Reporting Month: Key Air Compliance Lessons Learned

Once the fourth quarter's reporting window has closed, there is finally an opportunity to reflect on the past year. We compiled a list of air compliance lessons learned, based on customers' feedback.
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What is Reporting Month?

Facilities that must comply with 40 CFR Part 60 and 40 CFR Part 63 must submit reports to the EPA on a quarterly, semiannual, and annual basis. At the end of the reporting period, the facility has 30 calendar days to prepare and submit the required report under the Responsible Official’s signature for the facility. Emissions sources under 40 CFR Part 75 must submit emissions reports four times a year – one report per calendar quarter.

Air Compliance Lessons Learned

Once the fourth quarter’s reporting window has closed and all the other permit-required reports are on their way to the EPA, there is finally an opportunity to reflect on the past year. Think about what went well, what you learned, and identify areas for improvement. We compiled a list of lessons learned last year based on our customers’ feedback.

Take a few minutes and lock down the database for your monitoring systems each quarter (remember that StackVision has a wizard that guides you through this process: Tools – Data Locking Wizard). It typically takes only 5 minutes to lock down the entire quarter, including all data sets. This practice prevents the accidental re-processing of previously submitted or accepted data.

Take a few minutes and lock down the database for your monitoring systems each quarter (remember that StackVision has a wizard that guides you through this process: Tools – Data Locking Wizard). It typically takes only 5 minutes to lock down the entire quarter, including all data sets. This practice prevents the accidental re-processing of previously submitted or accepted data.

  • Look at your data reports weekly or more frequently.
  • Flag downtime, exceedance, and excess emission events with proper reason and action codes.
  • At least once a month, generate a QA and emission EDR file and run them through ECMPS.

These significant events require a lot of coordination and preparation.

  • RATAs for Part 75 usually occur two or four calendar quarters after the last successful test. RATAs for Part 60 are due within the next four calendar quarters after the previous successful test. The RATA Editor in StackVision is a helpful tool for tracking your RATAs (it will tell you how many quarters can pass before the next RATA is required).
  • Stack testing requirements can be complicated and confusing. In general, the regulation, the permit, or the letter from the state agency accepting the last set of results will list the requirements for when the test can occur. Some regulations give you a window (i.e., you must wait X months before or complete by Y months or days for the next round of tests.)

There are different ways to perform flow meter checks. Getting these checks completed is expensive and requires planning.

  • You can perform the test using a second meter in line with your existing meter and compare the amount of fuel flow recorded by each. Another type of test requires the meter’s removal to send to an approved vendor for an accuracy test (while a replacement meter takes its place).
  • Check on your Quality Assurance Quality Control (QAQC) Plan. In some situations, you may be able to delay QA checks to the next quarter.

ESC Spectrum’s Resources For Air Compliance

While these recommendations require time on the front end, you will save yourself from future headaches by investing in reviewing past events and adjusting plans accordingly. As always, the ESC Spectrum is standing by to put your lessons learned into practice. Contact us today for a quote on our full suite of CEMS and DAS solutions.

 

Are you looking for resources on Air Quality Compliance Reporting? Read this blog post to learn more about the activities required for 40 CFR Part 60, 63, and 75 reporting. Read about how to perform fuel flow to load or gross heat rate checks and how to improve your quality assurance filing process for more help with your air quality compliance. You can find more air compliance advice and resources in our air emissions compliance blog, “The Source.”

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