Electronic Audit Update

1. Electronic Audit Update Theresa H. Alexander USEPA/CAMD

2. Agenda • Review of the process • Summary of the 2006 audit activities • Appendix D & E checks • Additional audits • Common Errors • Process changes with re-engineering • Next steps

3. Review of the Audit Process • The initial review of the electronic data is performed by the Emissions Tracking System (ETS) • Feedback is given upon submittal for that quarterly file • Checks on file format, completeness, and recalculation of hourly data are performed • A comprehensive audit of the data is performed using the Monitoring Data Checking (MDC) Software • Reviews the reported QA tests and Test Calculations • Identifies hours for which a test has expired, missing, or failed as invalid • Checks the Monitoring Plan and tracks changes to ensure that the data is collected in a manner consistent with the rule • EMB staff work with sources to resolve errors when identified • Feedback from the E-Audit is sent to the sources • Critical errors must be corrected and the EDR resubmitted by the deadline • CAMD Engineers work with the sources to resolve the errors (e.g., missing records, incorrect parameters, or substitute data) • Conduct Ad hoc checks

4. Summary of the 2006 Activities • Audited all CEMS, Appendix D, Appendix E & Low Mass Emissions (LME) units • Continued to focus on the units with critical errors • Most sources are being very responsive to our feedback • There were very few mistakes in the bias adjustment factor applications (BAF) • Most of the critical errors were from small or new units • Our biggest challenge was with the Appendix D and Appendix E units

5. Appendix D Audit Checks • A historical search of the CAMD database for the most recent fuel flow meter accuracy test and primary element inspection (if applicable) to determine whether the monitoring system is up-to-date with required QA tests • Accuracy tests are required every four calendar quarters but may be extended up to 5 years (20 quarters) from the previous test by the following exceptions • Test deadline extensions for “non-QA” quarters • Use of the fuel flow-to-load ratio test provisions in section 2.1.7 of Appendix D • For orifice, nozzle and venture-type flow meters, a primary element inspection is required every 3 years (12 quarters), unless the deadline is extended using the fuel flow-to-load ratio test

6. Appendix E Audit Checks • Peaking unit status • QA fuel flow meter • NOx emission re-tests are required every 5 years (20 quarters), and whenever the monitored QA parameters are not within acceptable ranges for greater than 16 consecutive unit operating hours

7. Additional Audits • Ad hoc checks • Target Tool for Field Audits (TTFA) is used to generate a list of “suspect units” • List generated is based on statistical analyses of the data • Issues are investigated by the CAMB engineers • Helps the states/regional offices target their field audits • CAMD conducts field audits based on TTFA results • Field audits are conducted by States, CAMD’s contractor and/or EMB

8. Appendix D & E Errors • Failure to report the initial fuel flow meter accuracy test • Failure to conduct the primary element inspection • Failure to conduct or late flow meter quality assurance checks

9. Certification & QA Tests • RATA tests are conducted at the wrong loads • Linearity checks are performed with the wrong value or expired calibration gases • Use of Like-Kind analyzers • Linearity check must be completed by end of 168 operating hour after the probationary calibration error (CE ) test. • Use of these analyzers are limited to 720 cumulative operating hours per calendar year at a particular unit or stack. • To use the “LK” analyzer for > 720 cumulative operating hours, a RATA is required and the analyzer must be redesignated as a backup system in the monitoring plan.

10. Failure to Monitor all Emissions • Probe leaks • Holes in Ductwork • Especially, holes prior to control devices • Failure to maintain ductwork • Ash Handling Systems • Some systems remove emissions • Primarily affects flow-concentration systems • Bypass Stacks • Must account for emissions from bypass stacks • No start-up, shut-down or malfunction exemptions

11. Process changes with re-engineering • Emissions Collection and Monitoring Plan System (ECMPS) client tool allows you to evaluate your data before submitting it • CAMD engineers are available to assist you in resolving critical errors • We will continue to conduct ad hoc audits and refer “suspect” units for further investigation &/or field audits

12. Next Steps • Continue 100% electronic audit of data • Add checks to TTFA if more areas of concern come up • Continue to work in partnership with the states and regions • Continue daily communications with the sources • Prepare for the CAIR monitoring submittals

13. Contact Information • 202-343-9747 • Alexander.theresa@epa.gov