Part 75 Desk Audit Update

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.

 

Latest Developments in the LME EDR Utility

The EPA Clean Air Markets Division (CAMD) has announced a permanent delay in the ECMPS re-engineering project. While they haven’t set a definite start date for the transition to the new web-based ECMPS 2.0 interface with JSON formatted reports, we anticipate it won’t commence until at least the first quarter of 2025. Additionally, the EPA has reiterated that there are no plans to integrate the capability to generate low mass emissions (LME) EDRs into the ECMPS 2.0 client tool. Facilities responsible for reporting LME EDRs are advised to seek alternative solutions and establish a transition plan beforehand.

VIM continues to evolve and provide a solution for generating both XML and JSON formatted EDRs through our web-based LME EDR Utility. Users can use this platform to create XML EDRs for import into the current standalone ECMPS Client tool while exploring the JSON EDR capability for ECMPS 2.0 beta testing. We are committed to staying abreast of all re-engineering work and will provide updates to the LME utility when schemas or API interfaces get changed.

We hope that EPA will clarify the overall progress of the re-engineering project at the upcoming EPRI CEM User Group conference in Scottsdale, AZ, from May 21 – 23, 2024. VIM Technologies Inc. will be on hand and will provide an update on the status of the re-engineering project at the meeting’s conclusion.

If you’re interested in hearing more about the LME utility or have questions about the re-engineering project in general, please get in touch with Rudi Muenster at rudi.muenster@vimtechnologies.com.

VIM Technologies Unveils New LME EDR Solutions at EPRI

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.

As a leading provider of emissions monitoring software, we are excited to bring our latest solutions to the forefront and share our industry insights with attendees. Our VP of Environmental Products, Rudi Muesnster, will present on LME EDR Solutions for ECMPS 2.0. The presentation will cover the re-engineering effort of the Emissions Collection and Monitoring Plan System (ECMPS) Client Tool and its direct impact on Low Mass Emitter (LME) sources. With the introduction of the new web-based ECMPS 2.0 reporting tool, a key feature of the original ECMPS client tool will no longer be available. We will provide industry alternatives and options for generating LME EDRs without the burden and cost of installing a full-blown Data Acquisition and Handling System (DAHS). We invite you to attend this presentation!

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.

EPA Administrator Signs Final Testing Provisions for Air Emission Sources Rule

UPDATE (March 29, 2023)

Final Testing Provisions for Air Emission Sources Rule Published in Federal Register

The final “Testing Provisions for Air Emission Sources” rule was published in the Federal Register on March 29, 2023. The rule is effective on May 30, 2023. A copy of the final rule is available here

On March 7, 2023, the EPA Administrator signed the final “Testing Provisions for Air Emission Sources” rule and submitted it for publication in the Federal Register. The rule will become effective sixty (60) days after the date of publication in the Federal Register.
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ECMPS 2.0 Re-Engineering

Did You Know?

The Emission Collection and Monitoring Plan System (ECMPS) 2.0 web-based reporting platform is scheduled for mandatory reporting by Acid Rain Program, Cross-State Air Pollution Rule (CASPR), and Mercury Air Toxics Standards (MATS) Rule (Subpart UUUUU, 40 CFR Part 63) affected sources in 2024. More specifically, the Q1 2024 emissions and quality assurance (QA) files must be submitted via ECMPS 2.0 in JSON format by April 30, 2024, reporting deadline.Read more »

VIM Technologies Praised for Virtual Part 75 Training Course

VIM Technologies, Inc. (VIM) has successfully completed another Introduction to Part 75  virtual training course led by Senior Air Compliance Specialist Dru Sanders, with assistance from VIM’s COMPAS Division.

Introduction to Part 75 is an intermediate course recommended for environmental staff responsible for complying with 40 CFR Part 75 regulations. We typically offer this course twice during each calendar year.Read more »

VIM Technologies’ Part 60 CEMS and COMS Requirements Virtual Training

VIM Technologies’ (VIM) Senior Air Compliance Specialists, Eric Wiley, and Dru Sanders, co-presented the Part 60 CEMS and COMS Requirements online training course with high praise from those who attended.

This comprehensive course covered the required material in 2-hour sessions across 3 consecutive days. Attendees were thrilled with the virtual schedule that allowed flexible access to the training and eliminated the need for travel. The detailed course manual and the ability to download various supporting regulatory documents were a significant benefit to all participants

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Digital Transformation: The Fourth Industrial Revolution

The Fourth Industrial Revolution, called 4IR or Industry 4.0, is named for the rapid change in technology, data connectivity, and smart automation that is driving improvement trends throughout the industrial world. Roughly starting in the early 2000s, companies have been implementing changes to improve productivity, efficiencies, and profitability by investing in digital technologies. Machine Learning, Industrial Internet of Things (IIoT), and decision-based software systems are becoming commonplace as costs come down and the need to stay competitive drives buying choices. Regardless of the industry type, companies are making strategic decisions on how best to apply digital technology to their day-to-day operations.

Research shows the primary focus for most digital transformation projects is on process improvements that enhance the customer experience, reduce energy usage, and minimize unplanned downtime. Beyond these main objectives, Industry 4.0 uses technology to help meet Environmental, Social, and Governance (ESG) sustainability by focusing on social development and environmental stewardship. Through these initiatives, companies are addressing not only how they do business now, but the way they will do business in the future. Many ESG digital investment decisions are driven by which aspect of sustainability nets the best results the fastest. Unlike the impact of manufacturing process changes, digitalization investments in ESG are about the long game.

The rewards from these efforts may not hit the bottom line immediately but they do go a long way towards shoring up interest from investors and meeting company sustainability goals. The commitment to a digital strategy gives companies the opportunity to use data connectivity and transparency in conjunction with technology to achieve all of their transformation objectives. All efforts are focused on finding the balance between the digital world while enhancing the human experience, profitability, and ESG sustainability. The urgency to act now and the speed of technological advances opens the potential for implementation pitfalls. Clear thinking and dedication to involving all the company stakeholders are critical before expecting any digital strategy to have the desired impact.Read more »

EPA Publishes Revisions to Greenhouse Gas Reporting Rule in Federal Register

NEW UPDATE:

On July 19, 2022, EPA extended the comment period on the proposed “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” from August 22 until October 6, 2022.  A copy of the Federal Register notice is available here.


On June 21, 2022, EPA published the proposed “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” (i.e., 40 CFR Part 98) in the Federal Register. A few selected proposed amendments are discussed below.Read more »

EPA Good Neighbor Plan

Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard Published in Federal Register

UPDATE:

On May 12, 2022, EPA extended the deadline to submit public comments on the proposed “Good Neighbor Plan” from June 6 until June 21, 2022. A copy of the Federal Register notice is available here.


On April 6, 2022, EPA published the proposed “Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard” in the Federal Register. EPA is proposing this rule under the “good neighbor” or “interstate transport” provision of the Clean Air Act (CAA or Act). The proposed rule, referred to by EPA as the Good Neighbor Plan, includes several key components discussed below.Read more »