PERM204: Compliance Assurance Monitoring (formerly NACT 220)

February 1, 2023

Mohsen Nazemi and Bob Waterfall

AGENDA PERM204 Agenda and also available in the EPA Airknowledge Learning Management System to registered students.

Permit writers and inspectors for major sources that are Title V facilities. Also those dealing with other major or minor facilities that may need to perform less intensive periodic monitoring.

This one-day course provides an overview of the compliance assurance monitoring (CAM) requirements associated with Title V sources, covering the following topics:

• Title V operating permits program
• CAM rule
• Applicability
• Who will be affected by CAM
• Who is exempt from CAM
• CAM timing
• Monitoring design criteria

After completion of this course, learners will be able to explain key aspects of CAM.


The CAM rule, which applies only to emission units with active control devices whose potential pre-control device emissions are at or above the major source thresholds, requires the Title V permits for these sources to contain monitoring sufficient to give a reasonable assurance of compliance with requirements applicable to the source and with all permit terms and conditions over the anticipated range of operation. Thus, emission units with an approved CAM plan will require sufficient monitoring to satisfy the periodic monitoring requirement under title V and part 70. CAM concepts like background, 40 CFR part 64 (CAM) applicability, who will be affected by CAM, who is exempt from CAM, CAM timing, monitoring design criteria, frequency of monitoring, source, Local or State permitting agency & EPA roles in evaluating CAM plans, and quality improvement plans will be discussed in this course.


NOTE: These are ONLINE training courses. The maximum attendance for each course is 45 students in order to allow for instructors to fully engage students and manage Q&A sessions, ultimately making each course more interactive. MARAMA will work with your state agency Training Coordinators to confirm and prioritize attendance as necessary. If ENROLLED, you will receive a confirmation notice from the LMS system for EACH COURSE you are enrolled in.


Course Registration Deadline Date: January 20, 2023

This training series will be held via EPA’s AirKnowledge Learning Management System (LMS) and WebEx. There is NO registration fee for this training. Students will need to do the following in order to REGISTER FOR EACH COURSE INDIVIDUALLY on the LMS:

  1. Create a PROFILE in the EPA AirKnowledge LMS: If you have not already done so, please create an account in the new LMS here. Please reference the attached LMS Flier for instructions on how to set up your profile.
  2. REGISTRATION within the LMS: To do this, please follow these instructions (see attached student user guide for additional LMS and WebEx information):

·             Log-in to your account and hover over the “My Training” tab on the home page.
·             Select the third option under “My Training” entitled “Instructor Led Training Calendar.”
·             Change the applicable month in 2023, if it is not already and scroll down to the course date and click on the course title.
·             Register for the WAITLIST for EACH course by clicking on the blue REQUEST button.
·             Once you have received confirmation of your enrollment in each course, please take the OPTIONAL PRE-TEST by following the instructions on the attached LMS and WebEx USER GUIDE. The deadline to take the pre-test is January 31, 2023 for the PERM 204 and TOXC102 course.

  1. TRAINING ACCESS: Instructions for accessing each training course will be forwarded to all registered students via an LMS generated email prior to the training.


If you have any questions, please email Sharon Ray ( or Jackie and Sue (