Subject: CAM Applications to Engines with Catalytic Converters
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked]
Date: Fri, 14 Dec 2001 12:08:03 -0800 (PST)

I am trying to compile a list of engines with catalytic converters that will be subject to Compliance Assurance Monitoring (CAM) regulations.  All of the following four conditions must be met for CAM to apply:
1.  The emission unit must be located at a facility with a Title V permit.
2.  The emission unit must be subject to an emission limitation or standard, including a permit condition, for an applicable regulated air pollutant.
3.  The emission unit must use an add-on control device to achieve compliance with the emission limit or standard.  
4.  The emission unit must have "potential pre-control device emissions" equal to or greater than the amount required for a source to be classified as a major source under Title V (i.e. 100 tpy for criteria pollutants and 10/25 tpy for HAPs). 

If an emission unit is subject to CAM then a CAM Plan must be prepared and submitted with a Title V Permit application/renewal.  I will develop a standard plan for submission.

 A list of all the engines with catalytic converters is attached based on Power Services database.  Review the list for accuracy.  In addition, update the Title V status of each facility.  The last two columns (major for CO w/o controls and major for NOx  w/o controls) are based on AP-42 factors for rich-burn engines and a specific heat rate of 8500 Btu (LHV)/bhp-hr converted to 9350 Btu (HHV)/bhp-hr to determine whether a unit would be major for CO or NOx pre-control.  Review the permits for the units that would be major for NOx and/or CO to determine if an emission limitation or standard applies to the pollutant for which the unit would be major.  Let me know by January 15 which units you believe will require a CAM plan. 

Ruth