Rule: 40 CFR Part 60, Subpart [X] — Continuous Emissions Monitoring Requirement
Effective Date: December 1, 2026
Affected Entity: [Company Name], [Facility Location]
Bottom Line: Your facility's current manual monitoring schedule (quarterly stack tests) is no longer sufficient. You must install and calibrate a Continuous Emissions Monitoring System (CEMS) for SO2 and NOx before December 1, 2026. Failure to comply carries a penalty of $65,000 per day (42 U.S.C. §7413(a)).
Estimated Compliance Cost: $180,000–$340,000 (CEMS equipment + installation + 12-month calibration contract). See Section 4 for line-item breakdown.
Recommended Action Deadline: Issue RFP for CEMS vendor by October 31, 2026. Install by November 15, 2026. Calibrate and submit initial compliance report by December 1, 2026.
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Before this rule: Facilities emitting between 100 and 250 tons/year of SO2 or NOx could use manual monitoring (quarterly stack tests by a certified engineer). This was sufficient for compliance under 40 CFR Part 60.
After this rule: Facilities emitting more than 100 tons/year (the threshold dropped from 250 to 100) must use continuous monitoring. Manual stack tests are no longer an acceptable compliance method above the 100-ton threshold.
What this means for your facility: Your 2025 emissions report shows 187 tons/year of SO2. You are above the new 100-ton threshold. Your current quarterly stack test schedule is no longer compliant. You need a CEMS.
By Oct 31: Issue RFP to 3+ CEMS vendors. Request quotes for equipment + installation + 12-month calibration.
By Nov 15: Complete CEMS installation. Begin 30-day calibration period.
By Dec 1: Submit initial compliance report to EPA Region [X]. Include calibration data, installation certification, and ongoing monitoring schedule.
Ongoing: Monthly CEMS data review. Annual calibration. Quarterly reports to EPA.
Penalty if you miss December 1: $65,000 per day. EPA enforcement is automatic for CEMS non-compliance (no "cure period" under the 2026 amendments).
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