CC-15-001: Applicability of Quality Assurance and Control Requirements for Continuous Opacity Monitoring Systems (Procedure 3) to Forest Products Industry Sources

This memorandum addresses questions regarding the applicability of recently promulgated quality assurance and quality control (QA/QC) procedures for continuous opacity monitoring systems (COMS). The final rule appeared in the May 16, 2014, <em>Federal Register</em> and subjects all COMS used to demonstrate continuous compliance with opacity standards in NSPS rules to QA/QC procedures. This rule will be of interest to companies operating NSPS boilers, recovery furnaces and lime kilns that are subject to opacity standards. Although this final rule became effective on November 12, 2014, NCASI has been tracking miscellaneous questions regarding the applicability of this rule to NSPS sources in kraft pulp mills (Subparts BB and BBa) and boilers (Subparts D, Db and Dc). This memorandum addresses these questions and summarizes a broad EPA response to industry questions on applicability.