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One Page Tip: June 2020
Part 75's New Interim Final Rule Related to the COVID-19 Pandemic

Regulatory references: 

P75 New Interim Final Rule Related to the COVID-19 Pandemic.  

Background:

The Clean Air Market Division (CAMD) at the USEPA have provided recent guidance to address those unforeseen situations triggered by the COVID-19 pandemic.  This guidance is referred to as the Part 75 Interim Final Rule and can potentially provide relief going back as far as March 13, 2020. There have been reports of some sites locking down and limiting access to outside contractors, including stack testers.  Even though some states are removing their travel restrictions, some facilities might continue their recently imposed restricted access policies.

This One Page Tip will address new and potentially complex twists in Part 75 reporting regulations that need further investigation. This can be especially challenging because some monitoring systems (SO2 and flow) are used in both the reporting programs for Part 75 and MATS, but the Interim Final Rule does not necessarily apply to MATS data sets.  

Did you know about the recently issued Interim Final Rule for Part 75?  An alternate option is available for facilities to use if they are unable to perform the required quality assurance activities because of travel or other restrictions due to the COVID-19 virus.
 
For example, you may not be able to perform a RATA or a linearity before the end of a quarter due to restricted facility access. Instead of flagging the data as missing and using a replacement value from the missing data algorithms, in this case the data is still considered to be valid, but it needs to use an hourly method code of 54. The use of this method code begins with the first hour of the new calendar quarter and ends with the final hour of the successfully completed RATA or linearity.  For help in assigning the method code of 54, or to discuss the details with this alternate and temporary option, contact ESC | Spectrum for assistance.

For questions, suggestions, or for a general chat, please do not hesitate to contact me.

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Jon Konings

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