IMPORTANT EPA UPDATE FOR SWG100 OWNERS

PER MRU INSTRUMENTS 7-31-2024

Biogas Regulatory Reform, Alternative Measurement Protocol for MRU SWG 100 BIO-12142

In April, we informed you that we have submitted the SWG100 BIO to the EPA, as an Alternative Method Protocol (AMP) GCs.

Today (July 31, 2024) we want to inform you about the progress of this application and what it means for you.

The EPA has not yet indicated a timeline for the approvals on any analyzers, but they have indicated that they would be looking to grant preliminary approvals to facility registrations, proposing to use flow and gas quality meters which the OEM has submitted an AMP for (by referencing the JSDEP number (JSDEP-23528).

This means, facilities with completed registrations and proposing to use the MRU analyzer which we submitted an AMP for (SWG 100BIOGAS) would be eligible for participation under BRR regulations under a provisional approval (granted until the EPA issues a final decision on the AMP).

For your registration you will use the MRU registration number: JSDEP-23528

Please note, the provisional approval will be applied on a case-by-case basis for each registration and it is not applied to the equipment. The provisional approval for use of the MRU equipment would be supplied as part of a facility registration under BRR that submitted an engineering review with MRU analyzer and associated AMP JSDEP number.

The EPA has indicated in a call with our consultant, that they have not yet seen any red flags in AMP submissions that would indicate any at risk for denial. This includes the use of analyzers for RNG gas analysis as well as biogas!

Thank you for your time, we will send you updates as soon as we get additional information!