Is COM/CEM monitor downtime a deviation?
If monitor availability requirements are identified in the permit and actual monitor uptime is less than that required, then those periods would be deviations. If availability requirements are not specified in the permit then downtime would not be a deviation from the permit. If regulations and standards contain monitor availability requirements, yet they are not contained in the permit, the facility must still meet the requirements even though they do not have to consider it a deviation in their TVACC. 9. My Title V permit requires that I submit operational ranges for my fabric filter which provide a reasonable assurance of compliance. What am I certifying compliance with in this particular condition? This is a standard condition used in Title V permits to fulfill periodic monitoring requirements. The condition usually states that owner/operators install, operate, and maintain parametric monitoring devices. It also states that operational ranges be developed and submitted to the Depar