What the difference Between CFR 60 and CFR 75
40 CFR Part 60 (New Source Performance Standards – NSPS) focuses on setting emission limits and control technology standards for new or modified sources.
Key requirements
- Requires CEMS
- Requires RATA
- 7 Drift
Conversely, 40 CFR Part 75 (Acid Rain Program) mandates continuous monitoring and reporting for SO2, CO2, and NOx to support cap-and-trade programs, emphasizing data precision over specific technology requirements. In Colorado, Title V permits both may apply, often requiring strict adherence to Part 75’s rigorous QA/QC standards even when reporting for Part 60 compliance. [1, 2, 3, 4]
Key differences between Part 60 and Part 75 in air compliance include:
We are NOT under Part 75
- Core Purpose: Part 60 dictates how much a source can emit (limits). Part 75 dictates how to measure and report emissions (accounting).
- Calibration Standards: Part 60 requires daily calibrations with stricter drift specifications. Part 75 allows for a 26-hour calibration window with more flexible drift limits.
- Monitoring Focus: Part 60 addresses compliance with technology-based standards (e.g., [subparts Da, Db, Dc, J, Kb, Cc, etc.]), while Part 75 is primarily for the [Acid Rain Program] or for determining mass emissions.
- Relative Accuracy Test Audits (RATA): Part 75 generally mandates more frequent and stringent RATA requirements than Part 60.
- Compliance Approach: When both are required (as is common for EGU boilers), the tighter standard (usually Part 75) governs Continuous Emissions Monitoring System (CEMS) operations. [1, 2, 3, 4, 5]
- Applies if we are selling electricity back to grid. But we are currently planning not to sell.
- Acid Rain
[2] https://escspectrum.com/air-emissions-compliance-reporting/
[3] https://escspectrum.com/how-to-successfully-plan-and-complete-a-relative-accuracy-test-audit/
[4] https://www.epa.gov/power-sector/part-75-policy
[5] https://www.all4inc.com/content/uploads/2018/08/EthosEnergy-CEMS-Training-by-ALL4-Slides-2018.pdf
