Steve Norfleet

RMB Consulting & Research, I

Stationary Source Sampling & Analysis 

Point Clear, Alabama - March 22, 
 Workgroup Focused on Developing 

Reporting Alternatives for MATS

Utility, Software Vendor and Stack TesteGoal - Improve, Streamline and Simplify 

Improve, Streamline and Simplify 

Electronic Reporting Requirement

 But, MATS Is Just Tip of the Iceberg

Proposed Test Report Requirements ChaERT for New Standards (e.g., PC MACTProposed ERT/CEDRI for Existing Part 

 Testing Community Should Be Part 

Discussion

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Proposed test methods revisions (9/

Proposed test methods revisions (9/new requirements for Part 60 & 63 ptests reports (“electronic or paper ”) 

Current Requirement: Proposed Requi

§60.8(a): “...a written report 60.8(a): “...a written report 

of the results of such performance test(s)” 

§63.7(f)(1): “...results of a 63.7(f)(1): “...results of a 

performance test shall include the analysis of samples, determination of emissions, and raw data.”

General identification 

information for the facility including a mailing and actual address

Owner or operator or 

responsible official or representative and email address for this person

Latitude and longitude of 

the emission point being tested; FRS number for the facility

Purpose of test including 

the regulation requiring the test, the pollutant being measured, the units of the standard or the pollutant emissions units, and any process parameter component

Brief process 

sampling sitpermitted mprocess rate applicable)

Complete un

description, description ostreams and devices, SCC 

Description 

and analysis and any modstandard pro

Quality assu

procedures; preparation Record of ca

Record of op

conditions, ioperating pawhich limits during test

Current Requirement: Proposed Requi

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Mailing address and actual address o

 Owner, operator, responsible official 

appropriate representative and emai

 FRS number for facility

 Brief process description Complete unit description, including 

description of feed streams and contappropriate source classification cod

 Latitude and longitude of tested emi Permitted maximum process rate

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Purpose of test including regulation 

test, pollutant(s) measured, units of spollutant emissions, and any process parameter component

 Sampling site description Description of sampling and analysi

procedures and any modifications to procedures

 Quality assurance procedures

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Record of operating conditions, inclu

operating parameters for which limibeing set, during the test

 Record of preparation of standards

 Record of calibrations Raw data sheets for field sampling Raw data sheets for field and laborat

analyses

 Chain-of-custody documentation custody documentation

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Explanation of laboratory data quali

 Example calculations of all applicabl

parameters, emission rates, percent rrates, and analytical results, as appli

 Identification information for the com

conducting the performance test inclcontact person and his/her email ad

 Any other information required by t

method, a relevant standard, or the Administrator."

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Require electronic reporting (CEDRI 

for existing sources under many NSP

Subparts D, Subparts D, Da, Db and Dc addressed “u

, Db and Dc addressed “u

separate and independent rulemaking”

 Fundamental Issues

Support electronic reporting but ERT no

format or appropriate tool electronic 

Rule must identify specific reporting eleShould automatically discontinue paper Does not allow adequate transition time

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Support electronic reporting but ERT 

wrong tool for the job

Cumbersome data entry and awkward t

agency personnel that want to use the d

Has not been voluntarily adopted

 Touted as an all-in-one tool replace "time-

manual preparation and transcription of ssource emissions test plans and reports ...testers have not adopted it.

 Testers already have tools that they have 

verified over time

 Does not even allow you to report your co

average 

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Support electronic reporting but ERT 

wrong tool for the job

Includes data not required by rulesRequires much more than is needed to e

compliance and to develop emission fac

 ERT requires hundreds of data points to e

handful are actually exported to the webf

 Pleased to see that EPA is planning a

schema alternative to the ERT 

We Need an Actual Format

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Don’t just Don’t just rotely duplicate the ERT duplicate the ERT 

Now is the time to consider what data sh

reported and how best to report it and hthe specific requirements in the rules/m

 Recommend a balanced approach:

Focus on data that is critical for establish

compliance, ensuring tests were properland for showing that QA requirements w

Critical details in numeric format and ot

PDF form so that agency can have ready information in the full context of the rep

 States can always ask for more data 

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Potential Alternative to ERT for Stac

Report Critical Values for Each Test 

 Concentrations and Average Emissions Parameters Used to Convert to Emission S

CO2/O2, H2O, or flow) 2/O2, H2O, or flow)

 Sample Time / Sample Volume QA Parameters

Submit Full Stack Test Report Electronic

(Creates Full Record and Allows Compl

 Proposed Approach Includes More D

EPA exports from ERT to EPA exports from ERT to WebFIRE WebFIRE

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
ERT Webfi

XML Outpu

Facility/Source Identification X Pollutant/Method Used X Applicable Regulation/Test Purpose X Emission Limit X Run Sample Time and Volume 

Run Concentration Run Conversion Parameters (e.g., CO2, O2, H2O, flow, F-factor, etc.) 

Run QA Data (e.g., Filter Temp, Leak Check, Breakthrough, Iso-kinetic, Recovery, etc.) Run Sample Mass X Run Emission Rate (e.g., lb/MMBtu) X Test Compliance Average 

Modeling Data? (Temp/Flow/Diameter) X
 Template could be used for any pollu

method or subpart 

Can define specific QA parameters for e

and tools can validate values are in prop

Would allow the Agency to readily acco

new methods and to collect consistent d

 Relives EPA from the burden of:

Complexity of maintaining a single tool 

all potential existing or future methods

Technical support to disparate sources t

such a tool 

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry
 Again, Now Is the Time to Discuss H

Develop Electronic Reporting Requir

Need a balanced approach that consider

burden and provides critical info to asse

compliance focusing on important QA 

Need an actual format and can do better 

blindly creating an XML version of ERT 

 The Stack Testing Community Has a 

this Process and Electronic Reporting Beneficial...If We Do It Right

RMB Consulting & Research, Inc.

Providing Environmental Services to Industry