SERVICES
Part 60 Equipment Compliance Guidelines
Unlike 40 CFR 75, 40 CFR 60 does not address recertification, diagnostic testing, or temporary analyzer replacements. CiSCO consulted the EPA about the required testing for CEMS subject to 40 CFR 60 after repairs and replacements.
Why This Guidance Exists
The EPA holds the position that the state or local agency should determine what testing is required because they are responsible for enforcing 40 CFR 60. As a result, CiSCO contacted each state to understand their testing requirements following CEMS component repairs and replacements.
The table below contains the guidance provided by each state's regulatory department and various local agencies.
EPA Position
"Final determination of certification on this matter is deferred to the state and local agencies." (EPA List of State Agencies, 7/6/2020)
Regulatory Agency Responses by State
The full state-by-state guidance CiSCO has collected on recertification, diagnostic testing, and temporary analyzer replacement under Part 60/75.
| State/Local Agency | Regulatory Agency | Contact | Phone | Guidance from Regulatory Agency | Date Provided |
|---|---|---|---|---|---|
| USA | EPA List of State Agencies | Kim Garnett | (919) 541-1158 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Final determination of certification on this matter is deferred to the state and local agencies. | 7/6/2020 |
| Alabama | Alabama Department of Environmental Management | Doug Carr | (334) 271-7899 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis but is agreeable to using Part 75 Emissions Monitoring Technical Q&A procedures. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 7/6/2021 |
| Alaska | Alaska Department of Environmental Conservation | Moses Cross | (907) 451-2163 | Recertification/Diagnostic Testing: Refer to the permit. If additional testing isn’t specified, continual passing of normal QA requirements is sufficient. Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. | 9/10/2021 |
| Arizona | Arizona Department of Environmental Quality | David Kim | (602) 771-4365 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. | 6/23/2021 |
| Arkansas | Arkansas Department of Environmental Quality | Alan Breshears | (501) 837-2209 | Recertification/Diagnostic Testing: A RATA must be performed any time an event triggers a recertification, as dictated in the Part 75 Emissions Monitoring Technical Q&A. Part 75 Emissions Monitoring Technical Q&A guidelines may be followed for diagnostic events with CGAs being substituted for linearities. | 6/9/2021 |
| California | California Environmental Protection Agency | Contact Email | (916) 323-2514 | Final determination is deferred to the local agencies. | N/A |
| California (Sutter & Yuba County) | Feather River Air Quality Management District | Karla Sanders | (530) 634-7659 x205 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 7/2/2021 |
| Colorado | Colorado Department of Public Health & Environment | Jeffrey Bishop | (303) 692-3106 | Recertification/Diagnostic Testing: Use Part 75 Emissions Monitoring Technical Q&A as a guideline as required in CDPHE’s “Air Pollution Control Division Guidelines for State-Only Required Continuous Monitoring Systems in the State of Colorado.” | 5/26/2021 |
| Connecticut | Connecticut Department of Energy and Environmental Protection | John Degirolamo | (860) 424-3957 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 10/25/2021 |
| Delaware | Delaware Department of Natural Resources and Environmental Control | Mark Lutrzykowski | (302) 323-4542 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines when Part 60 does not address the issue. | 6/17/2021 |
| District of Columbia | Renewable Energy and Clean Transportation Branch | Contact Email | (202) 626-5100 | No answer at this time. | N/A |
| Florida | Florida Department of Environmental Protection | Jessica Dalton | (850) 717-9106 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis but is agreeable to using Part 75 Emissions Monitoring Technical Q&A procedures. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 7/12/2021 |
| Georgia | Georgia Environmental Protection Division | Daniel McCain | (470) 938-3374 | Recertification/Diagnostic Testing: Sites may follow Part 75 Emissions Monitoring Technical Q&A guidelines unless there are specific, applicable rules or permit conditions that are more stringent. Temporary Analyzer Replacement: The site must perform an initial calibration and CGA for the analyzer. The replacement analyzer may operate for up to 90 days, then the original must be put back in service or the temporary analyzer must be certified. | 7/1/2021 |
| Hawaii | Department of Health Clean Air Branch | Contact Email | (808) 586-4200 | No answer at this time. | N/A |
| Idaho | Idaho Department of Environmental Quality | Zach Klotovich | (208) 373-0295 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Part 75, EPA guidance, and NSPS Subpart specific guidance are generally used as references to make final replacement and repair decisions, but each incident is handled on a case-by-case basis. | 6/25/2021 |
| Illinois | Illinois Environmental Protection Agency | Kevin Mattison | (217) 953-4519 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Facilities should notify Kevin Mattison about replacements and repairs in a timely manner. Mr. Mattinson typically refers to the Part 75 Emissions Monitoring Technical Q&A to determine what testing to require but final determination is decided on a case-by-case basis. | 9/2/2021 |
| Indiana | Indiana Department of Environmental Management, Office of Air Quality | Jarrod Fisher | (317) 233-2723 | Recertification/Diagnostic Testing: IDEM generally defaults to Part 75 Emissions Monitoring Technical Q&A guidelines giving 45 days to complete certification testing. Reach out to the agency for a case-by-case review and suggest using Part 75 Emissions Monitoring Technical Q&A as a guideline. | 1/5/2022 |
| Iowa | Iowa Department of Natural Resources | Mark Fields | (515) 343-6589 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Iowa DNR has previously allowed Part 60 units to comply with Part 75 requirements if Part 60 does not specifically describe the event. Review the construction permit for language that allows use of Part 75 Emissions Monitoring Technical Q&A as a guideline. If the permit language is lacking submit a request for determination from IDNR. | 7/6/2021 |
| Kansas | Kansas Department of Health and Environment | Christopher Appier | (785) 213-2903 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement : CEMS regulated under Part 60 may utilize the QA procedures outlined in Part 75 Emissions Monitoring Technical Q&A to demonstrate that the CEMS meets performance specifications after repairs and/or replacements. The agency also allows Part 75 Emissions Monitoring Technical Q&A procedures to be used for temporary replacement CEMS during CEMS repair. | 7/7/2021 |
| Kentucky | Kentucky Energy and Environment Cabinet | Ben Markin | (502) 782-3147 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: “Sites that are subject to requirements of 40 CFR Part 60 or are subject to state permitting requirements follow the established standards in 40 CFR Part 75.” Sites cannot necessarily follow Part 75 Emissions Monitoring Technical Q&A guidance and substitute Part 60 tests (e.g., substitute a CGA for a linearity). Based on the language of CiSCO reviewed KEPPC permits the agency may require parameters subject only to Part 60 (e.g., carbon monoxide) to follow Part 75, Appendix B QA scheduling. For further clarification refer to your current permit or contact KEPPC. | 7/16/2021 |
| Louisiana | Louisiana Department of Environmental Quality | Brian Fontenot | (337) 262-5577 | Contact the facility’s Enforcement Writer at LDEQ. | 1/31/2022 |
| Maine | Maine Department of Environmental Protection | Robert Hartley | (207) 287-7644 | Recertification/Diagnostic Testing: The agency determines testing on a case-by-case basis. Contact the agency and suggest using Part 75 Emissions Monitoring Technical Q&A as a guideline. Temporary Analyzer Replacement: Like-kind is qualified as the same make and model (regardless of series) and can be used for up to 720 hours. After 720 hours a full cert is required. | 7/8/2021 |
| Maryland | Maryland Department of the Environment | Contact Email | (410) 537-3000 | No answer at this time. | N/A |
| Massachusetts | Massachusetts Department of Environmental Protection | Joanne Morin | (857) 972-3148 | Recertification/Diagnostic Testing: Sites should use Part 75 Emissions Monitoring Technical Q&A guidelines. | 11/3/2021 |
| Michigan | Michigan Department of Environment, Great Lakes, and Energy | Karen Kajiya-Mills | (517) 256-0880 | Recertification/Diagnostic Testing: Contact MI AQD prior to replacement or ASAP after for instruction on testing. Perform a calibration and CGA immediately following the event. Suggest using Part 75 Emissions Monitoring Technical Q&A as a guideline when contacting the agency. Temporary Analyzer Replacement: Perform a calibration and CGA immediately after the replacement. The analyzer may operate for a 720-hour period per calendar year before certification is required. This agency qualifies a like-kind analyzer as the same make and model. | 9/21/2021 |
| Minnesota | Minnesota Pollution Control Agency | Andrew Place | (651) 296-6300 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. However, monitor downtime should be reported until the CEMS is recertified, or the original analyzer is put back in service. MPCA may classify the recert period as “acceptable downtime.” | 3/3/2022 |
| Mississippi | Mississippi Department of Environmental Quality | N/A | (601) 961-5171 | No answer at this time. | N/A |
| Missouri | Missouri Department of Natural Resources | Josh Vander Veen | (573) 751-8328 | Recertification/Diagnostic Testing: Sites should use Part 75 Emissions Monitoring Technical Q&A guidelines. Temporary Analyzer Replacement: The agency agrees it is reasonable to use temporary analyzer replacements in accordance with Part 75 Emissions Monitoring Technical Q&A guidelines. However, the agency believes this should be evaluated during an operating permit review. If this approach is approved, it should be incorporated into the permit. | 9/22/2021 |
| Montana | Montana Department of Environmental Quality | Jamin Grantham | (406) 247-4446 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 2/1/2022 |
| Nebraska | Nebraska Department of Environment and Energy | Matt Turco | (402) 471-6087 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. | 1/10/2022 |
| Nevada | Nevada Division of Environmental Protection | Gregg Rosenberg | (775) 687-9573 | Recertification/Diagnostic Testing: For all counties except Washoe and Clark: follow the manufacturer’s instructions for all equipment replacements. | 9/21/2021 |
| Nevada (Clark County, Las Vegas) | Division of Air Quality | Jeff Robb | (702) 455-1650 | NOx and O2: Part 60 analyzers can follow Part 75 Emissions Monitoring Technical Q&A procedures for recertification, diagnostic testing, and temporary analyzer replacement. CO: Part 60 analyzer may most likely follow Part 75 Emissions Monitoring Technical Q&A as a guideline, but agency approval is required. | 9/22/2021 |
| Nevada (Washoe County, Reno) | Air Quality Management | Joshua Restori | (775) 784-7202 | The agency does not have a position on this matter because there are not any facilities within their jurisdiction that utilize CEMS. | 1/28/2022 |
| New Hampshire | New Hampshire Department of Environmental Services | Mike O’Brien | (603) 271-6546 | Recertification/Diagnostic Testing: Perform a CGA within 5 days and a RATA within 90 days if the replacement or repair could affect the ability of the CEMS to measure accurately, change the flue gas handling system in a way that could change the flow or concentration profile, or if the location or orientation of the probe is changed. If the replacement or repair is minor, no testing is required. Reference NHDES 808.05 (f) and (g). | 10/11/2021 |
| New Jersey | New Jersey Department of Environmental Protection | Neil Nissim | (609) 633-7946 | Recertification/Diagnostic Testing: NJ DEP refers to the Part 75 Emissions Monitoring Technical Q&A guidelines for recertification but reserves the right to require more testing. Sites should always reach out to the agency. Temporary Analyzer Replacements: Not allowed. | 9/24/2021 |
| New Mexico | New Mexico Environment Department | Cindy Hollenberg | (505) 476-4300 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. | 1/28/2022 |
| New York | New York State Department of Environmental Conservation | Randy Orr | (518) 402-8401 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 10/13/2021 |
| North Carolina | North Carolina Department of Environmental Quality | Gary Saunders | (919) 707-8413 | No answer at this time. | N/A |
| North Dakota | North Dakota Department of Environmental Quality | Keith Hinnenkamp | (701) 328-5196 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis but will likely consider and accept using Part 75 Emissions Monitoring Technical Q&A guidelines. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 9/22/2021 |
| Ohio | Ohio Environmental Protection Agency | Todd Brown | (614) 644-4839 | Recertification/Diagnostic Testing: If the CEMS is also subject to Part 75 you may follow Part 75 Emissions Monitoring Technical Q&A guidelines. Contact the agency to clarify which tests are required for CEMS subject to only Part 60. For Part 60, the agency assigns seven operating days of downtime for the drift test and then uses enforcement discretion to determine the amount of downtime to complete testing. Temporary Analyzer Replacement: Not allowed. | 9/21/2021 |
| Oklahoma | Oklahoma Department of Environmental Quality | Matthew Webb | (918) 293-1612 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. | 10/18/2021 |
| Oregon | Department of Environmental Quality | Find Regional Contact | Find Regional Contact | No answer at this time. | N/A |
| Pennsylvania | Pennsylvania Department of Environmental Protection | Richard Basso / Susan Foster | (717) 772-3946 / (717) 772-3369 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency has their own procedure in place for recertification and temporary analyzer replacements. The process is similar to the procedure outlined in Part 75 Emissions Monitoring Technical Q&A and can be found in Attachment No. 5 of the Continuous Source Monitoring Manual Revision 8 . | 12/2/2006 |
| Rhode Island | Rhode Island Department of Environmental Management | Contact Email | (401) 222-1360 x7023 | No answer at this time. | N/A |
| South Carolina | Department of Health and Environmental Control | Michael Shroup | (803) 898-4051 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 9/28/2021 |
| South Dakota | South Dakota Department of Agriculture & Natural Resources | Cooper Baltzer | (605) 773-4213 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency has previously allowed sites to follow Part 75 Emissions Monitoring Technical Q&A guidelines where Part 60 is lacking instructions. The agency requires sites to reach out prior to replacement (if possible), directly after replacement (if the circumstance warrants), or if offices are closed (e.g., weekends, holidays, after COB, etc.). | 9/30/2021 |
| Tennessee | Tennessee Department of Environment & Conservation | Jeryl Stewart | (615) 532-0605 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. Please note that the agency retains the right to require additional testing if the technical secretary finds it justified. | 1/24/2022 |
| Texas | Texas Commission on Environmental Quality | Keith Sheedy | (512) 239-1556 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Sites may use Part 75 Emissions Monitoring Technical Q&A guidelines. | 2/1/2022 |
| Utah | Utah Department of Environmental Quality | Rob Leishman | (801) 536-4438 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency expects facilities required by 40 CFR 60 to install, operate, and maintain CEMS to meet the requirements and guidance of 40 CFR 75 for the operation of the monitors. DAQ defers to the federal guidance for the installation, certification, calibration, maintenance, alternate monitoring, and replacement of monitors. | 9/22/2021 |
| Vermont | Vermont Department of Environmental Conservation | Contact Email | (802) 828-1294 | No answer at this time. | N/A |
| Virginia | Virginia Department of Environmental Quality | Sherry Tostenson | (804) 698-4050 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency does not currently have any guidance on this matter but is considering working on such guidance in 2022. Contact the agency and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 10/12/2021 |
| Washington | Washington State Department of Ecology | Christopher Hanlon-Meyer | (360) 407-6115 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: Follow the permit and reach out to the site’s ecology inspector with questions. Request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. | 10/5/2021 |
| West Virginia | West Virginia Department of Environmental Protection | Find Regional Contact | Find Regional Contact | No answer at this time. | N/A |
| Wisconsin | Wisconsin Department of Natural Resources | Andrew Seeber | (608) 267-0563 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis but is agreeable to using Part 75 Emissions Monitoring Technical Q&A procedures. | 9/27/2021 |
| Wyoming | Wyoming Department of Environmental Quality | Mark Gagen | (307) 777-7351 | Recertification/Diagnostic Testing/Temporary Analyzer Replacement: The agency determines testing on a case-by-case basis. Contact the agency immediately and request to use Part 75 Emissions Monitoring Technical Q&A as a guideline. Downtime is taken into consideration by the agency during the site’s quarterly review. | 1/10/2022 |
Need Guidance for Your State?
Don't see your state's agency, or need help interpreting the guidance above? Reach out to our regulatory team directly.