EMC Voluntary Superior Monitoring

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The Emissions Measurement Center of EPA's Office of Air Quality Planning and Standards in Research Triangle Park, NC is exploring a regulatory option called "Voluntary Superior Monitoring (VSM)." Under this option, owners/operators of industrial air pollution sources could volunteer to conduct "superior" monitoring which could range from more frequent monitoring of emissions to replace existing monitoring. In return for conducting superior monitoring, EPA plans to offer incentives to these sources, such as less record keeping and reporting, more flexibility in control device or process operation, or flexibility in averaging times for determining compliance with the standard. We are also considering pursuing tax credits as an incentive; however, obtaining tax credits as an incentives will present some higher than normal hurdles and will result in EPA negotiating with agencies and groups beyond their normal purview. In conjunction with the rulemaking, we plan to provide guidance on how to implement Voluntary Superior Monitoring which will contain the detailed criteria that industrial sources would need to meet to be eligible for this program. We are still in the data gathering stage and are seeking ideas concerning this project, especially ideas concerning incentives and eligibility criteria.

In order to implement this program, we will need to conduct rulemaking. Revising all of the individual New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) to allow VSM would be daunting. Instead, we envision implementing this regulatory option by revising the general provisions to parts 60, 61, and 63. The general provisions contain the general monitoring, testing, recordkeeping, reporting, and other requirements common to all NSPS and/or NESHAP. In addition, we believe that this progrmam will also need to be implemented through the operating permit program in parts 70 and 71 which may need to be modified to allow this approach.

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