SteveNorfleetRMB Consulting & Research, Inc.Stationary Source Sampling & Analysis ConferencePoint Clear, Alabama - March 22, 2016Workgroup Focused on Developing XMLReporting Alternatives for MATSUtility, Software Vendor and Stack TestersGoal- Improve, Streamline and Simplify MATSImprove, Streamline and Simplify MATSElectronic Reporting RequirementBut, MATS Is Just Tip of the IcebergProposed Test Report Requirements ChangesERT for New Standards (e.g., PC MACT, Da)Proposed ERT/CEDRI for Existing Part 60 SourcesTesting Community Should Be Part ofDiscussionRMB Consulting & Research, Inc.Providing Environmental Services to IndustryProposed test methods revisions (9/8/15)Proposed test methods revisions (9/8/15) -new requirements for Part 60 & 63 performancetests reports (“electronic or paper ”)Current Requirement:Proposed Requirement:§60.8(a): “...a written report60.8(a): “...a written reportof the results of suchperformance test(s)”§63.7(f)(1): “...results of a63.7(f)(1): “...results of aperformance test shallinclude the analysis ofsamples, determination ofemissions, and raw data.”General identificationinformation for the facilityincluding a mailing andactual addressOwner or operator orresponsible official orrepresentative and emailaddress for this personLatitude and longitude ofthe emission point beingtested; FRS number forthe facilityPurpose of test includingthe regulation requiringthe test, the pollutantbeing measured, the unitsof the standard or thepollutant emissions units,and any processparameter componentBrief process description;sampling site description;permitted maximumprocess rate (whereapplicable)Complete unitdescription, including adescription of feedstreams and controldevices, SCC codeDescription of samplingand analysis proceduresand any modifications tostandard proceduresQuality assuranceprocedures; record ofpreparation of standards;Record of calibrationsRecord of operatingconditions, includingoperating parameters forwhich limits are being set,during testRaw data sheets for fieldsampling; raw data sheetsfor field and laboratoryanalysesChain-of-custodycustodydocumentation;explanation of laboratorydata qualifiersExample calculations ofall stack gas parameters,emission/reduction rates,and analytical resultsIdentification informationfor the testing companyincluding a contact personand email addressAny other informationrequired by the testmethod, a relevantstandard, or theAdministrator.“Current Requirement:Proposed Requirement:RMB Consulting & Research, Inc.Providing Environmental Services to IndustryMailing address and actual address of facilityOwner, operator, responsible official orappropriate representative and email addressFRS number for facilityBrief process descriptionComplete unit description, includingdescription of feed streams and control devices,appropriate source classification code (SCC)Latitude and longitude of tested emission pointPermitted maximum process rateRMB Consulting & Research, Inc.Providing Environmental Services to IndustryPurpose of test including regulation requiringtest, pollutant(s) measured, units of standard orpollutant emissions, and any processparameter componentSampling site descriptionDescription of sampling and analysisprocedures and any modifications to standardproceduresQuality assurance proceduresRMB Consulting & Research, Inc.Providing Environmental Services to IndustryRecord of operating conditions, includingoperating parameters for which limits arebeing set, during the testRecord of preparation of standardsRecord of calibrationsRaw data sheets for field samplingRaw data sheets for field and laboratoryanalysesChain-of-custody documentationcustody documentationRMB Consulting & Research, Inc.Providing Environmental Services to IndustryExplanation of laboratory data qualifiersExample calculations of all applicable stack gasparameters, emission rates, percent reductionrates, and analytical results, as applicableIdentification information for the companyconducting the performance test including acontact person and his/her email addressAny other information required by the testmethod, a relevant standard, or theAdministrator."RMB Consulting & Research, Inc.Providing Environmental Services to IndustryRequire electronic reporting (CEDRI and ERT)for existing sources under many NSPS subpartsSubparts D,Subparts D, Da, Db and Dc addressed “under a, Db and Dc addressed “under aseparate and independent rulemaking”Fundamental IssuesSupport electronic reporting but ERT not a goodformat or appropriate tool electronicRule must identify specific reporting elementsShould automatically discontinue paper reportingDoes not allow adequate transition timeRMB Consulting & Research, Inc.Providing Environmental Services to IndustrySupport electronic reporting but ERT is thewrong tool for the jobCumbersome data entry and awkward tool for stateagency personnel that want to use the dataHas not been voluntarily adoptedTouted as an all-in-one tool replace "time-intensivemanual preparation and transcription of stationarysource emissions test plans and reports ...” but states andtesters have not adopted it.Testers already have tools that they have developedandverified over timeDoes not even allow you to report your complianceaverageRMB Consulting & Research, Inc.Providing Environmental Services to IndustrySupport electronic reporting but ERT is thewrong tool for the jobIncludes data not required by rulesRequires much more than is needed to establishcompliance and to develop emission factorsERT requires hundreds of data points to entered only ahandful are actually exported to the webfire databasePleased to see that EPA is planning an XMLschema alternative to the ERTWe Need an Actual FormatRMB Consulting & Research, Inc.Providing Environmental Services to IndustryDon’t justDon’t just rotelyduplicate the ERTduplicate the ERTNow is the time to consider what data should bereported and how best to report it and how to identifythe specific requirements in the rules/methodsRecommend a balanced approach:Focus on data that is critical for establishingcompliance, ensuring tests were properly performedand for showing that QA requirements were satisfied.Critical details in numeric format and other details inPDF form so that agency can have ready access to thatinformation in the full context of the reportStates can always ask for more dataRMB Consulting & Research, Inc.Providing Environmental Services to IndustryPotential Alternative to ERT for Stack TestsReport Critical Values for Each TestConcentrations and Average EmissionsParameters Used to Convert to Emission Standard (e.g.,CO2/O2, H2O, or flow)2/O2, H2O, or flow)Sample Time / Sample VolumeQA ParametersSubmit Full Stack Test Report Electronically as PDF(Creates Full Record and Allows Complete Audit)Proposed Approach Includes More Data thanEPA exports from ERT toEPA exports from ERT to WebFIREWebFIRERMB Consulting & Research, Inc.Providing Environmental Services to IndustryERT WebfireXML OutputProposedComplianceReport FormatFacility/Source Identification X XPollutant/Method Used X XApplicable Regulation/Test Purpose X XEmission LimitX XRun Sample Time and VolumeXRun ConcentrationXRun Conversion Parameters(e.g., CO2, O2, H2O, flow, F-factor, etc.) XRun QA Data (e.g., Filter Temp, Leak Check,Breakthrough, Iso-kinetic, Recovery, etc.) XRun Sample Mass X IndirectlyRun Emission Rate (e.g., lb/MMBtu) X XTest Compliance AverageXModeling Data? (Temp/Flow/Diameter)XTemplate could be used for any pollutant,method or subpartCan define specific QA parameters for each methodand tools can validate values are in proper rangeWould allow the Agency to readily accommodatenew methods and to collect consistent dataRelives EPA from the burden of:Complexity of maintaining a single tool to addressall potential existing or future methodsTechnical support to disparate sources trying to usesuch a toolRMB Consulting & Research, Inc.Providing Environmental Services to IndustryAgain, Now Is the Time to Discuss How Best toDevelop Electronic Reporting RequirementsNeed a balanced approach that considers reportingburden and provides critical info to assesscompliance focusing on important QANeed an actual format and can do better than justblindly creating an XML version of ERT tablesThe Stack Testing Community Has a Stake inthis Process and Electronic Reporting Can BeBeneficial...If We Do It RightRMB Consulting & Research, Inc.Providing Environmental Services to Industry