Regulatory Information

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Don't Overstate Your NOx Emissions - When your NO Sensors warm up... so does your reading!! See how ENERAC's innovative solution gives you true NO readings.

Emssions Testing Frequently Asked Questions(FAQ) - Become an expert in emissions testing techonolgy. A Must Read for any technician.

EPA Issues Periodic Monitoring Guidance - Title V monitoring requirements.

CTM-022 - Determination of nitric oxide, nitrogen dioxide and NOx emissions from stationary combustion sources by electrochemical sensor analyzer.

Credible Evidence - White Paper
Credible Evidence - Regulations
EPA solicited public comment on a proposal to amend 40 CFR Parts 51, 52, 60 and 61 to eliminate language that has been read to provide for exclusive reliance on reference test methods as the means of demonstrating compliance with various emission limits under the Clean Air Act (CAA). These revisions--generally referred to as the "credible evidence" revisions--were designed to clarify that non-reference test data can be used in enforcement actions, and to remove any potential ambiguity regarding this data's use for compliance certifications under Section 114 and Title V of the Act.

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Persons to Contact for Permits

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EPA's Credible Evidence Rule
Has Dramatically Increased Clean Air Compliance Risks

On February 13, 1997, the EPA issued the final promulgation of its Credible Evidence Rule. This rule dramatically expands the types of data that EPA, states, and citizens can use to allege, even determine that an emissions violation has occurred.

On February 13th, Administrator Browner signed the EPA's Clean Air Act Credible Evidence Rule. This rule is now the law of the land.

Under the Credible Evidence Rule, procedures that had previously been seen as only indicators of proper O&M (quarterly testing - operating parameters, etc.) can now be used by the EPA, the states, and the public to demonstrate noncompliance .... significantly increasing compliance risks.

Until February 13th, the EPA had to rely almost exclusively on data from infrequent "Reference Method" testing to demonstrate that a violation had occurred. The Any Credible Evidence (ACE) rule has significantly reduced this burden of proof. The ACE Rule will now allow the use of non-reference method direct emissions data, parametric data, engineering analysis, witness testimony or other information, to be used as evidence to determine whether a facility has violated its emission standards.

The preamble to the rule also reasserts EPA's position that:
sources are required to be in compliance at all times (except where specifically excused, e.g., start-up, shutdown or malfunction) and across all normal operating conditions and loads.

Compliance demonstration is no longer limited to only one specific operating condition /or load. In response to this rule, many sources have been advised to:
immediately reevaluate their permit applications and monitoring requirements exclude "any monitoring data or methods" they would not wish to see used in determining their compliance status utilize only "defensible" quality assured data for compliance reporting

This effort to build a "Ring of Quality Assured Defensible Data" is a prudent risk management approach. It will help to establish the quality of data which a source represents as sufficient to demonstrate compliance (data reciprocity), while providing a quality assured emissions profile to protect against the possible misinterpretation or misuse of less accurate incidental data.

For major NOx sources, the use of the Enerac 3000 Series of Compliance Level Analyzers, can help provide just such a "Ring of Quality Assured Defensible Data". The Credible Defense for Credible Evidence

The Enerac 3000, which utilizes advanced SEM sensor technology, a product of an extensive joint development effort with the scientists at City Technology Limited, provides the technical capabilities to:

• meet all the performance requirements of the EPA NOx test method CTM-022
• provide documented QA/QC performance
• protect against the real danger of inadvertently overstating a source's actual emissions.

When such high quality emission data is used for Periodic Monitoring, CAM Plan Development etc., it can help provide a Credible Defense against the possible misuse or misinterpretation of less credible - less accurate data. In fact, the Enerac 3000 performance is so good that it has even been used for Compliance Level source testing. Enerac 3000 users have been allowed by several states to utilize the Enerac 3000 to conduct their own compliance level source testing. They have not only decreased their risk, but have produced cost savings estimated to be over one million dollars a year.

Given the Credible Evidence Rule, and the President's Executive Order to increase the public availability of source emissions data, a prudent and timely evaluation of Enerac 3000's unique technical capabilities can help expand your compliance monitoring options.

Not only will it help reduce monitoring costs, but it will also provide the scientifically sound quality assured data needed to protect your facility.

For more information on EPA's Credible Evidence Rule, and how the Enerac 3000 Series Compliance Level Analyzers can help reduce your facilities compliance costs and risks,
View the Credible Evidence Regulations

Or Call us at 1-800-695-3637