How do you design an emission monitoring program comparing CEMS vs emission factors?

Emission monitoring program design: regulatory requirements analysis (which sources require CEMS vs calculations), source characterization (continuous vs batch, emission variability), CEMS requirements (Part 60/75 applicability, affected sources), emission factor selection (AP-42, source-specific testing), mass balance methods where applicable, and parametric monitoring options (surrogate measurements with correlation). CEMS advantages: continuous actual measurement, required for cap-and-trade. CEMS challenges: capital/operating cost, maintenance requirements, data completeness requirements. Design total program: CEMS for large/critical sources, emission factors for smaller sources, periodic stack testing for verification. Document methodology per regulatory requirements and maintain records for audit.