Why is July so Stressful for Air Emission Reporting?
July is the second busiest reporting period of the year. This is because quarterly reports, semiannual, and the first ozone season quarter reports are all due. According to the ECMPS website, “the first date of the 2022 Q2 reporting period is Friday, July 1, 2022. Sources required to report 2022 Q2 emissions data under the Acid Rain Program (ARP), the Cross-State Air Pollution Rule (CSAPR), the NOx SIP Call (SIPNOX), the Texas SO2 Trading Program (TXSO2), the Regional Greenhouse Gas Initiative (RGGI), and the Mercury and Air Toxic Standards (MATS) rule have until the end of the day on Monday, August 1, 2022 to submit their emissions data to the EPA using the ECMPS Client Tool.”
Quarterly EDR Reports
Emissions sources under Part 75 must submit emissions reports four times a year — one report per calendar quarter. These reports allow the EPA to track emissions data throughout the year and must include the following information:
- Facility information;
- The hourly emissions data, operating data, the results of the required QA tests, and other info specified in the monitoring plan and recordkeeping sections of Part 75;
- Unit operating hours for the quarter and cumulative SO2 mass emissions for the calendar year and/or ozone season;
- Tons of SO2 emitted during the quarter and cumulative SO2 mass emissions for the calendar year (ARP units and Clean Air Interstate Rule (CAIR) SO2 units, only);
- Average NOx emission rates (lb/mmBtu) for the quarter and for the year-to-date (ARP units, and certain CAIR NOx units);
- Tons of CO2 emitted during the quarter and cumulative CO2 mass emissions for the calendar year (ARP units);
- Tons of NOx emitted during the quarter and cumulative NOx mass emissions for the calendar year and/or ozone season, as applicable (for CAIR Nox units); and
- Total heat input for calendar year (or ozone season)—unless exempted from heat input reporting by regulation
Semiannual Monitoring Reports
Semiannual monitoring reports cover the times required monitoring for a facility (Part 60 & Part 63) did not occur during the previous six month period. The types of monitoring required at a facility vary bit can include:
- Continuous Monitoring Systems (CEM systems, such as SO2, NOx or CO2 systems, or SCR inlet fuel gas temperatures)
- Periodic monitoring (daily fugitive dust records and readings)
- Monitoring inspections of operating equipment (daily or weekly rounds of operating equipment)
- Periodic testing (schedules depends on the permit)
Ozone Season Quarter Reports
Under the Clean Air Act, EPA implements several regulations that affect power plants, including the Acid Rain Program (ARP), the Cross-State Air Pollution Rule (CSAPR), the CSAPR Update, and the Mercury and Air Toxics Standards (MATS). These programs require fossil fuel-fired electric generating units to reduce emissions of sulfur dioxides (SO2), nitrogen oxides (NOx), and hazardous air pollutants including mercury (Hg) to protect human health and the environment.
For the July Reporting Month requirements, facilities must report their ozone emission data for the time period from 5/1 through 9/30.
Top Tips for July Reporting Success
In order to meet all of your July Reporting deadlines, it is important to understand the four major reasons why July is so difficult.
- The 4th of July holiday typically makes it difficult for staff to get a head start on reasons #2 and #4.
- Plant staff are busy preparing and submitting their usual quarterly reports for Q2.
- The Q2 reports need to be completed before they begin to prepare their semiannual monitoring reports for Title V operating periods.
- At the same time, they must also begin to collate records for Downtime and Excess Emission Report that the state and other local air quality agencies require.
So, how can you make sure you are meeting all of your July deadlines?
- Update your emission database with any fuel quality data (sulfur % or GCV values) into Prism or StackVision databases now.
- Generate quarterly EDR files for those quality assurance and emission records recorded so far in the quarter. Run these files through ECMPS and work on addressing any errors. Fix them now so you don’t feel so pressured in July to beat the July 30th deadline.
- Begin working on semiannual compliance reports.
- Review your logbooks and other documentation so you can try to generate Downtime and Excess Emission Reports.
Once you generate the partial quarterly and semiannual reports mentioned above, review them to ensure they meet your expectations. They may not be complete for the whole quarter or the first half of the year, but at least you will know where you need to spend your time cleaning up.
How ESC Spectrum Can Help
Reporting Services: If you have any issues with your July reporting, our Reporting experts are standing by to help correctly record facility data and ensure your reports meet ever-changing requirements for final submission.
Contact us for any questions regarding reporting, regulatory services or the July reporting period.