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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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