A Hands-On Approach to Learning About Emissions Testing Reporting

1. A Hands-On Approach to Learning About Emissions TestingReporting Angela Hansen, QSTI How many of you have reviewed a source test report? written a source test report? My name is Angela Hansen, and I write source test reports � lots of them! I have written or reviewed thousands of source test reports while working with AmTest Air Quality and I am here today to share with you what is supposed to be included in a source test report and what to look for in a report if you are reviewing one.How many of you have reviewed a source test report? written a source test report? My name is Angela Hansen, and I write source test reports � lots of them! I have written or reviewed thousands of source test reports while working with AmTest Air Quality and I am here today to share with you what is supposed to be included in a source test report and what to look for in a report if you are reviewing one.

2. I obtained the information in this presentation from several sources, including EPA�s Guideline Document 043 (there is a copy on the back table) you can find it on the EPA ttn web site at www.epa.gov/ttn/emc click instructional material, then on guideline documents EPA�s Red Book � Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III EPA�s Source Testing Policy (I brought a few copies of this document in case you haven�t seen it before) Alaska DEC�s policy from their SIP Idaho DEQ�s Source Test Guidance Manual They are all basically the same � some agencies have slightly different requirements, which I will discuss later. The first part of the report should contain a summary paragraph which includes the following: Who � plant, source test contractor, labs should be listed. The agency observers should also be listed. What � pollutants measured When � date Where � location of plant, site tested Why � regulation requiring the test Then all parties involved should be listed, including the source, testing company, subcontract labs, etc. I also include the physical plant address and the mailing addresses for everyone The report should include a certification signed by a member of the test team and by a responsible representative of the testing firm certifying that �to the best of their knowledge� the source test report has been checked for completeness, and that the results presented therein are accurate, error-free, legible, and representative of the actual emissions measured during testing. The responsible official should have a PE, QEP, or QSTI certification.I obtained the information in this presentation from several sources, including EPA�s Guideline Document 043 (there is a copy on the back table) you can find it on the EPA ttn web site at www.epa.gov/ttn/emc click instructional material, then on guideline documents EPA�s Red Book � Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III EPA�s Source Testing Policy (I brought a few copies of this document in case you haven�t seen it before) Alaska DEC�s policy from their SIP Idaho DEQ�s Source Test Guidance Manual They are all basically the same � some agencies have slightly different requirements, which I will discuss later. The first part of the report should contain a summary paragraph which includes the following: Who � plant, source test contractor, labs should be listed. The agency observers should also be listed. What � pollutants measured When � date Where � location of plant, site tested Why � regulation requiring the test Then all parties involved should be listed, including the source, testing company, subcontract labs, etc. I also include the physical plant address and the mailing addresses for everyone The report should include a certification signed by a member of the test team and by a responsible representative of the testing firm certifying that �to the best of their knowledge� the source test report has been checked for completeness, and that the results presented therein are accurate, error-free, legible, and representative of the actual emissions measured during testing. The responsible official should have a PE, QEP, or QSTI certification.

3. What EPA Wants in Reports 2.0 Plant and Sampling Location Descriptions 2.1 Process Description 2.2 Control Equip. Description 2.3 Sampling Locations 2.4 Process Sampling Locations Stack testers need the plant to help with this section of the report. We need you to provide a general description of the basic process It is very helpful if the plant provides a flow diagram to us where we can mark the emission and process test points This write-up should include a discussion of typical process operations, such as: - Production rates � info to verify that the source was operating at worst-case normal operating conditions or other requirement - Feed material and feed rates or batch sizes - Equipment sizes and capacities (ratings) Production schedules (hours/day, days/week, weeks/year, peak periods) The plant should sign and date their process data and spell out what units the data is in The report should include a schematic of each sample location that includes the duct diameter, direction of flow, dimensions to nearest upstream and downstream disturbances (include number of duct diameters), location and configuration of the sampling ports, nipple length and port diameters, the number and configuration of traverse points Photos of the stack and sampling locations are very helpful The write-up should confirm that the sampling location met the EPA criteria - if not, give reasons why not and discuss the effect on results. Discuss any special traversing or measurement schemes used. If process stream samples (fuel or feed samples) were taken discuss this here. Stack testers need the plant to help with this section of the report. We need you to provide a general description of the basic process It is very helpful if the plant provides a flow diagram to us where we can mark the emission and process test points This write-up should include a discussion of typical process operations, such as: - Production rates � info to verify that the source was operating at worst-case normal operating conditions or other requirement - Feed material and feed rates or batch sizes - Equipment sizes and capacities (ratings) Production schedules (hours/day, days/week, weeks/year, peak periods) The plant should sign and date their process data and spell out what units the data is in The report should include a schematic of each sample location that includes the duct diameter, direction of flow, dimensions to nearest upstream and downstream disturbances (include number of duct diameters), location and configuration of the sampling ports, nipple length and port diameters, the number and configuration of traverse points Photos of the stack and sampling locations are very helpful The write-up should confirm that the sampling location met the EPA criteria - if not, give reasons why not and discuss the effect on results. Discuss any special traversing or measurement schemes used. If process stream samples (fuel or feed samples) were taken discuss this here.

4. What EPA Wants in Reports 3.0 Summary and Discussion of Test Results 3.1 Objectives and Test Matrix summary table is helpful 3.2 Field Test Changes and Problems 3.3 Presentation of Results include a subsection for each pollutant In this section you restate the overall purpose of the test program and list the objectives. An overall summary table with the following information is helpful: - Run no. and date - Sample type/pollutant - Test method - Sampling locations - Clock time Sampling time Section 3.2 is very important and over the years I have learned it is better to state any problems and discuss the impact on results to avoid questions in the future % isokinetics, rejected runs Shortened sample times, process problems weird data acquisition situations Present summary tables and discussions for each method performed. Present results in both English and metric units. Include the permit limit in the tables. Results need to be presented in units of the emission standard.In this section you restate the overall purpose of the test program and list the objectives. An overall summary table with the following information is helpful: - Run no. and date - Sample type/pollutant - Test method - Sampling locations - Clock time Sampling time Section 3.2 is very important and over the years I have learned it is better to state any problems and discuss the impact on results to avoid questions in the future % isokinetics, rejected runs Shortened sample times, process problems weird data acquisition situations Present summary tables and discussions for each method performed. Present results in both English and metric units. Include the permit limit in the tables. Results need to be presented in units of the emission standard.

5. What EPA Wants in Reports 4.0 Sampling and Analytical  Procedures 4.1 Test Methods 4.2 Process Test Methods In this section, include the following: - Schematic of each sampling train - Flow diagram of the sample recovery - Flow diagram of sample analysis - Description of any modifications to the methods used - Discussion of any problematic sampling or analytical conditions If a non-EPA method was used in place of an EPA method, explain the reason. Include a copy of non-EPA or novel methods in the appendices of the report. Discuss any process sampling that was performed (fuel sampling, etc.) Lab analysis results should discuss any deviations and be signed by a responsible official at the lab and include the C-of-C Include a complete set of sample calculations for one run of each pollutant test (by-hand) Discuss how non-detect data was handled in the calculations � I will discuss non-detect reporting later in my presentation Some agencies like a copy of the permit and the test plan and the test plan approval letter included in the appendices.In this section, include the following: - Schematic of each sampling train - Flow diagram of the sample recovery - Flow diagram of sample analysis - Description of any modifications to the methods used - Discussion of any problematic sampling or analytical conditions If a non-EPA method was used in place of an EPA method, explain the reason. Include a copy of non-EPA or novel methods in the appendices of the report. Discuss any process sampling that was performed (fuel sampling, etc.) Lab analysis results should discuss any deviations and be signed by a responsible official at the lab and include the C-of-C Include a complete set of sample calculations for one run of each pollutant test (by-hand) Discuss how non-detect data was handled in the calculations � I will discuss non-detect reporting later in my presentation Some agencies like a copy of the permit and the test plan and the test plan approval letter included in the appendices.

6. What EPA Wants in Reports 5.0 Internal QA/QC Activities 5.1 QA/QC Problems 5.2 QA Audits Was anything out of calibration? Were there any sample custody issues? Discuss QC checks like instrument calibration, matrix spikes, duplicate analyses, internal standards, blanks, linearity checks, drift checks, response time checks, and system bias checks. Did you use an alternate calibration method? We use ALT-009 and 011 for most of our jobs, so this needs to be spelled out. The appendices of the report should include: chain-of-custody records for any subcontracted lab work For gaseous testing you should include copies of gas cylinder certificates and the analyzer name, model number and range, copies of strip charts or data acquisition printouts Need copies of interference checks and converter efficiency checks Current calibrations for meter boxes, pitot tubes, thermocouples, rotameter, orifices, etc. Copies of all raw field data and process data If opacity is performed, a copy of the observer�s certificate should be included Once accreditation is required for specific subparts, testers should include copies of QSTI certificates and their company�s accreditation certificate in their reports For each of the test methods for which an audit was conducted, list (if applicable) the following: - Type of audit conducted - Limits of acceptability - Supplier of audit material - Audit procedure - Summary of results (mention a good Table of Contents then SEGWAY FROM REPORTS TO ERT)Was anything out of calibration? Were there any sample custody issues? Discuss QC checks like instrument calibration, matrix spikes, duplicate analyses, internal standards, blanks, linearity checks, drift checks, response time checks, and system bias checks. Did you use an alternate calibration method? We use ALT-009 and 011 for most of our jobs, so this needs to be spelled out. The appendices of the report should include: chain-of-custody records for any subcontracted lab work For gaseous testing you should include copies of gas cylinder certificates and the analyzer name, model number and range, copies of strip charts or data acquisition printouts Need copies of interference checks and converter efficiency checks Current calibrations for meter boxes, pitot tubes, thermocouples, rotameter, orifices, etc. Copies of all raw field data and process data If opacity is performed, a copy of the observer�s certificate should be included Once accreditation is required for specific subparts, testers should include copies of QSTI certificates and their company�s accreditation certificate in their reports For each of the test methods for which an audit was conducted, list (if applicable) the following: - Type of audit conducted - Limits of acceptability - Supplier of audit material - Audit procedure - Summary of results (mention a good Table of Contents then SEGWAY FROM REPORTS TO ERT)

7. Electronic Reporting Tool (ERT) www.epa.gov/ttn/chief/ert/ert_tool.html Available for Methods 1, 2, 3A, 4, 5, 6C, 7E, 10, 17, 23, 25A, 26A, 29, 101, 101A, 201A, 202, CTM 39, CTM 40, OTM 27, OTM 28 Application (the ERT �software�) Project Data Set (PDS) Excel Spreadsheet  The ERT is a Microsoft Access desktop application designed as an alternative for paper reports. It is available for download at epa.gov/ttn/chief/ert. There are several videos and webinars that can be viewed at that site. There are 3 parts to the application: The Application (the Access database) The Project Data Set an Excel Spreadsheet (you can use EPA�s or your own) The Application has all of the screens, reports, calculations and other items necessary to create and distribute the Test Plan and Test Report. The Project Data Set (PDS) contains the Test Plan and Test Report Data. This is the file that will be exchanged between the tester, the source, and the Agency. Each PDS includes information for one test report. When you start a new ERT, you are prompted to name the PDS that is created automatically in a "Project Data" directory. The last PDS used is remembered by the ERT when restarted. There is no limit on the number of PDS files but only one PDS can be opened at a time. You can use old ones that are similar for �templates.� The Excel spreadsheet is intended to be used as a replacement for other field data calculation and entry software in the field (or office) to enter the run information. While the spreadsheet functions like most field data collection spreadsheet applications, many groups of cells have been named to allow exporting of critical data. The ERT has the ability to import this data into the selected PDS. To use the ERT, you can use this spreadsheet file, transcribe the data manually, or create the appropriate links in your own spreadsheet. There is still information in the ERT that needs to be setup before the excel spreadsheet data can be imported. This is actually a fairly complicated process, until you have practice filling out these ERT�s. We did 10 of them last year and got pretty good at them The ERT is a Microsoft Access desktop application designed as an alternative for paper reports. It is available for download at epa.gov/ttn/chief/ert. There are several videos and webinars that can be viewed at that site. There are 3 parts to the application: The Application (the Access database) The Project Data Set an Excel Spreadsheet (you can use EPA�s or your own) The Application has all of the screens, reports, calculations and other items necessary to create and distribute the Test Plan and Test Report. The Project Data Set (PDS) contains the Test Plan and Test Report Data. This is the file that will be exchanged between the tester, the source, and the Agency. Each PDS includes information for one test report. When you start a new ERT, you are prompted to name the PDS that is created automatically in a "Project Data" directory. The last PDS used is remembered by the ERT when restarted. There is no limit on the number of PDS files but only one PDS can be opened at a time. You can use old ones that are similar for �templates.� The Excel spreadsheet is intended to be used as a replacement for other field data calculation and entry software in the field (or office) to enter the run information. While the spreadsheet functions like most field data collection spreadsheet applications, many groups of cells have been named to allow exporting of critical data. The ERT has the ability to import this data into the selected PDS. To use the ERT, you can use this spreadsheet file, transcribe the data manually, or create the appropriate links in your own spreadsheet. There is still information in the ERT that needs to be setup before the excel spreadsheet data can be imported. This is actually a fairly complicated process, until you have practice filling out these ERT�s. We did 10 of them last year and got pretty good at them

8. Electronic Reporting Tool (ERT) Create the Test Plan Print and attach draft Test Plan into PDS (optional) Test Plan (via PDS file) is submitted to the Agency Agency approves or returns (via PDS file) to submitter for revisions Test Plan (via PDS file) is revised and re-submitted to the Agency Field data is entered into the ERT Excel Spreadsheet After test is performed, test and process data is entered into The ERT PDS file PDS file is submitted to Agency Agency reviews PDS According to EPA, this is how the process will work: Create the Test Plan Print and attach draft Test Plan into PDS (optional) Test Plan (via PDS file) is submitted to the Agency Agency approves or returns (via PDS file) to submitter for revisions Test Plan (via PDS file) is revised and re-submitted to the Agency Field data is entered into the ERT Excel Spreadsheet After test is performed, test and process data is entered into The ERT PDS file PDS file is submitted to Agency Agency reviews PDS In their instructions, EPA forgot to include the step where the source would have an opportunity to review the PDS. So the file could actually be transferred up to 6 times. According to EPA, this is how the process will work: Create the Test Plan Print and attach draft Test Plan into PDS (optional) Test Plan (via PDS file) is submitted to the Agency Agency approves or returns (via PDS file) to submitter for revisions Test Plan (via PDS file) is revised and re-submitted to the Agency Field data is entered into the ERT Excel Spreadsheet After test is performed, test and process data is entered into The ERT PDS file PDS file is submitted to Agency Agency reviews PDS In their instructions, EPA forgot to include the step where the source would have an opportunity to review the PDS. So the file could actually be transferred up to 6 times.

9. Electronic Reporting Tool (ERT) My thoughts on using the ERT: Difficult to learn � not normal file logic Difficult to share the file � it gets spammed Difficult to tailor, unlike Excel Source, Agency, and Tester all need to learn to use it properly for it to be a useful tool  The ERT is the software and the PDS is the �file� The tester should draft the test plan, then send the file to the client to review, then to the agency for review, then the agency sends it back and the tester puts the data in and the process is repeated. There also needs to be client review. I worry that we are not savvy enough using the Access software to have a seamless hand-off, but I guess we won�t know until we try it As far as I know, each person viewing the PDS can make edits to it, so how does the test firm protect themselves against the client or agency making an edit to their data that they are unaware of? It is hard to attach the file to an e-mail because .mdb files are seen as spam by virus protection software, so we would need some kind of file protocol transfer software to use to send it between the 3 parties When you use Excel it is easy to edit the spreadsheet for a run with a shortened run time or some weird exception � in the ERT you have to devise a way to trick it to give you the answer you need I think it has possibilities for the future of source test reporting, but clients are going to need to be willing to pay more for testers to work up the data two different ways until the learning curve issues are dealt with There are still lots of bugs in the ERT, so it is evolving as testers use it and provide feedback to EPA. When I used it I compared my results to theirs and they are close, but the ERT handles blank correcting differently and show too many or too few sig figs I think we would need a hands-on training course we could all take to learn to use it properly. EPA has hosted some webinars, but much more education of the stakeholders is needed. SEGWAY INTO A BRIEF DISCUSSION OF NON-DETECT REPORTING The ERT is the software and the PDS is the �file� The tester should draft the test plan, then send the file to the client to review, then to the agency for review, then the agency sends it back and the tester puts the data in and the process is repeated. There also needs to be client review. I worry that we are not savvy enough using the Access software to have a seamless hand-off, but I guess we won�t know until we try it As far as I know, each person viewing the PDS can make edits to it, so how does the test firm protect themselves against the client or agency making an edit to their data that they are unaware of? It is hard to attach the file to an e-mail because .mdb files are seen as spam by virus protection software, so we would need some kind of file protocol transfer software to use to send it between the 3 parties When you use Excel it is easy to edit the spreadsheet for a run with a shortened run time or some weird exception � in the ERT you have to devise a way to trick it to give you the answer you need I think it has possibilities for the future of source test reporting, but clients are going to need to be willing to pay more for testers to work up the data two different ways until the learning curve issues are dealt with There are still lots of bugs in the ERT, so it is evolving as testers use it and provide feedback to EPA. When I used it I compared my results to theirs and they are close, but the ERT handles blank correcting differently and show too many or too few sig figs I think we would need a hands-on training course we could all take to learn to use it properly. EPA has hosted some webinars, but much more education of the stakeholders is needed. SEGWAY INTO A BRIEF DISCUSSION OF NON-DETECT REPORTING

10. Non-Detect Reporting There are three ways data has historically been reported when results were less than the detection limit (DL) : DL = the calculated in-stack DL(very conservative) DL = � of the calculated in-stack DL(conservative) DL = Zero(lenient � �best-case emissions�) 

11. New Non-Detect Reporting Protocol BDL (below detection level) - all analytical values used to calculate and report an in-stack emissions value are less than the laboratory�s reported detection level(s) DLL (detection level limited) - at least one but not all values used to calculate and report an in-stack emissions value are less than the laboratory�s reported detection level(s) ADL (above detection level) - all analytical values used to calculate and report an in-stack emissions value are greater than the laboratory�s reported detection level(s)  For the recent Information Collection Request (ICR) reporting using the ERT the EPA has requested these 3 data flags: BDL � this is the case where you have multiple portions to a sample and all samples were below the DL. The DL is used in the calculations and the data is flagged as BDL. DLL � this is the case where you have multiple portions to a sample and some are hits and some are less than DL. The DL is used for the portions that are less than the DL and added to the hits, so it can potentially bias non-detected emissions higher than what is �real� ADL � the number was a �hit� � these are �real� emissions; for example with a multi-metals train, all 5 portions were above the DL for that run. And for the average of 3 runs all portions of all runs were ADL. All of these flags are added to data that is reported using the Electronic Reporting Tool in the comments areas. So this style of reporting may be the way of the future. For the recent Information Collection Request (ICR) reporting using the ERT the EPA has requested these 3 data flags: BDL � this is the case where you have multiple portions to a sample and all samples were below the DL. The DL is used in the calculations and the data is flagged as BDL. DLL � this is the case where you have multiple portions to a sample and some are hits and some are less than DL. The DL is used for the portions that are less than the DL and added to the hits, so it can potentially bias non-detected emissions higher than what is �real� ADL � the number was a �hit� � these are �real� emissions; for example with a multi-metals train, all 5 portions were above the DL for that run. And for the average of 3 runs all portions of all runs were ADL. All of these flags are added to data that is reported using the Electronic Reporting Tool in the comments areas. So this style of reporting may be the way of the future.

12. What the Source Should Do With Their Report Review the test firm�s report � compare results to historical data � did I pass? Consider having an outside consultant review the test report too Forward the results of the testing to the appropriate agency within the time frame specified in their permit or by the regulation Most firms will provide a draft report for the source to review � the client should look at it carefully and if they don�t have the time or expertise they should use an outside consultant to review it The company should send the report to the agency themselves � many agencies require special paperwork or signatures to be submitted along with the report � check your permit requirements. Some examples are: NWCAA�s form ODEQ�s STAR Reports � I have an example for Method 5 Most firms will provide a draft report for the source to review � the client should look at it carefully and if they don�t have the time or expertise they should use an outside consultant to review it The company should send the report to the agency themselves � many agencies require special paperwork or signatures to be submitted along with the report � check your permit requirements. Some examples are: NWCAA�s form ODEQ�s STAR Reports � I have an example for Method 5

16. ?Questions?