periodic monitoring could backfire when the permit comes up for renewal and the public and EPA get a chance to comment. Your goal when negotiating periodic monitoring requirements for a Title V permit should be to simplify and reduce the periodic monitoring to only that which is necessary to reasonably demonstrate compliance with the applicable standard.
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