Clean Air Markets Division Electronic Audit Update

1. Clean Air Markets Division Electronic Audit Update NOx SIP Call Workshop June 10, 2004 Theresa Alexander, USEPA

2. Background • Recap of E-Audit Program • CAMD received hourly data from over 1000 NOx SIP Call reporters • Perform electronic audits on all CEMS, LME and peaking units

3. Why an Audit Program? • To enhance our cap-and-trade programs through data accuracy and credibility • Designed to identify problems early in the process so they can be corrected • Assists sources in complying with our programs • Identify areas that require improvement and training needs

4. Basic Elements • Check electronic submissions to assure the accuracy of the data • Perform targeted field audits • Provide tools to sources for self assessment & problem prevention • Develop tools to identify benchmarks and to more effectively focus field audit resources

5. QA/QC Begins with the Source • Conducts QA/QC requirements • Generates the Electronic Data Report (EDR) • Performs self-checks by running the EDR through the Monitoring Data Checking (MDC) software and correcting the errors • Submits the EDR to the Emissions Tracking System (ETS)

6. CAMD Process • ETS performs a series of formatting & calculation checks • ETS sends automatic feedback • The E-Audit Process begins once ETS accepts the EDR • E-Audits are performed and feedback is sent

7. E-Audit Overview • EDRs are audited using the MDC software • MDC Quarterly Review System(MDC-QR) • MDC Hourly • Ad-hoc Evaluations • Targeted Field Audits

8. MDC-QR • Equivalent to MDC (Review menu function) • Performs import evaluation, identifies data inconsistencies, looks for basic file structure errors

9. MDC-QR • Evaluates the monitoring plan in that quarter’s EDR (e.g., monitoring methodologies, emissions formulas, systems used) • Evaluates the reported QA test in that quarter’s EDR (e.g., check calculations, determine past/failure status, reference methods, calibration gases)

10. MDC-CAMD • Data from MDC-QR is loaded into MDC-CAMD • MDC-CAMD is a separate database that contains a historical record of all the monitoring plans and QA tests • MDC-CAMD also includes monitoring plans and certification/recertification test data submitted to the EPA regional mail boxes

11. MDC-CAMD • From this database it is possible to perform hourly data checks across quarterly boundaries • Bias Adjustment Factor applications • Out-of-control systems • Equivalent to running MDC-Hourly, provided the unit’s historical MDC database is populated

12. BAF Checks • MDC-CAMD allows for EPA to audit for the proper application of the BAFs • Each hours unadjusted reported value is multiplied by the accepted BAF from a qualified RATA and compared to the reported adjusted value

13. Out-of-Control System Checks • The OOC checks are used to identify hours that are reported as quality assured, but do not have the QA records to match • The OOC system checks for: • Missing or Expired QA Tests • Incomplete QA tests • Failed QA tests

14. MDC Feedback • Feedback from the MDC audits are combined and 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., substitute data)

15. Resubmission Deadlines • Sources have until: • 1Q04 - July 1, 2004 • 2Q04 - October 1, 2004 • 3Q04 - December 30, 2004 • 4Q04 - March 15, 2005

16. Ad-hoc Audits • EPA also performs Ad-hoc audits of the data to evaluate • MPC, Span, and Range • Flow-to-Load Ratio • Missing Data Substitution • Other QA parameters, as applicable

17. Ad-hoc Audits • These audits are not currently automated by any of the MDC products and are selected on an as needed basis • Ad-hoc feedback may lead to an email or phone call to the plant contact or Authorized Account Representative • Ad-hoc audits can also result in the use of substitute data

18. Field Audits • Provides for another independent means to QA emissions data • These audits are targeted based on statistical analyses of emissions data • Engineers review all the data from the targeted plant and conduct comprehensive audits • These audits also involve regional and state personnel

19. Typical Errors • Failure to correctly apply BAFs • RATAs conducted at wrong loads • RATAs performed after due date • Missed linearity checks

20. Typical Errors • Failure to respond to flow-to-load variations • Failure to make annual span and range adjustments • Incorrect calibration gases

21. Highlights • Issues with different databases &/or use of different MDC versions • Mail box submittals for monitoring plans and certifications and recertifications • Different historical databases

22. 2003 Audit Results • NOx Sip Call files audited: ~ 450 • Critical errors: ~ 200 • Excess Emissions: 7 units

23. Recent Changes • Combined MDC-QR & Hourly feedback • MDC updated to calculate test exemptions and extensions • More effective internal tracking tool of audit results • Feedback during the submission period • More effective way to target sources for field audits

24. Future Focus • Address issues with new reporters • Further scrutiny of annual adjustments • Development of benchmark analyses • Statistical analysis to identify outliers • Gearing up for re-engineering