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EPA Publishes Updates Correcting Inaccurate Testing Provisions, Outdated Procedures, and More

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On October 7, 2020, the EPA published updates in the Federal Register to correct inaccurate testing provisions and outdated procedures, as well as adding approved alternative procedures which allow more flexibility to testers. It includes performance specifications in 40 CFR 51, 60, 61, and 63.

One noteworthy addition includes the clarification of response time from “must not exceed 2 minutes” to “must not exceed 240 seconds” in 40 CFR 60, Appendix B, PS4B, section 4.5.

There is also a stipulation on the 40 CFR 60, Appendix F, Procedure 1, section 5.2.3(2) the criteria for CGAs as applicable to diluent monitors is included. For sites subject to 40 CFR 63, Subpart LLL, the units of measure in Equations 12 (THC operating limits), 13, 17, 18, and 19 are revised for clarity.

The rule is effective on December 7, 2020. Please review the rule under 85 FR 63394 for more details.

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.

EPA Signs Final Revisions to 40 CFR Part 63

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EPA Seal

On October 1, 2020, the EPA Administrator signed final revisions to 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants for Source Categories.

The rule will become effective sixty (60) days after publication in the Federal Register.  The rule is designed to formalize EPA’s 2018 guidance memorandum which overturned EPA previous policy of “once in, always in” (OIAI), which is often referred to as the May 1995 Seitz Memorandum.

The rule also finalizes revisions to the Part 63 General Provisions clarifying “that a major source can be reclassified to area source status at any time upon reducing its potential to emit (PTE) hazardous air pollutants (HAP) to below the major source thresholds (MST) of 10 tons per year (tpy) of any single HAP and 25 tpy of any combination of HAP.”

Additionally, the final rule specifies compliance dates, notification, and recordkeeping provisions applicable to sources electing to reclassify to area source status or to sources reverting back to major source status.  A copy of the prepublication version of the rule is available here.

Clean Air Markets Division Updates Part 75 Policy Manual

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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.Read more »

Managing DAS & CEMS Systems: Top 5 Challenges and Solutions

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Updated Original Post Dated: April 23, 2019

Compliance Managers can only be effective if the data they’re accessing is current and thorough. Multiple regulations coming into play, outdated DAS, or incomplete testing are just some of the many challenges Compliance Managers face.

When overcoming these challenges, if you document the solutions the lessons learned can be invaluable tools for future reference and training new employees. With that in mind, we’ve assembled the top 5 challenges faced when managing DAS and CEMS systems — and recommended solutions to address the issue.

Challenge: Late or Incomplete QA Test
Solution: Be Proactive with Tracking QA Test Deadlines

Missed or incomplete testing can result in excessive downtime. Excessive downtimes can be very expensive for sources in trading programs such as ARP, SIP, CSAPR, and RGGI. One way to combat these challenges is to be proactive with tracking QA test deadlines – don’t wait for ECMPS to tell you. Having a thorough understanding of what qualifies for an extension and/or grace period can help ensure you’re conducting and submitting information on time.

The CEMLink 6 compliance calendar and QA test deadline features allow users to track and monitor Part 60 ongoing QA tests in addition to inspection and site-specific operating limits (SSOL) required by many MACT regulations. Learn how to use these helpful tools in this pre-recorded webinar, available for download here.Read more »