Measurement Policy Group - Measurement and Monitoring Projects
2011 / 2012 Projects
This is a status report from the Measurement Policy Group of projects and other current activities involving air emissions monitoring and other emissions quantification tools, databases, and protocols.
Improving Emissions Monitoring through Rulemaking
- Information Collection Requests (ICRs) – ICRs are a means by which we use our authority under section 114 of the Clean Air Act to collect source emissions and operational data in order to assist rule development. Since we lost a number of court cases due, in part, to a lack of data, we issued ICRs this past year that included emissions testing for refineries and wool fiberglass plants. These requests generally require the use of our Electronic Reporting Tool (ERT) to submit data from source testing. In support of rule writers and their ICRs, MPG and MTG staff maintain web sites for responses to FAQ, hold webinars, expedite alternative monitoring requests, respond to telephone and email questions, and update the ERT.
Contact: Steffan Johnson, MPG, firstname.lastname@example.org, 919-541-4790.
- Improving Compliance Monitoring through Rulemaking – We have recommitted to including monitoring to provide continuous compliance with emissions limitations and standards in all new and revised rules. MPG and MTG staff worked closely with SPPD rule writers to develop and update monitoring requirements in 14 proposed rules and 12 final rules over the past year. Where feasible and practical, we have promoted and will continue to apply continuous, direct emissions monitoring of the pollutant of concern using continuous emissions monitoring systems (CEMS). Where CEMS are not feasible or practical, we continue to implement a combination of periodic performance testing and parametric monitoring.
Contact: Barrett Parker, MPG, email@example.com, 919-541-5635.
- Innovative Monitoring – We continue our implementation of new monitoring technologies in current and future rulemakings. We took comment on the use of optical gas imaging (OGI, also known as “the camera”) as a replacement for traditional Method 21 leak detection monitoring in the Oil and Gas Sector rules. Although OGI is already allowed as part of the Alternative Work Practice (AWP) promulgated in Subpart A to both Part 60 and Part 63, the AWP currently requires the use of Method 21 monitoring annually. In the Oil and Gas Sector rule, we took comment on OGI as a technique that can stand on its own. We expect to propose such an approach in rules in the future. Currently, MPG and MTG are working on developing a protocol for OGI that will be promulgated as Appendix K to 40 CFR Part 60. This protocol will outline specifications of the equipment that must be used, calibration techniques, procedures for conducting surveys, training requirements for camera operators, and techniques to verify that your equipment can see the most prevalent chemical in your process unit. Because field conditions greatly impact detection of volatile organic compounds using optical gas imaging, the protocol will describe the impact that these field conditions may have on readings, how to combat the effects of these conditions, and when monitoring with this technique is inappropriate. Additionally, the Agency is actively working on developing methods to use passive sorbent tube fenceline monitoring as a technique for monitoring fugitive emission sources. We expect rules to be issued in the near future that will incorporate fenceline monitoring.
Contact: Gerri Garwood, MPG, firstname.lastname@example.org, 919-541-2406.
- Compliance and Emissions Data Reporting Interface (CEDRI) - CDX Data Flow – We have designed a process to allow submission of stack test reports generated using the Electronic Reporting Tool (ERT) to our Central Data Exchange (CDX) using CEDRI. CDX is an application used by EPA programs and various stakeholders to manage environmental data transmitted to us to meet reporting requirements. Submittal of files through CDX requires a Cross-Media Electronic Reporting Regulation (CROMERR) compliant signature. Authorized signature authorities for the facility may use the LexisNexis electronic identity validation service in lieu of a paper-based validation. Facility contractors (or consultants) may submit files on behalf of an authorized signature authority for the facility. Contractors must proceed through the paper-based validation process prior to submitting files to CDX. Contractors may not use the LexisNexis electronic signature authority validation process in lieu of the paper-based validation process. Once you have passed the identity validation process and log in, you will be able to add CEDRI as a reporting portal in your account profile. Upon accessing CEDRI, you can upload your stack test report for submission. You should not make any changes to the file name generated by the ERT software. Prior to submission, you will be required to re-validate your user name and password and officially sign the submission document. The submission files will be stored as official copies of record in the CDX CROMERR archive and become available to submitters and authorized EPA reviewers immediately upon submission. Copies of submitted reports are available on the WebFIRE web site. Additionally, interested parties may complete a registration form to receive e-mail notifications when a facility located within their area of interest (a state, multiple states, or counties within a state) submits an ERT file to WebFIRE. For more information, see the CEDRI CDX User Guide, available on the ERT web site.
Contact: Michael Ciolek, MPG, email@example.com, 919-541-4921.
- CEDRI Enhancements – CEDRI is the portal in CDX where stack testing data, as well as other data required by the Compliance and Emissions Data Reporting Rule (CEDRR), is submitted. The portal began accepting ERT reports on January 1, 2012. In the next couple of years, MPG will be working on developing subpart specific reporting forms for facilities affected by the CEDRR. Once the system is complete, you will access CEDRI, select the applicable subpart for the report that you are submitting, select the report type being transmitted, enter the data into the form, and click on the submit button. In some cases, such as with stack test data, you will select the report type, enter basic facility information, and then upload the report in a specified file format (e.g. the ERT file or PDF).
Contact: Colin Boswell, firstname.lastname@example.org, 919-541-2034.
- Emissions Factors Program Improvement Project - We continue to implement our multi-part process to improve the air pollutant emissions factors (EF) program and to make the program self-sustaining. We posted the draft recommended procedures for development of emission factors for comment on December 17, 2010. The comment period ended on March 17, 2011, and we have spent time addressing issues within the document. We expect the final document to be available shortly. When finalized, it will supersede the previous guidance for emissions factor development (Procedures for Preparing Emission Factor Documents (EPA-454/R-95-015, November 1997)). The document presents an introduction to emissions factors and provides the historical background for how and why we have developed recommended emissions factors for stationary emissions units or processes. It describes the new approach and procedures that we will follow when developing new or revising existing emissions factors and the procedures, data evaluation criteria, associated tools, and data management systems that we recommend for developing air pollutant emissions factors for stationary emissions units or processes. It also provides an overview of our interactive emissions factor database, WebFIRE, and a discussion of the role the Electronic Reporting Tool (ERT) plays in submitting emissions test data to us. Once the procedures document is finalized, we will begin reprogramming WebFIRE to match the processes described in the document.
Contact: Michael Ciolek, MPG, email@example.com, 919-541-4921.
- Compliance and Emissions Data Reporting Rule (CEDRR) - In order to acquire adequate data for regulation development, improvement of emissions factors, and other air pollution control activities, we sought comment on requiring the electronic submission to us of certain performance testing information already collected by industry. (The advance notice of proposed rulemaking was published on October 14, 2009: 74 FR 52723.) We continue to work on developing this rule, and we have expanded the scope to include electronic submission of excess emission reports, summary reports, and notification of compliance reports. We plan to propose this rule later this year.
Contact: Tom Driscoll, MPG, firstname.lastname@example.org, 919-541-5135.
- Implementation of Electronic Reporting – Ahead of the CEDRR being proposed, we have begun incorporating electronic reporting into recently promulgated rules. This includes requirements to use the ERT in rules for:
- Coal Preparation and Processing Plants
- Portland Cement
- Gold Mine Ore Processing and Production
- Sewage Sludge Incinerators
- Commercial/Industrial Solid Waste Incinerators
- Industrial, Commercial, and Institutional Boilers
- Group I Polymers and Resins
- Marine Tank Vessel Loading Operations
- Pharmaceuticals Production
- Printing and Publishing Industry
- Secondary Lead Smelting
- Coal- and Oil-fired Electric Utility Steam Generating Units, Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units aka Mercury and Air Toxics Standards (MATS)
We have also proposed requirements to use the ERT in rules for:
- Polyvinyl Chloride and Copolymers Production
- Nitric Acid Production
- Primary Aluminum Reduction
- Mineral Wool Production
- Wool Fiberglass Production
- Ferroalloys Production
- Group IV Polymers and Resins
- Pesticide Active Ingredient Production
- Polyether Polyols Production
- Pulp and Paper Production
- Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks
- Steel Pickling -- HCl Process Facilities and Hydrochloric Acid Regeneration Plants
- Secondary Aluminum Production
- Oil and Natural Gas Sector
In addition to the requirement to report test data using the ERT, the MATS rule includes requirements for reporting CEMS summary data, parametric monitoring summary data, notification of compliance status reports, excess emission reports, and compliance reports electronically to WebFIRE using the Compliance and Emissions Data Reporting Interface (CEDRI) in EPA’s Central Data Exchange (CDX)
- Electronic Reporting Tool (ERT) – In early 2006, we made available a Microsoft Access© desktop application, called the ERT, which is an electronic alternative to paper reports for source emission tests. The goals and benefits of the ERT include:
- Reduced time and resources to transcribe data from paper to electronic format
- Consistent reporting from all sources
- Broader and more efficient sharing among EPA, State/Local, and Tribal agencies
- Automatic internal QA checks
- Increased compatibility with source testers and laboratories’ electronic databases
We are continually reviewing comments we receive on the ERT and updating the ERT to address these comments in the ERT Revision History (PDF 268K). We released Version 4 of the ERT for beta testing on August 10, 2011 and posted it online for use on October 26, 2011. Version 4 was most recently updated on February 3, 2012. Some of the changes introduced in Version 4 include:
- Addition of the capability for individual users to add target pollutants to an individual ERT project data set. User must enter the CAS number and molecular weight for custom pollutants.
- Revision of the Latitude and Longitude fields to accept only degrees and decimal degrees with a requirement for 5 or 6 digits after the decimal.
- Implementation of the ability to rename runs, rename run dates, and delete runs.
- Addition of EPA Methods 102, 103, 104, 108, 315, and 316 and SW-846 Method 0061, and addition of target compounds to SW-846 Method 0011.
- Addition of the ability to import new and old spreadsheets.
- Addition of a feature to allow test result reports and tables to be exported to MS Word.
- Addition of a Completeness Assessment.
- Revision of the Test Report function such that you are now able to view/export full report or data summary tables now using the .accdb format (corrects attachment restrictions, file size issues etc.).
- Revision of Instrumental Test Methods to allow user to pick from earlier runs for: Stack Flow, Moisture, CO2, O2.
- Revision of isokinetic methods to be able to pull CO2, O2 from Instrumental Test Methods.
- Implementation of procedures to submit properly formatted files to CDX system.
- Correction of test plan and test report to show attachment list from old .mdb files.
- Addition of a button on Run Data Methods screens that allows the user to view/edit the location information for that location without having to go back to the test plan screens.
To download the ERT, access the user’s manual, or learn about training opportunities, please visit the ERT webpage. Contacts: Ron Myers MPG, email@example.com, 919-541-5407 and Rachel Agnew, firstname.lastname@example.org, 919-541-0328.
- Source Classification Code Improvement Project – We are in the process of updating and improving the Source Classification Code (SCC) system. The objective of this project is to correct issues such as: disorganization, duplicate SCCs, “miscellaneous” and “other” categories (which don’t effectively classify the emission process), outdated SCCs, and inconsistencies in the level of detail the SCCs provide. A cross-walk linking retired SCCs to revised SCCs will be developed to help users find the appropriate SCC. To date, SCCs have been revised for 7 sectors and should be posted online by the end of March, 2012. The second stage of this project is to develop a structured methodology for creating new SCCs. Contact: Rachel Agnew, email@example.com, 919-541-0328.