Q619. 40 CFR 98.237 specifies that a monitoring plan required by 40 CFR 98.3(g)(5) must be completed by April 1, 2011. For a facility that became subject to reporting after April 1, 2011, when does a GHG monitoring plan have to be in place?

Q619. 40 CFR 98.237 specifies that a monitoring plan required by 40 CFR 98.3(g)(5) must be completed by April 1, 2011. For a facility that initially becomes subject to reporting under Subpart W after April 1, 2011, by when does a GHG monitoring plan have to be in place?

A619. According to 40 CFR 98.3(g), maintaining a copy of a monitoring plan is a recordkeeping requirement, and all records must be kept for at least 3 years from the date of submission of the annual GHG report for the reporting year in which the record was generated. Thus, at a minimum, reporters must have a current monitoring plan in place by the date of submission of each annual GHG report. However, because the monitoring plan must include a description of the procedures and methods that are used for quality assurance, maintenance and repair of all continuous monitoring systems, flow meters, and other instrumentation used to provide data, EPA encourages reporters to prepare such documentation prior to starting operation or implementing monitoring requirements to help ensure compliance with such requirements.

Footer / References Bar which is Visible to the public