Recent EPA Guidance
- EPA does not intend for the calibration requirements of 98.3(i) to apply to any units where the rule allows the use of “company records” to quantify fuel usage or other parameters; however, a facility’s GHG monitoring plan must include descriptions of the procedures and methods used for quality assurance, maintenance, repair of all flow meters and any other instrumentation used to measure fuel consumption
- Comfort heaters and water heaters are considered to be part of the Subpart C source category
- Pilot fuel gas combustion is not considered to be part of the Subpart C source category
Recent EPA Guidance Response to Inquiries
- If Tier 4 is used and SSM emissions are routed through aseparate stack that is not equipped with a CEMS, missingdata procedures may be used to calculate thoseemissions
- HHV data used for Tier 2 and carbon content data usedfor Tier 3 calculations must be based on an approved testmethod listed in 98.34
- For units not required to use Tiers 3 or 4, Tier 2 can only betriggered if available HHV data is based on a test method listed inthe rule. If the reporter does not measure the HHV and does notroutinely receive results of sampling and analysis from the fuelsupplier, then use Tier 1. If frequency of HHV measurements isless than that listed in 98.34(a)(2) use Tier 1.