On September 28, 2020 the Clean Air Markets Division (CAMD) posted an update to the Part 75 Emissions Monitoring Technical Q&A (also known as the ‘Part 75 Policy Manual’) that contains five new questions and two revised questions. You can access the new and updated questions here.
The new questions center around Like-Kind monitors, Low Mass Emitters (LME) and Part 75 Appendix D Fuel Flowmeters. The most notable question, Question 23.22, provides clarification on the minimum data capture requirements for Appendix D certifiable fuel flowmeters. EPA has now stated that each fuel flowmeter must meet the minimum data capture requirement for continuous monitoring systems in 75.10(d)(1), the same requirement for CEMS.
We are pleased to report that the CEMLink line of products have been implementing this very approach for decades. There is no need to update the DAHS for this programming but more importantly, no potential risk of underreporting.
If you have any questions on the recent update or how they may impact your facility, contact VIM COMPAS at COMPAS@vimtechnologies.com. The VIM COMPAS Team is ready to assist you.
