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The Final Proposed Revisions to the Mercury and Air Toxins Standards (MATS) Reporting Rule published on September 9, 2020 triggered a new approach to processing and reporting downtime events under the EGU MATS requirements. These changes will be reflected in the upcoming Semiannual Compliance Report which cover the period from June 1 through December 31, 2020. This report is submitted to your local air quality agency and is due no later than midnight on January 30, 2021.

The handling and reporting of downtime events will be addressed using one method prior to September 9, 2020 and differently for all following downtime events occurring on September 9 and later.

Prior to September 9, 2020 downtime events were reported in the semiannual compliance report as downtime events. But starting on September 9, 2020 some downtime events were addressed as a downtime event AND deviation, while certain other types as a downtime event ONLY.  The linked guidance document (Are All MATS Downtime Events Deviations – No!)  explains the difference in reporting downtime events after September 9, 2020.

Since this new reporting definition for downtime deviations occurred in the middle of the semiannual period, it triggers the need to address downtime events differently before and after the date (September 9, 2020) the final MATS reporting regulations were published in the Federal Register.

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Jon Konings

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