![[logo] US EPA](http://www.epa.gov/epafiles/images/logo_epaseal.gif){kind=logo}
Questions and Answers: Rule and Reporting Changes to Support ECMPS
ECMPS Additional Information
New FAQs appear at the beginning of each section.
Q: Will EPA subject the new XML file format to rulemaking to ensure that it does not impose substantive reporting requirements that are not otherwise required by rule?
A: As with the current EDR file format, the new XML file format will not be included in the monitoring rule. However, like the data elements collected through the current EDR file format, all data elements and data collection methodologies are described in the monitoring rule.
Q: In the past, EPA has implemented some data checks that have issued errors for data that was reported in accordance with Part 75, the EDR reporting instructions and monitoring guidance. Affected sources are looking for a way to get more involved with the process for developing checks. Under the ECMPS process, will sources have the opportunity to participate in the process of developing and testing checks?
A: Under the ECMPS process, sources will have access to documentation which outlines the checks and checking logic of the Client Tool. Prior to the Beta testing period, EPA will conduct testing on the checking logic of the Client Tool. Furthermore, during the Beta testing period, sources will have an opportunity to test this logic with their own data. As it has done in the past, EPA will continue to be responsive to sources when an issue with the checking software is identified, and EPA will act quickly to rectify the issue. However, EPA does not intend to solicit input on the types of checks to be performed by the Client Tool.
Q: How will discrepancies between monitoring plan data in the EPA database and the source's monitoring plan data be resolved?
A: The Client Tool will allow sources to identify and correct discrepancies in their monitoring plan data in order that the data record and subsequent checks are accurate. Remember, EPA's copy of the official data comes from the source submissions. It is important for the data on EPA's database to match the data at the source. EPA understands that errors will occur from time to time from the process of exporting data from the DAHS and then submitting the information. The key to the process change is to give sources more hands-on control of the data submitted to EPA, in order that sources can easily identify and correct mistakes using the Client Tool.
Q: During initial discussions of the ECMPS project, EPA said it was looking at ways to eliminate redundant data or data that could be calculated from other data in the file, such as unadjusted and adjusted hourly values. If EPA eliminates reporting of the unadjusted or adjusted hourly values, how do they plan to verify any BAF?
A: A stated objective of the ECMPS project is to identify redundant data or data that could be calculated based on other data within the quarterly report. Unadjusted and adjusted hourly values fall into this category. However, after careful review, the ECMPS project team decided to continue to require the reporting of both unadjusted and adjusted values.
Q: One enhancement in the reporting format that I would like to see is the elimination of the need to track all of the exemption records required. For example, exemptions must be applied for each quarter if you have less than 168 hours. I would like to see the new system automatically track this. You just tell them how many hours you operate, the new system automatically tracks when all the various QA, such as meter calibrations, linearities, and RATAs.
A: The new system will be capable of tracking and applying exemptions like the 168 operating hour exemption and CEM grace periods. There will be some exemption claim records that will still be needed where there is not enough data for EPA to know if sources qualify for the specific exemption. EPA is working to minimize the number of exemption claim records needed.
Q: What is the time line for the rule changes to support the ECMPS project?
A: The rule revisions supporting the ECMPS process were scheduled to be sent to OMB by the end of March 2005. Based on the overall ECMPS project time line, the rule revisions time line has been modified as follows:
- August 22, 2006 - Proposed rule published
- November - December, 2007 - Publish final rule
Q: EPA suggested that it wants to require the reporting of hourly fuel combustion. Is this going to be added as a reporting requirement as part of the ECMPS process?
A: EPA receives repeated requests for the type and amount of fuel combusted on an hourly basis. EPA asked the question about sources' ability to report fuel combustion on an hourly basis to solicit feedback as to the issues involved with including this data in the quarterly report. Based on the comments received, there will be no requirement to report this data to CAMD.
Q: Do we know what changes will be made to the CFR 40 Parts 72 and 75?
A: See proposed rule published August 22, 2006. Other changes may be made in response to comments received.
Q: Will sources still have to Email certification applications once the ECMPS process is implemented?
A: The electronic portions of the Certification and/or recertification applications will no longer be emailed to EPA once the ECMPS process is implemented. This data will be sent through the Client Tool. The hardcopy requirements, however, for Certification and/or Recertification applications will not be changed.
Q: Part of the flexibility discussed as part of the ECMPS process is to allow sources to submit Monitoring Plan changes and Quality Assurance/Certification Test Data when the changes are ready rather than waiting for the submission period to submit the changes with the emissions data in one data file. Isn't there a regulatory requirement to submit a complete package of data each quarter?
A: Part 75 does specify the data to be reported each quarter as part of an electronic data report. While the requirement to report this data will not change, the manner in which it is to be reported will change. Revisions to Part 75 will include language that gives affected sources the flexibility to maintain facility and unit attribute data outside of the quarterly report while also giving them the ability, if they elect to do so, to provide Monitoring Plan and Quality Assurance and Certification Test data when the changes are made or the tests performed. However, sources may still report all of the data at one time during the submission period.
Q: Will the new Client Tool prevent sources from submitting data if data checks are failed? What are the fundamental requirements based on the regulations?
A: The current method for allowing files to be submitted will be carried forward into the ECMPS process. That is, files must meet a basic level of quality that will allow meaningful feedback to be generated. While the current mainframe-based checking is built around status codes, the ECMPS checking process is being developed around levels of severity. The level of severity of a check and its resulting error message will dictate whether the data may be submitted. Below is a description of the Levels of Severity.
Through the ECMPS Client Tool, sources are able to submit their data to meet the regulatory deadline although all of the data's critical errors have not been resolved. In these cases, the data is received by the EPA as an XML file, but the data is not loaded into the EPA Host System database. Consequently, sources will need to resolve the critical errors associated with this data and resubmit the data in order for it to be loaded into the EPA Host System database.
| Severity Code | Description | Monitoring Plan Examples | QA/Cert Examples | Emissions Examples | Required Action |
|---|---|---|---|---|---|
| Fatal Error | Indicates an error that compromises the integrity of the data. | Monitoring plans missing systems or components that have already been reported in tests or emissions data. | Different tests assigned the same test number; the same test assigned a different test number. | Date not within the reported quarter. | Because this data violates database constraints, it must be corrected before it can be submitted. Data in XML files with fatal errors can not be imported. |
| Critical Error - Level 1 | Indicates invalid data. There is a problem with the way the data are reported, and it should be possible to correct the error by correcting the reporting. | A) Invalid method code for parameter code B) NOX system with SO2 component. |
A) RATA performed on fuel flow system B) Inaccurate calculations - not within tolerance |
Missing records for one or more hours during the quarter. | All Critical Level 1 errors should be resolved before submitting your file. If necessary, you may submit your file with Critical Level 1 errors. However, your data will not be loaded into the EPA Host System, and resubmission will be required. |
| Critical Error - Level 2 | Indicates apparent deviations from rules and policies. Either the data were reported incorrectly or the monitoring or testing was not done in accordance with the requirements. If the latter, the EPA will decide whether the error should be excused. | Ratio between MPC and MEC not valid according to rules. | A) Cal gas slightly deviates from official percent of span. B) Linearity injections out of sequence. |
A) Unadjusted SO2 Concentration is higher than expected. B) Reported emissions value does not match recalculated value and is outside of the tolerance band. |
All reporting issues should be resolved before submitting your file. Monitoring or testing issues may be forgiven under special circumstances. Tests with Critical Level 2 errors will be considered invalid (i.e., not compliant with the QA requirements for the system or component). |
| Non-Critical Error | Indicates small calculation errors or possible reporting errors that have minimal impact on interpretation of the data or implication for other data. | Plan includes unnecessary information. | Unnecessary Percent Monitor Availability reported (e.g., for O2 used only for NOx emission rate). | None, errors do not have to be corrected. | |
| Informational | Message is informational only and appears in separate "Information Only" report. These messages are intended to identify unusual aspects of a source's report that are not necessarily errors. EPA requests that the user review the informational reports to confirm that they do not indicate problems with the data. They have no impact on data submission. | A) Definition of a multiple pipe is not necessary in most instances. B) New requirement that will take effect in the future. |
Aborted test(s) were not evaluated. | None. |
Q: Will the process of submitting a revised Monitoring Plan be the same as it is for emissions or will it be more like using the CAMD Business System (CBS)?
A: The Client Tool will be used to transmit all monitoring plans to the EPA. The CAMD Business System will not be used to create, maintain or submit monitoring plan data.
Q: What about pending regulations? If the mercury program is implemented, will the new data be included in the same quarterly file?
A: Yes, all new data required for the Mercury program, i.e., monitoring plan updates, quality assurance and certification test data and emissions, will be included in the same quarterly file with data reported to CAMD for other programs.