Compliance Related Resources Archives

VIM Technologies at CAPCA Spring 2025: Conference Highlights

Posted April 24, 2025May 16, 2025

We had a fantastic time at the CAPCA Spring Conference, held April 9–12, 2025, at the beautiful Omni Grove Park Inn in Asheville, NC! We’re so proud to have participated alongside so many great people—our customers, and friends—from Domtar, Duke Energy, Georgia Pacific, Giant Cement, Ingevity, Nucor, Smurfit Westrock, University of South Carolina, and many more. It was a privilege to share the floor with our industry-leading partners: Air Hygiene, Alliance Technical Group, B3 Systems, M&C Technical Group, STI CEMS, and Thermon.

Conference Highlights

The CAPCA Spring Conference brought together the best minds in air quality and environmental compliance for a week of learning, networking, and innovation. Some of our favorite moments included:

Deep Dives into CEMS Innovations: We explored the latest advancements in Continuous Emissions Monitoring Systems and data-driven approaches for real-time compliance monitoring.
Insightful Regulatory Panels: Panels on emerging regulations and best practices for air permit management provided practical takeaways for staying ahead of compliance requirements.
Capital Project Commissioning Tips: Experts shared tips and strategies for commissioning capital projects that support environmental compliance and operational excellence.
Regulatory Updates: We received valuable updates from the EPA, as well as North Carolina and South Carolina regulatory agencies, helping everyone stay informed on the latest changes.

Thank You for Making It Special

We extend our sincere thanks to everyone who stopped by our booth, joined our conversations, and contributed to the dynamic spirit of the event. Your insights, questions, and enthusiasm are what make the CAPCA community so special.

VIM Technologies is a proud supporter of the Carolina Air Pollution Control Association. We deeply value the relationships and knowledge shared at this conference—insights that drive innovation and help shape tomorrow’s solutions in emissions monitoring and environmental compliance.

We look forward to seeing you again at future CAPCA events!

ECMPS 2.0 Rollout Delayed to 2026: What You Need to Know

Posted April 23, 2025

On April 22^nd, 2025, EPA’s Clean Air and Power Division (CAPD) provided a status update on the ECMPS 2.0 re-engineering effort. The blog post can be found here.

The key takeaway from the message is the delay for ECMPS 2.0 implementation until at least Q1 2026 (from Q3 2025). This announcement didn’t take us by surprise considering the beta testing environment has been unavailable for 9 of the last 10 months!

If you haven’t already done so, we strongly encourage you to get set up with CDX and CBS test accounts and start playing around with the new ECMPS 2.0 web-based client tool. EPA created a quick start guide that will walk you through setting up your test accounts in all applications (CBS, CDX and Login.gov). It also describes the various roles and responsibilities within CDX and what to expect during the official migration expected sometime next year. To get a copy of the startup guide click here or visit the re-engineering page at https://www.epa.gov/power-sector/ecmps-re-engineering-effort.

We are excited to hear that ECMPS 2.0 beta environment is back on-line, but most importantly to hear that it’s been backfilled with historical MP, QA, and EM data through Q3 2024. The ECMPS 2.0 tool, even when it was on-line, was relatively unusable due to out-of-date records in monitoring plans and the divergence of data between production and beta systems. Any JSON files that were produced by a DAHS likely contained outdated monitoring plan information that weren’t present in the beta system.

Some other good news is that there was no mention of any JSON schema updates. This means that any CEMLink6 DAHS systems running 6.2.620 or greater are equipped with the tools they need to start playing around in the beta environment. If you’re unsure the version you’re running or need help getting your DAHS updated, please contact our support group at support@vimtechnologies.com or call us 1-866-484-6435 and follow the prompts for support.

Unfortunately, one area where EPA is digging in their heels, is regarding Contractor Access. This is a topic we have been very vocal about to both EPA and industry for the last 3 years. This is a feature that’s available in CBS and the current stand-alone ECMPS 1.0 Client Tool and one that the vendors (DAHS, Consultants and Stack testers) rely on to access key information. Without an equivalent feature in ECMPS 2.0, industry will be forced to add a significant number of preparer agents under the sponsor (original DR or ADR) to get the support they need. It’s imperative that industry press EPA on this subject because it will pose a significant burden to you as it’s currently architected.

VIM will continue to stay abreast of the ECMPS 2.0 developments and update this blog as relevant information becomes available. Please contact our COMPAS group at compas@vimtechnologies.com for more information concerning the ECMPS 2.0 implementation or any questions you may have.

President Signs Proclamation Granting MATS Rule Exemption For Certain Sources

Posted April 18, 2025May 16, 2025

On Tuesday, April 8, 2025, the President issued a Presidential Proclamation exempting specified stationary sources, listed in Annex I of the Proclamation, from compliance with the “National Emissions Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review” (89 Federal Register 38508) (the “Rule”). A copy of the Proclamation and Annex I list is available HERE. As specified in the Proclamation, the President’s exemption extends the compliance deadline for two (2) years beyond the Rule’s current compliance date (i.e., for the period beginning July 8, 2027 through July 8, 2029). During the 2-year exemption period, the coal-fired sources listed in Annex I are subject to the compliance requirements that they are currently subject to under the Mercury and Air Toxics Standards (MATS) as the MATS Rule existed before the “RTR” MATS Rule (89 Federal Register 38508).

Facilities listed in Annex I must maintain compliance with the pre-RTR MATS standards. Monitoring, reporting, and quality assurance programs should continue to follow the requirements in place before the 2024 RTR amendments. Affected sources not listed in Annex I must comply with the RTR MATS Rule requirements effective July 8, 2027. It is unclear if MATS affected sources not listed in Annex I can request a similar Presential exemption.

While the exemption provides temporary relief to some sources, facilities should continue preparing for eventual compliance with the RTR MATS Rule. Proactive planning and system readiness are essential for long-term compliance.

For more information or to schedule a compliance consultation, please contact VIM Technologies, Inc. (VIM). VIM remains committed to being a trusted partner in environmental compliance, helping clients navigate regulatory changes with confidence and precision.

Stay tuned to the VIM Technologies News section for ongoing updates and expert insights on air compliance regulations.

ECMPS 2.0 Update EPA Announces Q3 2025 Rollout and Key Changes

Posted January 23, 2025May 15, 2025

On December 20^th, 2024, EPA’s Clean Air and Power Division (CAPD) provided a status update on the ECMPS 2.0 re-engineering effort. The blog post can be found here.

Their message addressed the following three (3) key points:

Copies of the ECMPS 2.0 monitoring plan, quality assurance and emissions reporting instructions were posted.
They confirmed that the initial rollout of ECMPS 2.0 would NOT contain any new MATS related records.
ECMPS 2.0 via the new web-based utility has a tentative earliest effective date of Q3 2025.

Now that EPA has brought the ECMPS 2.0 beta system back on-line and penciled in a deadline of 2025 Q3, industry should be prepared to re-engage with the project. There are no plans to run both systems in parallel so the transition will be aggressive when it occurs. DAHS vendors have what we need to prepare industry for reporting. Detailed below are a few things you can do to prepare for the deadline:

EPA has finished migrating security and login capability for the ECMPS 2.0 beta systems from CAMD Business System (CBS) to Central Data Exchange (CDX) and Login.gov. If you haven’t already familiarized yourself with the CDX and Beta startup guide, we encourage you to do so. To access a copy of the startup guide please click here.
Reach out to your DAHS vendor to discuss their plans and to schedule an update. Most vendors have been testing in the beta environment since it came back on-line earlier this fall. VIM recently announced to all Part 75 CEMLink customers that an update (Ver. 6.2.620) is available for users who want it to test in the beta environments. We have been encouraging end users to update to familiarize themselves with the new ECMPS 2.0 web-based interface. EPA has been spending time on critical bug fixes rather than usability enhancements, so the look-and-feel of the screens are a bit crude.
Provide feedback on your experience with the new interface to EPA. Once your set up with the required test accounts (in CDX and CBS), you can provide feedback to EPA via ecmps-beta@camdsupport.com. It’s important that industry acquaint themselves with the new interface and workflow. There are significant changes to Agent designations and EPA has not re-established “Contractor Access” like we have in the current environment. It’s imperative that industry press EPA on this subject because it will pose a significant burden to you as it’s currently architected.
MATS-affected sources should contact their stack test contractors to ensure that they will continue to provide the applicable required MATS stack test data elements specified in Sections 17 through 30 of Appendix E to the MATS Rule in XML format. EPA will likely continue with the “attachment” approach until there are at least a few years of run-time in the new environment. We don’t expect EPA to re-engage with vendors or industry until at least 2026 to discuss the additional MATS data elements.

ECMPS 2.0 Update

Posted July 23, 2024April 25, 2025

The ECMPS 2.0 launch date continues to be postponed indefinitely, and EPA has stated that it will not be rolled out in calendar year 2024. Additionally, on June 3, 2024, EPA’s Clean Air and Power Division (CAPD) announced that the ECMPS 2.0 Beta and CBS Beta systems were going offline for several weeks due to maintenance. This effectively halts any testing that DAHS vendors and industry participants were performing on the new system, but also gives us time to reflect and strategize on what the year ahead looks like. Additional details regarding this scheduled maintenance event can be found in EPA’s blog post here. We wanted to take this opportunity to brief you on some important details related to the re-engineering project and what to expect once the beta systems come back online later this summer.

If you attended the EPRI May 2024 CEMUG Conference, you learned that EPA is about to make a significant pivot on the re-engineering project. While not officially going on record saying it, EPA looks to be making major changes to the direction and scope of the web based ECMPS Client Tool. It appears EPA is re-focusing its efforts squarely on the original scope from 2019, which was simply to build a web-based version of the Client Tool with the same functionality as the current one, but with a shift from XML to JSON file formats. Therefore, it is a strong possibility that EPA will pull the new MATS-related test records, originally slated for Phase II of the web-based Client Tool, from the initial rollout of the ECMPS 2.0 Client Tool. The details listed below surrounding the re-engineering project also validate this theory.

The JSON schema documents (files that dictate what the reports should look like) for QA and EM reports do not contain ANY MATS-related elements. Test elements such as ACA, RAA, CGA, RCA, PS-11, and even the MATS quarterly compliance report are absent from the schema. While we do have draft copies of the accompanying reporting instruction documents that do contain them, there are numerous errors and omissions that make it difficult to implement. One area that needs significant improvement is the deviation and downtime section. CAPD really needs to consult with OAQPS, industry, and DAHS vendors on the formal construction of these records.
EPA has been focused on another major change, the migration from the CAMD Business System (CBS) to Central Data Exchange (CDX). With this change, all users will need to register on CDX. If you haven’t already familiarized yourself with the CDX and Beta startup guide, VIM Technologies (VIM) encourages you to do so. A link halfway down the page will take you to the most recent version of the guide (November 21, 2023, at the time of writing).
EPA announced last year that the vendor who had been working on the re-engineering project was being replaced. The new vendor, ERG, is the same one responsible for the existing standalone ECMPS Client Tool, so the learning curve won’t be as steep. It’s safe to assume that this project will be broken up into smaller, more manageable chunks, with MATS records potentially feeling the brunt of the delay, likely to 2026 or beyond.
EPA spent considerable time building a mechanism to submit multiple file types via the MATS Data Submission module. While it’s lumpy and leaves a lot to be desired, it’s in place and functional. It also gives industry a mechanism to submit just about any file type they believe complies with the MATS Rule. We believe CAPD will take this opportunity to circle the wagons with OAQPS, industry, and DAHS vendors to work on the language and clear up the file format for the MATS data, including the quarterly compliance report.

While there is a great deal of confusion concerning the format in which to report certain MATS compliance data (e.g., quarterly compliance reports, PM CEMS hourly data, etc.), it is clear that the respective data elements in Sections 17 – 30 of Appendix E must be submitted in XML format via the ECMPS MATS Data Submission module for MATS compliance tests conducted on or after January 1, 2024. These MATS tests include Hg RATAs and SO₂ RATAs (if used for MATS compliance), Hg LEE tests, performance tests, PM CEMS RRAs, RCAs, and initial PS-11 correlation tests. Additionally, the “Supporting Test Information For Each Test” specified in Section 31 of Appendix E must be submitted in PDF format via the ECMPS MATS Data Submission module. To meet the Section 31 requirements, many affected sources are opting to submit a PDF copy of the complete test report.

One thing is clear – CAPD needs to re-engage with industry, vendors, and even OAQPS to openly discuss technical details on the re-engineering project. Those of us who were around for the MDC to ECMPS migration know how much time and effort this takes. It was only achievable with open lines of communication, clear instructions, achievable timelines, and measurable results.

VIM will continue to stay abreast of the ECMPS 2.0 developments and update this blog as relevant information becomes available after the maintenance period is over. We will have an update available to CEMLink6 later this summer so our users can beta test the ECMPS 2.0 Client Tool.

For those interested, we have several sessions dedicated to Part 75, the ECMPS 2.0 re-engineering project, and MATS program updates at our upcoming CEMLink6 and Regulatory training in Dallas, TX, at the DFW Lakes Hilton from Nov 5-7, 2024. For more information regarding this event, please visit our information page here.

Please contact our COMPAS group at compas@vimtechnologies.com for more information concerning the ECMPS 2.0 implementation or any questions you may have.

Part 75 Desk Audit Update

Posted June 26, 2024June 26, 2024

The Clean Air & Power Division (CAPD), formerly known as the Clean Air Markets Division (CAMD), continues to conduct virtual Part 75 continuous emission monitoring system (CEMS) program audits referred to as “Part 75 Desk Audits.” Initially, the Desk Audits primarily focused on coal-fired units equipped with full CEMS. Part 75 Desk Audits are conducted by CAPD personnel or contractors and typically last approximately four (4) months. Ongoing communication is handled via emails and/or conference calls. Information requested from the plant usually includes:

Quality Assurance/Quality Control (QA/QC) Plan
Hardcopy Monitoring Plan, including all schematics and diagrams
Latest relative accuracy test audit report
Targeted CEMS logbook entries for previous year
Various photos of CEMS shelter, analyzer serial numbers, and images of current daily calibration error test and linearity check PGVP cylinder certifications.

These audits also included a review of the QA/QC requirements for mercury (Hg) CEMS and/or Hg sorbent trap monitoring systems used for compliance with Subpart UUUUU to Part 63 (aka The MATS Rule).

During the May 2024 EPRI CEMUG Conference, CAPD gave a presentation which discussed expanding the scope of the Part 75 Desk Audits to include requirements and checklists specific to gas- and oil-fired units using Appendix D & NOx CEMS as well as peaking units utilizing Appendix E NOx correlation curves. In addition to the standard information request listed above, some checks specific to gas- and oil-fired units include, but are not limited to:

Documentation that the fuel meets the definition of pipeline natural gas (PNG) or natural gas (NNG).
Verification that fuel flow is corrected to EPA “standard conditions” as defined in §72.2
Fuel sampling procedures
Fuel flowmeter QA test procedures

The CAPD presentation also discussed conducting Appendix D correlation checks to detect discrepancies in reporting heat input. In general, the check compares hourly heat input values at the same load bin in two adjacent calendar quarters. The check only considers bins 5 – 10 and there must be at least 168 hourly values or more in a bin. CAPD stated that their initial analysis showed that most Appendix D units reported consistent heat input data. In a few cases, issues with fuel flowmeter “scaling factors” required resubmission of quarterly emissions files.

VIM has reviewed a draft Appendix D checklist from the Part 75 Desk Audit Manual and is ready to help. VIM has successfully conducted numerous CEMS program audits. Audits can be tailored to assess compliance with air permit requirements, 40 CFR Part 75, 40 CFR Part 60, 40 CFR Part 63 and Greenhouse Gas Reporting rule specifications. A comprehensive audit can provide an objective assessment of compliance with the applicable federal and State regulations and evaluate the efficiency of your overall CEMS program. During the audit, VIM conducts a detailed review of the QA Plan, Monitoring Plan, CEMS maintenance logs, corrective maintenance activities, and associated standard operating procedures. VIM also reviews the data acquisition and handling system (DAHS) to ensure that calculations are performed correctly.

VIM typically conducts a review of documentation prior to performing an on-site inspection of CEMS equipment and other site records. This process makes the site visit more efficient, requiring less time for your busy plant staff. VIM’s findings and recommendations are submitted in a formal report. If you’re interested in hearing more about the Part 75 Appendix D Desk Audit guidance or an audit for your facility, please contact Dru Sanders at dru.sanders@vimtechnologies.com or at (410) 859-5455 Ext. 4051.

Category: Compliance Related Resources

We are thrilled to announce that VIM Technologies will be exhibiting and presenting at the 31st Electric Power Research Institute (EPRI) Continuous Emissions Monitoring User Group Meeting. This premier event is scheduled to take place on May 16-17, 2023, at The Galt House in Louisville, Kentucky.

We also invite you to visit our booth. Our team will be available to answer questions and demonstrate our software solutions. You can find us at Booth #3.

The EPRI Continuous Emissions Monitoring User Group Meeting. is an excellent opportunity for industry professionals to network, learn, and stay up-to-date on the latest developments in continuous emissions monitoring.