United States Office of Air Quality EPA-340/1 -84-015
Environmental Protection Planning and Standards September 1984
Agency Washington DC 20460
Stationary Source Compliance Series
Technical
6
Guidance On
Review and Use
Of Excess
Emission Reports
c
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EPA-340/1-84-015
Technical Guidance On
The Review and Use Of
Excess Emission Reports
Prepared by
Louis R. Paley
Technical Support Branch
U.S. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460
September 1984 U.S. Environmental Protection Agency
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,'. £v ..:->jrn Street, Room 1670
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ATTACHMENT
TECHNICAL GUIDANCE ON THE REVIEW AND USE OF
EXCESS EMISSION REPORTS (EERS)
GUIDANCE Page
NO.
I. INTRODUCTION AND SUMMARY 1
II. INVENTORY DEVELOPMENT AND DETERMINATION OF 3
SOURCE COMPLIANCE WITH CEMS INSTALLATION AND
OPERATING REQUIREMENTS
III. EXCESS EMISSION REPORT ANALYSIS 4
IV. EXAMPLE TARGETING CRITERIA AND RECOMMENDED 9
AGENCY FOLLOW-UP ACTIONS
V. ENTRY OF EER DATA INTO THE CEMS SUBSET OF CDS 16
VI. REVIEW OF CEMS DATA QUALITY AND SOURCE 16
COMPLIANCE WITH ALL CEMS REQUIREMENTS
VII. CONTACTS FOR FUTURE TECHNICAL ASSISTANCE, 18
COMMENTS, AND ADDITIONAL COPIES OF GUIDANCE
APPENDICES
1. EER Reviewer's Checklist A-l
2. Summary of Agency Survey of Recommendations for A-2
Revising EER Requirements and for Using EERS
0 Need for EER summary
0 Summarize quantity of incidents and
duration of excesses
0 Normalize data using process operating
data
0 Categorize excess emission data
0 Use standarized reason category definitions
0 Minimum agency EER review program
3. CEMS General Compliance Audit Data Sheet A-3
4. NSPS Source Categories Which are Required to A-4
Use Continuous Emission Monitors
FIGURES
1. Agency's Review and Use of CEMS Data F-l
2. Example of Sources Which Should be Targeted F-2
for Follow-up Action
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TECHNICAL GUIDANCE ON THE REVIEW AND USE OF EXCESS EMISSION
REPORTS (EERS)
I. Introduction and Summary
This guidance is in direct support of three Agency
policy statements on the Stationary Air Compliance Program.*
Although it outlines a program primarily based upon Agency
experience with EERs from large boilers, the guidance can be
used for the review and follow-up of EERs derived from
continuous emission monitoring systems (GEMS) required by most
Federally-enforceable regulations (most current applications
of CEMS data, other than direct compliance determinations
with emission standards such as in Subpart Da) . Specifically
these applications of CEMS/EER data include targeting, general
source surveillance, determinations of compliance with operation
and maintenance (O&M) requirements, and general case support.
The guidance recommends the implementation of a methodical
procedure to review and follow up on EERs derived from sources
which the agency believes for the most part are in compliance
with their emission, monitoring, and reporting requirements.
In general, the procedures are not designed primarily for use
on known violators or sources which have had a long history
of non-compliance. The guidance will facilitate the agency's
division of the remaining ("nominally complying") sources into
two groups: (a) those with suspected compliance problems; and
(b) those that are apparent-ly in compliance. For sources
suspected of a violation, the agency should follow-up the EER
review with conventional compliance methods such as stack
tests, and for the second group simply update its compliance
data system, as necessary.
It is believed that such a process will permit the agency
to better concentrate its resources on those sources which
have compliance problems. Accordingly, implementation of the
guideline should be seen and used as an important supplement
to an agency's present surveillance/compliance monitoring
methods.
The technical guidance addresses various elements of an
effective program to use EERs and is divided into five sections:
0 development of a CEMS inventory and determination of
source compliance with CEMS installation and operating
re qu i r erne nt s;
* "Agency Operating Guidance FY 1985-1986" dated February 1984;
"Compliance Strategy for Stationary Sources of Air Pollution",
dated January 1984; "Strategy to Assure Continuous Compliance
by Stationary Sources of Air Pollution", dated April 1984.
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0 excess emission report analysis;
0 examples of criteria and agency follow-up actions;
0 entry of EER data and results of agency review into
CDS and its GEMS Subset; and
0 general review of GEMS data quality and source compli-
ance with all GEMS requirements.
Figure 1, which depicts the agency's "Review and Use of GEMS
Data," should facilitate the reader's understanding of the
guidance.
The major objective of this guidance is to assist Regional
Offices in proceeding expeditiously, and in a nationally
consistent manner, with the review and follow-up of EER data
from NSPS Subpart D and other source categories where the
monitoring system is not the compliance method. The guidance
intentionally permits a fair measure of flexibility in order
to allow each agency to optimize its EER program implementation.
The guidance suggests that with the exception of Phases
1 and 2 of the EER analysis, the results of the agency's
review of EERs are best handled in the same manner as any
other surveillance data. In short, such data is conceptially
similar to agency receipt of information such as a citizen's
complaint, and therefore should be integrated directly into
an agency's traditional surveillance/compliance program at a
similar point in that process. In the situation where the
agency has an ongoing enforcement action or case development
against a source, the agency should consider adding potential
GEMS violations or data to the case.
Experience has shown that the three most important areas
for agencies to apply their GEMS program resources are in:
(a) inventory development; (b) determination of source
compliance with GEMS installation and operating requirements;
and (c) review of EERs and Agency follow-up. It is recognized
that between the initial operation of the GEMS and the submittal
of an EER there are a number of intermediate activities which
a source is required to perform, such as to demonstrate
achievement of the performance specifications. However, by
emphasizing these three areas of the EER program, the agency
can make it clear to the source that the agency is interested
in minimizing emissions through the source's proper operation
and maintenance of its process and control systems. Although
the agency needs to receive valid data, it is the source's
responsibility to take action to assure the quality of the
data. Therefore, the degree of the agency's involvement in
the intermediary steps needs to be balanced against a more
effective review and use of the EERs.
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The guidance suggests that agencies initiate a three-phase
EER review and follow-up program concurrently with the
development of a thorough inventory of CEMS-affected sources
and the determination of the compliance status of these
sources with GEMS installation and operating requirements.
Absence of a complete inventory should not preclude use of
data presently available.
Although the subject technical guidance provides many of
the details on how to implement an EER program, the comments
received on the draft document indicated that additional, more
specific technical information would be very helpful. Such
information will be included in a forthcoming EER Users
Handbook, to be issued in FY 1985.
II. Inventory Development and Determination of Source Compliance
with GEMS Installation and Operating Requirements
As noted previously, inventory development and determina-
tion of source compliance with GEMS installation and initial
operating requirements (§60.13{b)), though preliminary steps
to an EER review, are two of the three most important activities
an agency should implement when beginning its GEMS program.
Upgrading of an agency's current inventory is important, but
doesn't have to be completed before the agency begins to
determine the compliance status of sources in its current
inventory with GEMS installation and initial operating
requirements or establishes a program to utilize available EERs._
Although such determinations are important because the
timing of initial GEMS operation determines when the initial
EER had to be submitted, experience shows that an agency can
effectively begin to evaluate and follow up on EER data before
it completes either the inventory or the compliance determi-
nations .
To the extent that the agency is not certain that its
GEMS inventory is current and complete, it should upgrade its
inventory. There are a number of possible resources that may
be useful in carrying out this task. They include:
0 the current CDS and the CEMS Subset;
0 the NSPS Subpart D CEMS regulations;
0 "Power Directory-1983 - An Environmental Directory
of United States Steam Electric Power Plants", by
the Edison Electric Institute; and
0 various types of State and Federal agency records
(e.g., inspection and test observation reports,
recent background reports associated with the
development of the NSPS Subpart D (revision), Da
and Db).
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III. Excess Emission Report Analysis
The third of the three most important elements of GEMS
program implementation is excess emission report analysis.
(This document delays addressing any GEMS requirements dealing
with activities which chronologically occur between initial
operation of the monitor and source submission of EERs until
after discussing EER review and follow-up procedures. Such
information can be found in Section VI of the guidance).
As per §60.7, thirty days following the first calendar
quarter during which the source installed and began operating
its GEMS, it is required to submit its first EER to the
agency. Thus, a source must submit EERs even if its monitor
has not undergone or passed a Performance Specifications Test
(PST). If the agency is not currently receiving EERs, it
should request all of its CEMS-affected sources to submit
them.
Experience indicates that once the GEMS is installed and
operational, agency insistence on: (a) timely submission of
the EER; (b) review and follow up of the data; and (c) discussion
of the results with the source, provides a great deal of
motivation for the source to operate and use its GEMS to
minimize its emissions. Therefore, it is essential for the
agency with primary EER responsibility to obtain, review, and
follow up on the most recent EER from every source required
to install GEMS.
The recommended analysis and follow up to the source-
submitted EER is presented as a three-phase process in this
guidance as follows:
0 Phase 1 - initial review and summarization of EER
data;
0 Phase 2 - confirmation of Phase 1 results, targeting
of sources for follow-up, and data input to the GEMS
Subset of the CDS; and
0 Phase 3 - follow-up comparison of GEMS data and
other emission data, and potential recommendations
for additional testing or compliance/enforcement
actions.
All EERs must be subjected to Phase 1 and Phase 2 evalua-
tions. Evaluations performed during these two phases are
unique to GEMS data. Phase 3 of the EER program should
represent a conventional agency follow-up to data which have
identified a possible violator.
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Experience has shown that each EER should be processed
"sequentially" as it is received, as the EERs usually arrive
at the agency individually and as they are usually assigned
to different case engineers. Also, it appears to be most
beneficial for the agency to enter the new compliance data
into its CDS at major milestones during the 3 phases.
The phases are described in more detail below.
A) Phase 1 - Screening Assessment and Summarization of
the Data
During the Phase 1 evaluation, the reviewer is to perform
a preliminary evaluation of the data and to summarize the
data into specific categories for subsequent entry into the
GEMS Subset of the CDS. A few Regional Offices have found
that this can be very effectively done by para-professionals
or technicians and that it takes about an hour per EER. The
following paragraphs provide additional details about Phase 1
act ivities.
1) Assess the completeness and general acceptability
of the EER.
One should perform a general assessment of the
EER. Items 1 to 5 on the "EER Reviewer's Checklist"
are provided in Appendix 1 for the reader's con-
venience in completing this activity. Such an
assessment should compare the EER with the following
requirements excerpted from §60.7. While each item
is required, it is important to remember that the
key to the review and use of EERs is to obtain
quickly sufficient data to determine the adequacy of
a source's operation of its emission control system
and to try to motivate sources to minimize their
emissions and to remain in compliance.
(a) The source should submit EERs as follows:]Y
(1) Within 30 days after the end of each
calendar quarter, submit a written report
of: (a) excess emissions (as defined in the
applicable Subpart); and (b) monitor system
performance.
(b) An EER is required every quarter, even if
no excess emissions were recorded or if the
GEMS had no downtime, and was not repaired
or modified.
l_/"source" includes NSPS Subpart Da units which must submit
opacity monitoring EERs
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(c) Each EER shall include:
(1) The magnitude (averaged during the excess
period, including any conversion factor(s)
used), date, start and ending times,
nature, cause and corrective action
taken for each excess emission; specific
identification of each period of excess
that occurred during startups, shutdowns
and malfunctions of the affected facility;
the nature and cause (if known) of the
malfunctions and corrective actions taken.
(2) The date, start and ending times of each
instance when the GEMS was inoperative
(except for zero and span checks, etc.),
and description of the nature, cause
and corrective action taken for each
such period.
(3) The number of days in a quarter (or
percent of time) when the process was
operating versus percent of time when the
GEMS was operating and percent of
time GEMS was not operating ((2) above) 2/
2) Summarize the Emission and Monitor Performance Data
Before the EER data can be entered into the GEMS
Subset and effectively used, the data must be in a
categorized and summarized form. To the extent that
the EER data are not categorized and summarized by
the sources in a manner consistent with the
definitions, as shown in items 4 and 5 of Appendix 1
(e.g., startup, shutdown, process problems, monitors
and non-monitor equipment problems), the agency
reviewer must summarize the data manually. The
four key parameters which must be summarized by
reason code, are:
(a) total number of exceedance incidents;
(b) total duration of time that the standard
was exceeded;
(c) total number of GEMS downtime incidents; and
(d) total duration of each CEMS's downtimes.
2/ Note: This item is only implicitly specified in §60.7.
However, it is essential for agencies to know the quantity
of GEMS downtime while the process was operating in order
to determine the adequacy of the source's GEMS performance
and the representability of the excess emission data
reported in the EER.
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Suggested reason codes and their definitions
are presented in Sections VI and VII of Appendix 2.
It should be noted, however, that these definitions
are not official and are still being considered by
EPA as part of a possible regulatory revision
intended to obtain standardized summaries directly
from the sources.
It is recognized that agency summarization of the EER data
is the most resource intensive element of the Phase 1 analysis.
However, it's completion is critical to the effective use of EERs.
B) Phase 2 - Verification of Phase 1 Results, Targeting
of Sources and Data Entry into the Subset
The Phase 2 EER activities should be performed by an
experienced compliance person. To date, agencies have relied
upon a professional who was familiar with reviewing, other
compliance data. This part of the EER assessment is more
complex than Phase 1 in that it involves: 1) completion of an
internal check and concurrence with the Phase 1 results;
2) comparison of the EER data with agency targeting criteria
(for example, see Section IV), and in some instances includes
recommendations for additional agency evaluation of
source-related data; and 3) supervision of EER data entry into
the GEMS Subset of the CDS. Completion of these activities
should be documented in items 6 and 7 of Appendix 1, for
example, during Phase 2. Current experience indicates that
these activities can be completed within about one hour. The
following paragraphs delineate additional details about Phase 2.
1) Verification and Concurrence with phase 1 Results
The Phase 2 reviewer should check the data analysis and
summarization completed during Phase 1 in sufficient detail to
permit the reviewer to concur with the results. It is expected
that spot-checking of the Phase 1 results will usually suffice.
2) Comparison of EER Data with Targeting Criteria and
Possible Recommendation of Additional Agency Evaluation
of Source Data
Once the Phase 1 EER summary results have been concurred
with, they should be compared to the agency's targeting
criteria (see sample list of criteria and follow-up actions
in Section IV). For instance, if the source reported exceeding
the opacity standard for 2-5% of its operating time during
the quarter, the agency might target it for a follow-up action,
such as sending the source a letter requiring it to reduce
its excesses by the next quarter. A second example is shown
in Figure 2. There one can see that the relatively poor
emission performance of three sources virtually "leaps off
the page" compared to others in the same State. These three
sources should be targeted for agency follow-up action.
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f
One would expect that the EER review process would
initially find most source's EER data indicating compliance,
and therefore not causing the source to be targeted. However,
as a "quality assurance" check on the agency's EER review
procedures, and to verify the data, to the extent that resources
permit, the agency should randomly target a few of these
apparently complying sources for follow-up action.
3) Enter the Summarized Data.and Notification to the
Source
At least once a quarter, and more frequently if appro-
priate, each set of summarized data should be entered into
the GEMS Subset of the CDS. Furthermore, it is essential to
provide the source with a timely notification of the results
of the agency's EER review (both positive and negative). This
will help to promote better emission control and monitoring
of operations by the source because they will be aware that
the data are being scrutinized and will not want their EERs
to trigger an agency follow-up activity such as an inspection
or stack test. Furthermore, providing the results to the
sources will improve the credibility of the EER process with
the source.
C) Phase 3 - Conduct Agency Follow-up Activities
\ The Phase 3 analysis and follow-up will likely be per-
formed on a relatively small fraction of an agency's sources,
and is in general more comprehensive and more sophisticated
than the activities performed in Phases 1 and 2. Once a
specific source has been targeted as a possible violator
(during Phase 2), the agency should proceed as it normally
would whenever it has reason to believe that a source may be
out of compliance. As with any conventional follow-up activity,
phase 3 may be performed in the office or in the field. It
may include activities such as comparison of the EER results
with other available data (e.g., malfunction and inspection
reports, stack test results, and EER data), and compliance
activities which result in the acquisition of new data.
Furthermore, a Phase 3 assessment may result in a recommendation
for initiation of an enforcement action. Therefore, it is
suggested that a professional on the agency's compliance
staff perform these activities.
The Phase 3 activities may result in one of the following:
0 a determination that an "apparently complying"
source, based upon conventional surveillance/
compliance monitoring data, was actually in
violation of one or more regulations; or
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V ° a determination that a source appearing to be a
violator, based upon CEMS/EER data, was actually
in compliance.
Regardless of the outcome, the agency's confidence in its
compliance data for that source will be measurably enhanced.
IV. Example Targeting Criteria and Recommended Agency
Follow-up Actions
The following example criteria and follow-up actions are
based on a limited amount of Regional Office experience,
mostly with EERs from large boilers. They are intentionally
non-specific in order to provide a framework or "starting
point" for each Regional Office to formulate its own criteria
and recommended follow-up actions (in consultation with its
States, as appropriate) specifically suited to its unique set
of circumstances. It is suggested that an agency consider,
among other parameters, the following things when developing
its criteria for targeting sources for follow-up actions:
0 staff size and expertise relative to the size and
complexity of its responsibilities;
0 availability of external resources (cooperating
agencies, contractor assistance);
v
0 current level and quality of agency knowledge of
its source's emissions, control systems, processes,
fuel alternatives, etc.;
0 compliance and malfunction history of its sources;
0 relative priority of the sources and the pollutants
to be addressed by criteria; and
0 technical and regulatory tools, limitations, etc.
available to the agency.
Furthermore, it is appropriate for each agency to review
its criteria and follow-up plans annually and to revise them,
as necessary. By the end of FY 1985, EPA intends to review
agency experience with EERs and this guidance, and to provide
additional details and examples of criteria in an "EER Users
Handbook".
A) General Comments on the Example Criteria
The following additional comments are relevant to under-
standing and using the example "Criteria for Action" and
"Recommended Follow-up Actions" provided on the following
pages.
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Of the three types of examples provided (i.e.,
Emission Performance, GEMS Performance and
Administrative Problems), "Emissions Performance"
is clearly the most important. However, the urgency
and severity of follow-up to GEMS or administrative
problems should be controlled by the degree to
which the GEMS or EER deficiency itself inhibites
interpretation and use of the data relating to
emission exceedances. For example, major gaps in
data, or gaps in data from a problem source, would
warrant the strongest enforcement response. On the
other hand, format problems presenting only a minor
inconvenience to the reviewer would warrant a less
stringent response.
It is recommended that each agency begin its EER
program with fairly simple, quantitative criteria
and simple qualitative follow-up action recommen-
dations. Later, as experience dictates, each
agency might choose to establish more sophisticated
and qualitative criteria.
Whenever a detailed review of exceedances occurs,
a similar review of GEMS downtime should also be
performed. Check next quarter (whether or not the
threshold point is reached) to determine whether
similar problems recurred and whether the source's
previous corrective action was acceptable.
Emission and monitoring criteria for gaseous
emissions, comparable to the opacity examples,
should be developed by each agency. There are
probably enough data currently available for
agencies to develop such criteria.
The example criteria provided are not intended to
suggest that an agency's criteria should or could
all be precisely definable (e.g., 2% monitor down-
time). The criteria provided were for illustrative
purposes. For instance, perhaps a source's normal
emission and monitor performance should also be
taken into account in the criteria.
Because this document is primarily based on agency
experience with large power boilers, EER data from
other types of sources should be analyzed sufficiently
in order to determine appropriate targeting criteria.
An annual review of these criteria should be conducted
to assess the need for modifications.
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The operating experience of opacity and SC>2
monitoring systems should be reviewed annually to
determine whether different action threshold points
are justified.
Approximately a year of operating experience with
NOx and TRS monitoring systems (high quality
historical data is acceptable) should be evaluated
when determining specific threshold points for
these GEMS.
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Example Criteria and Recommended Follow-Up Actions
(Opacity Emission Performance Problems)
Criteria for Action*
Recommended Follow-Up Actions
Emissions below both high and
low threshold points.
Conduct a random "quality assurance"
review of some EERs for exceedances
each quarter.
In the first quarter after
problem was noted, emissions were
below the low threshold point.
Check next quarter to determine
whether or not similar problems
have recurred and if corrective
action was acceptable.
(a) Total duration of exceedances
exceeds the low threshold point
selected by the agency for the
source or source category (two
percent of the total source
operating and monitored time, and
certain other factors, have been
used successfully by Region V for
certain power plants).
(b) Total duration is less than
the agency's low threshold point,
but there is a significant increase
in the number or duration of
exceedances.
(c) Detailed examination of the EER
discloses unacceptable types of
exceedances or reasons for exceedances.
(a), (b), (c). Initiate the lowest
level of agency action (e.g., a
more thorough analysis of the EER
by an engineer). This may result in
a warning by telephone or letter
being sent to the source relating to
its excess emissions.
- Continued on next page -
*These were placed in a "relatively" ascending order of
severity/importance
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Example Criteria and Recommended Follow-Up Actions
(Opacity Emission Performance Problems) - Continued
Criteria for Action*
Recommended Follow-Up Actions
(a) Total duration** exceeds a high
threshold point (five percent of
the total source operating and
monitored time and certain other
factors, have been used
successfully by Region V for
certain power plants).
(b) Total duration is less than
this high threshold point, but
there has been a significant
increase in the number or
duration of exceedances.
(a),(b) Initiate a moderate level of
agency action (e.g., a more thorough
analysis of the EER and other com-
pliance information by an engineer/
technician and compliance staff).
This may result in additional surveil-
lance activity or.a conference with
the source. An immediate inquiry into
specific exceedances should be
conducted.
Recurrence of same or similar
problems from prior reporting
periods.
Proceed with more rigorous follow-up
action. This should also depend on
the severity of excess emissions
and other relevant targeting factors
(e.g., size, compliance history)
*These were placed in a "relatively" ascending order of
severity/importance
r*Summary data from EERs or reviewer's checklist (see Appendix 1)
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Example Criteria and Recommended Follow-Up Actions
Opacity and SO?
(GEMS Performance Problems)
Criteria for Action *
Recommended Follow-Up Actions
"Random" EER follow-up review done
on EER (e.g., when GEMS downtime
does not exceed the high or low
threshold points) to determine
whether there was questionable
GEMS "downtime".
Regardless of results, the source
should at least be notified that a
follow-up review was performed.
Perhaps a telephone report would
suffice unless a major problem was
identified.
GEMS downtime exceeds the low
threshold ("W"-opacity or "X"-SO2
percent) point.
The specific reasons should be
examined and if it is determined
that such performance is unacceptable,
the source should be directed to take
corrective action. The source should
be notified (by telephone should
suffice) of the follow-up review
regardless of the results.
GEMS is out of service for more Similar to above, but a written
than the high threshold ("Y"-opacity report would be appropriate.
or "Z"-SC>2) percent of the total
operating time of the source during
any given quarter.
Excessive GEMS downtime reported
for a second quarter; or
exceedance "caused" by GEMS
Conduct an inspection and/or require
the source to repeat its demonstration
of achievement of the GEMS performance
specifications.
Continuing problems with GEMS
for at least three quarters
Proceed with more rigorous follow-up
action. The urgency and severity of
enforcement would be controlled in
part by the degree to which GEMS
problems interfere with effective
source surveillance. Other targeting
factors, particularly excess emission
performance should also be considered.
'These have been placed in a "relatively" ascending order of
severity/importance
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Example Criteria and Recommended Follow-Up Actions
(Administrative Problems With EERs)
Criteria for Action*
Recommended Follow-Up Actions
EER contains one or more
reporting deficiencies
In every case, call or send a written
critique of the EER relative to EER
requirements. Require corrective
action by next quarter.
EER not received by 45 days
after quarter ends
In every case, call or write the source
requiring EER submittal within 15 days.
EER contains the same or
similar deficiencies for a
second t ime
Telephone follow-up, confirmed by letter,
stating deficiencies and requiring
corrective action in the next quarterly
report.
EER contains the same or
similar deficiencies a third
time
Proceed with more rigorous follow-up than
the previous time (depending in part on
degree these problems impede agency's
ability to conduct source surveillance) .
*These have been placed in a "relatively" ascending order of
severity/importance
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V. Entry of EER Data into the GEMS Subset of CDS
Keeping the agency's data base current is very important.
Particular emphasis is required with respect to the GEMS -
related data. Keeping the data system current will not only
help a specific agency to manage its resources and keep its
sources in compliance, but will also add significantly to the
rather limited data base available to other agencies. This
data will provide very important support for activities such
as establishing criteria for targeting sources, deciding
against whom/when to take enforcement actions, etc. In
addition, what is recorded by the end of a quarter will
represent the agency's baseline for implementing the program
in the next quarter. Lastly, the historic record created by
several quarters of data is useful for time-series and trend
analyses (e.g., how much SC>2 is emitted from specific sources
and during specific atmospheric conditions) .
Information concerning specific data requirements and
entry procedures are presented in the GEMS Subset Users Guide.
In addition, training opportunities concerning use of the
Subset are available.
VI. Review of CEMS Data Quality and Source Compliance with
All GEMS Requirements
As discussed in Section I of this guidance, it is recom-
mended that an agency begin implementing its CEMS/EER program
by primarily concentrating on: (a) inventory development;
(b) determination of source compliance with CEMS installation
and operating requirements; and (c) review of EERs and follow-ups
The activities addressed in this guidance were purposefully
ordered in a manner consistent with that recommendation.
Therefore, the activities which chronologically may occur at
a source between the initial operation of the CEMS and source
submission of EERs (e.g., performance specification test)
have yet to be addressed. This Section addresses those items.
Whenever the agency chooses to evaluate the data quality
and a source's general CEMS compliance, experience indicates
that this can be accomplished most effectively by determining
each source's compliance with all of the CEMS requirements,
rather than through sequential assessment of the compliance
of a number of sources with a single CEMS provision. Thus,
by reviewing a complete set of data from a single source
(e.g., inspection and performance test reports, EERs), it is
easier to develop a more complete picture of the quality of a
source's emission and monitoring performance, as well as to
detect any inconsistencies within the data.
-------
- 17 -
The agency should document (see Appendix 3 for an example
checklist) each source's general compliance with the following
applicable GEMS requirements, summarized below for NSPS sources
(similar requirements may exist for SIP and PSD sources):
A). The source shall install 3_/ and operate a GEMS
prior to conducting the initial performance test -
§60.13(b),
(1) Note - although some coal-fired, non-FGD,
Subpart D - sources have not installed SC>2
.GEMS while they await EPA's resolution of the
"reserved" §60.45(d) paragraph, these sources
have always been required to implement the
opacity and NOx GEMS requirements contained
in §60.13(b).
B). The source shall locate the GEMS such that the
measurements are representative of emissions -
S60.13(f) .
C). The source, after giving the agency at least
30 days notice, shall demonstrate achievement of
the performance specifications through a perfor-
mance specifications test (PST) - §60.13(c).
(1) A PST (for a GEMS of the same pollutant) is
required during, or within 30 days after
each performance test required under §60.8.
If a source performance test was done without
obtaining concurrent GEMS data, the test
should be repeated, preferably concurrently
with the PST.
(2) Note an initial PST is required for all
GEMS, even those for which contracts were
signed before September 11, 1974 - §60 .13(c)(3) .
(3) The source is required to submit the results
(demonstrating achievement of the performance
specifications) of such tests to the agency
within 60 days after completion of the PST.
D). The source shall perform quality assurance checks
specified by the Administrator, such as at least
daily zero and span drift checks and the adjustments
contained in §60.13(d).
V See Appendix 4 for a list of CEMS-affected NSPS source
categories and their specific GEMS requirements.
-------
- 18 -
E). The source shall demonstrate that except for moni-
toring system breakdowns, calibrations, etc., the
GEMS are capable of continuous operation and can
meet minimum cycle times as follows:
(1) Opacity GEMS - sample and analyze opacity once
in each successive 10-second period - §60.13(e)(l)
(2) NOx» SC>2, C02 and ©2 GEMS - sample, analyze and
record the parameters, once in each successive
15-minute period - §60 .13(e)(2).
F). The source shall perform data reduction as follows:
(1) Opacity GEMS - reduction of all data to 6-minute
averages (based on at least 36 equally spaced
data points per 6 minutes) - §60.13(h).
(2) Gas GEMS - reduction of all data to 1-hour
averages (based on at least 4 equally spaced
data points per hour) - §60.13(h).
G) . The source shall maintain (for at least two years)
copies of all GEMS performance evaluation and
quality assurance/control data, emission data,
performance test data, GEMS and control system
maintenance records, etc. - §60.7(b) and (d).
H) . The source shall submit quarterly EERs to EPA and
(if delegated) to the State agency - (§60.4(b)).
Please refer to 40CFR Part 60 for the specific language
on each of these requirements.
VII. Contacts for Future Technical Assistance, Comments, and
Additional Copies of the Guidance
As agencies implement their CEMS/EER program, EPA antici-
pates that there may be a continuing need for technical
assistance in implementing the guidance, answering technical
questions, and receiving comments and suggestions. Additional
copies of the guidance may also be needed.
Please direct these technical questions and requests to
Louis Paley at (202) 382-2835; or for CDS related items, please
contact Howard Wright at (202) 382-2826; or write to either
Mr. Paley or Mr. Wright at -
U.S. EPA
Stationary Source Compliance Division (EN-341)
401 M Street, S.W.
Washington, D.C. 20460
-------
CONTINUING CEMS
PROGRAM IMHEMENTATIO* '
CE
EHT
- PHASE 1 -
EER REVIEWED
AND SUMMARIZED
- PHASE: -
i VERIFY PHASE I
> TARGET SOURCES
> DATA ENTRY TO SUKET
FOLLOW-UP REQUIRED?
- PHASE 3 -
CONDUCT FOLLOW-UP
EVALUATIONS AT
TARGETED SOURCES
FIGURE 1. ASENCY-S REVIEW AND USE OF CEMS DATA
-------
DURATION OF EXCEEDANCES
(PERCENT OF TIME)
C/3
3"
O ^
C M-
a c
(D
to
QJ I
id ra
(t) X
rf (u
3
a-o
O
(D
o
l-h
H- O
i . ^~
O *1
« o
I (D
C CO
O
O M-
rt n
H- zr
O
3
-------
APPENDIX A - 1
-------
Sample Form
10/3/84
EER REVIEWER'S CHECKLIST
(40 C.F.R. Part 60, Subpart D)
Phase 1 Review
Phase 2 Review/
Subset Data Entry
Phase 3 Review/
CDS Action Entry
APPENDIX A-l
Name
Date
Name
Date
Name
Date
1. Company
Plant/Unit
Quarter
Year
2. Timeliness (Must be postmarked within 30 days of quarter)
(a) Date Postmarked (b) Days Late
3. Completeness (For EERs which cover multiple monitors, specify monitor when noting problem.)
Excess Emissions (EEs) Information
(a) Data Reported in Units of
Applicable Standards
(b) Date and Time of Commencement
(c) Date and Time of Completion
(d) Magnitude
(e) Conversion Factors Used
(f) Identification of EEs Caused by
Start-up, Shutdown, or Malfunction
(g) Mature and Cause of Malfunction
(h) Malfunction Corrective Action
or Preventive Measures
(i) Affirmative Statement of No EEs
CEMS Performance Information
(a) Date and Time Identifying
Specific Periods During Which
CEM5 Was Inoperative
(b) Nature of System Repairs
or Adjustments
(c) Affirmative Statement of No Period
of Downtime, Repair or Adjustment
(include no CEMS modifications)
Source Operating Time
No Problem
Problem (Describe)
!
A revision of reporting retirements to require a summarization of data, categorization of excess
emissions and CEMS problems according to new uniform categories, and reporting of source operating time is
cow under consideration. Although not specifically recniired, source operating time has been included on
this sample form because it is necessary to allow for data analysis included in this checklist.
-------
Data Summary for Opacity EESs
APPENDIX l(Cont.)
(a) Opacity CEMS Performance
Causes of CEOS Downtime*
Monitor Equipment Malfunctions
Non-monitor CEMS Equipment Malfunctions
(e.g., computer, data recorder, etc.)
Calibration/QA
Other Known Causes
Unknown Causes
Total
Number of
Incidents
Total
Downtime (Hours)
Percent ,
Unavailability
%
%
%
%
%
%
"Percent unavailability" is calculated by the following formulas:
CEMS Downtime During Source
Operating Time (Hours)
Source Operating
Time (Hours)
x 100
Percent
Unavailability
Where:
Time in
Quarter (Hours)
Source Down-
time (Hours)
Source
Operating Time (Hours)
(b) Opacity Emissions Performance (Data Reported as Consecutive 6-ainute Periods; Calculate Duration in
Hours to Nearest Tenth)
Causes of Excess Emissions*
Process Start-up/Shutdown
Sootb lowing
Control Equipment Failures
Process Problems
Fuel Problems
Other Known Problems
Unknown Causes
Total
Number of
Incidents
Total
Duration (Hours)
Percent of Operating
Time (Normalized) ~
%
%
%
%
%
%
%
%
"Percent of Operating Time (Normalized)" is calculated by dividing Total Duration by the following
Normalization Factor, then multiplying the result by 100.
Time in
Quarter
(Hours)
Source
Downtime
(Hours)
CEMS Downtime
During Source
Operating Time
(Hours)
Normalization
Factor
t Assume all reported CEMS downtime occurs during periods of source operation unless explicitly stated.
* Proposed definitions for these categories appear in "Technical Guidance on Agency Review of Excess
Emission Reports and Follow-up Actions," Appendix 3.
-------
APPENDIX 1 (Cont.)
5. Data Summary for SO, or NO.. EERs (Use Separate Forms for Each Monitor)
Type of Pollutant
(a) CDS Performance (Includes Aggregate Downtime for Pollutant and Diluent Monitors)
Causes of CEMS Downtime*
Monitor Equipment Malfunctions
Non-monitor CSMS Equipment Malfunctions
(e.g., computer, data recorder, etc.)
Calibration/QA
Other Known Causes
Unknown Causes
Total
Number of
Incidents
Total
Downtime (Hours)
Percent ,
Unavailability''
%
%
%
%
%
%
"Percent unavailability" Is calculated by the following formulas:
CEMS Downtime During Source
Operating Time (Hours)
Source Operating
Time (Hours)
x 100 _
Percent
Unavailability
Where:
Time in
Quarter (Hours)
Source Down-
time (Hours)
Source
Operating Time (Hours)
(b) EMISSIONS PERFORMANCE (Data Reported as Consecutive 3-Hour Periods)
Causes of Excess Emissions*
Control Equipment Failures
Process Problems
Fuel Problems
Other Known Problems
Unknown Causes
Total
Number of
Incidents
Total
Duration (Hours)
Percent of Operating
Time (Normalized) "
%
%
%
%
%
%
"Percent of Operating Time (Normalized)" is calculated by dividing Total Duration by the following
normalization factor, then multiplying the result by 100.
Time in
Quarter
(Hours)
Source
Downtime
(Hours)
CEMS Downtime
During Source
Operating Time
(Hours)
Normalization
Factor
Assume all reported CEMS downtime occurs during periods of source operation unless explicitly stated.
* Proposed definitions for these categories appear in "Technical Guidance on Agency Review of Excess
Emission Reports and Follow-up Actions," Appendix 3.
-------
APPENDIX 1 (Cont.)
6. ZER Data Summary and CDS/CEH Data Coding ChecXed;
[Also sign second line, page 1 of ChecKlist.)
(Hale) (Date)
7. Should this EER be Revleved for Possible Agency Follow-up? (Compare EER data with criteria for follow-up.)
Yes/No:
Comments:
(Indicate type o£ monitor(s) and problemts), applicable follow-up criteria and possible follow-up.)
8. Recommendations for Follow-up Activity Based on Detailed Review of EER and Other Compliance Information;
(Indicate recommended agency action with checK.(s) and/ or appropriate letter Is) and comments below.)
No Action
Target Source for Detailed
EER Review Next Quarter
Contact State
Defer to State
Contact Source
a. Telephone source
b. Meet with source
c. Request add. information
d. Request add. reporting
e. Request corrective action
f. Request add. testing
g. Request alt. monitoring
h. Request specific OSM/QA
procedures
1. Other (Specify)
Target for Additional
Surveillance
a. VEO
b. LIDAE
c. Inspection
d. Audit
e. Compliance test
f. Other (Specif?)
Enforcement
a. Warning Letter
b. § 113 MOV
c. § 113 Compliance Order
d. § 120 Notice of Nbacompliance
e. Initiate civil action
f. Other (Specify)
Emissions Problems
Opacity
SO,
NO/
CZMS Problems
Opacity
S07
N0x
Time-
liness
Complete-
ness
Comments:
9. Action Coded and Etatered in CDS;
(Also sign third line, page 1 of Checklist.)
(Name)
(Date)
-------
APPENDIX A -' 2
-------
APPENDIX A-2
Summary of Agency Survey of Recommendations for Revising
EER Requirements and for Using EERS
I. INTRODUCTION
The following recommendations are the result of a
study completed in March, 1984, which identified and evaluated
appropriate elements of an agency EER review and follow-up
program keyed to surveillance targeting. It included a survey
of existing Federal and State EER programs and the identification
and evaluation of major problems and constraints that inhibit the
effective implementation of those programs. It also included the
design of optional review procedures and a test review of selected
EERS in two States. Following this review, project participants
met with State and EPA regional representatives to discuss the
advantages and disadvantages of specific review options, and to
identify areas in which specific EPA guidance is needed.
Recommendations reflect a perceived need for certain EPA action
along with a determination that such action is feasible.
II. AN EER SUMMARY SHOULD BE REQUIRED
(A) Explanation
EPA should require that a one-page EER summary be
prepared by each source required to submit an EER
for EPA review. This summary should be prepared
according to a uniform format, applicable nationwide,
and steps should be taken to ensure consistency of
content. Until at least the source demonstrates
that it has a high-quality emission control and GEM
program, the summary should be submitted in addition
to, and not in lieu of, the "traditional" report
of the individual exceedances and other reportable
incidents. In the cases where only summary reports
are subsequently required, the agency should
periodically audit the source's complete EER.
(B) Major Considerations
o It will facilitate a quarterly review of EERS by
Agency Staff. An EER summary will facilitate EER
review by substantially shortening the amount of
time necessary to screen the EER for a determina-
tion of the need for follow-up. This is
especially useful for an agency which may have a
legitimate shortage of staff time to commit to EER
review, and which is reviewing a substantial volume
of EERs reporting a substantial number of exceedances
or monitor problems.
-------
- 2 -
o It will facilitate a comparative analysis of EER
data. An EER summary should provide an effective
basis for tracking the overall performance of a
source from quarter-to-quarter and identifying both
gradual and extraordinary changes in emissions over
time. This tracking might be performed for every
source submitting EERs or only for certain sources
that have been targeted for more intensive
surveillance.
o It will not result in a significant new burden on
sources currently filing EERs that comply with
NSPS requirements. It is believed that preparation
of a summary will impose only a negligible burden
on most sources with computer analysis capability,
since in most cases only a minor modification
in software will be required. The costs will
be more significant in cases where the software
is permanently installed or "hard-wired". In
instances where excess emissions data is tablulated,
analyzed and reported manually, summarization
should still require only a minor additional
effort compared to the total time spent in EER
preparation.
o It should help some sources use the data for
compliance management purposes. A summary should
{ also provide the environmental control manager at
sources who are not currently tracking EER trends
a convenient tracking mechanism for internal control
purposes.
o Submission of the summary without the underlying
report. Some agency spokespersons have indicated a
preference toward receiving just the summary, then
requesting the underlying EER only if needed. The
recommended approach is to receive the entire
(current) EER for some minimum period, then,
the agency might reduce the reporting requirement
for sources with clearly excellent records,
subject to periodic EER audits.
o The preferred mechanism for establishing this
requirement is through an amendment to the reporting
requirements in 40 C.F.R. § 60.7. This approach is
preferred over all alternative mechanisms (e.g., the
use of individual § 114 letters or the SEA process),
by agency and source personnel alike. The
consistency and formality of rulemaking provides
significant support to the requirement and reduces
the probability of, or reticence on the part of,
agency and industry personnel to make the change.
v
-------
o The recommended summary will require changes in how
the underlying report is prepared at most facilities.
There are basic differences in EER content from
State to State, and from source to source in many of
the States. No survey was conducted to determine
the precise nature of the impact of these changes on
specific sources. State representatives generally
agreed, however, that the impact would be minor and
not unexpected. As indicated by agency staff in
Minnesota and Colorado, most sources are accus-
tomed to receiving agency requests for information
according to formats that periodically change -
this has become an ordinary aspect of doing
business with the government. Although some
objection is encountered, there are usually no
serious confrontations where, as in the current
situation, the reasons for the change are logical
and not perceived to be artitrary, and the net
effect is to create a more efficient, uniform and
stable reporting program.
III. THE EER SUMMARY SHOULD INCLUDE THE TOTAL NUMBER OF EXCESS
EMISSION INCIDENTS AND THE TOTAL DURATION OF ALL EXCESS
EMISSIONS
(A) Explanation
The number of incidents should include each continuous
time period in .which an excess emission occurs, and
the total duration should include the sum of the time
periods associated with all incidents. Periods during
which a permissible exception may apply should be
reported as any other excess emission.
(B) Major Considerations
o Among available options, this appears to be the
most useful and efficient. Other summary options
are either not as effective in terms of providing
a useful targeting aid or add a level of complexity
without a corresponding benefit. These options
include:
Incidents only. This approach is not as useful
because the number of incidents alone will not
always provide a fair indication of the magnitude
of control problems at the facility; incidents
may be expected to vary in duration.
-------
- 4 -
-- Incidents and duration. This is the recommended
approach. The number of incidents will allow for
quick evaluation of the frequency of excess
emission problems at a facility; and the total
duration will allow for a quick evaluation of the
overall magnitude of the problems. Incidents are
defined in terms of a continuous period of an
excess emission because NSPS regulations require
reporting on this basis. This does not account
for the possibility that a single control problem
will be summarized as several incidents (if the
problem results in intermittent exceedances);
however, the extent of any specific control problem
may be further ascertained by reviewing the
underlying report. As such, consideration of the
number of incidents will still be effective as a
screening aid, since any bias that is introduced
will usually exaggerate the number of incidents
and therefore not tend to restrict .further inquiry
into the underlying report.
Incidents and duration qualified by the severity
of the exceedance. This approach takes into
account the extent to which each reported
exceedance actually exceeds the applicable standard
and therefore provides a truer indication of the
actual pollution associated with excess emissions
during the quarter. However, as a screening
mechanism it provides no significant benefit
beyond screening simply on the basis of the number
of incidents and the total duration of excess
emissions. The simpler screening approach contains
an assumption that all exceedances are significant;
this can be verified, if necessary, by reviewing
the underlying report.
o Current summary and analysis techniques do not
usually track the frequency of excess emission
incidents. Most, like EPA's GEM Subset of the
CDS, look only at duration. Thus, a new review
criterion will be introduced. It is believed
that this is justified to ensure that sources with
numerous short-term exceedances are not overlooked
when targeting for EER follow-up.
-------
- 5 -
o Periods during which an exception applies should
not be excluded. The purpose of the summary is to
aid in screening for further review and follow-up.
For this reason no excess emission should be
omitted on the basis of an independent source
determination that it is excusable.
IV. THE EER SUMMARY SHOULD INCLUDE INFORMATION ALLOWING FOR
APPROPRIATE NORMALIZATION OF REPORTED DATA
(A) Explanation
This information should be sufficient for agency
staff to determine the total source operating time,
the total CEMS operating time, and the precise
degree of overlap (source operating time when the
monitor is down and the monitor operating time
when the source is down).
(B) Major Considerations
o A source with relatively few exceedances will not
be overlooked for further evaluation, if emission
data has not been obtained for a significant portion
of the quarter. This will allow for the simplest
( meaningful determination of whether reported
exceedances are significant in terms of the total
source and monitoring operating time.
o What if £he monitor is up but malfunctioning?
Clearly this would affect the usability of the
data in many circumstances. It is recommended
where the facility feels that CEM performance has
affected the quality of exceedance data that this
be clearly indicated in the summary.
o A problem exists in the interpretation of opacity
data that has been gathered during source downtime.
Many agencies require that sources continue to
record and report opacity data during a source
outage. Sometimes there are significant opacity
exceedances during these outages. It is recommended
that this data be summarized separately, so that
there is a consistent basis for comparison of
uptime data from source to source.
-------
- 6 -
Further normalization is not considered warranted.
It is possible to normalize the data further to
account for production factors (e.g., megawatts
produced during the reporting time period),
control equipment performance parameters, and an
ever-increasing level of detailed information that
ultimately zeros in on the actual volume of
particulate emissions represented by the recorded
opacity, and a calculation of the severity of
excess emissions during the quarter. It is felt
that this additional level of detail is not
warranted for the purpose of conducting a simple
screening program. Individual agencies may
want to require additional summarization to suit
their own targeting needs.
V. THE EER SUMMARY SHOULD INCLUDE A BREAKDOWN BY POLLUTANT OF
EXCESS EMISSION INCIDENTS AND DURATION WITHIN .CERTAIN
REASON CATEGORIES
(A) Explanation
Recommended categories include start-up/shutdown,
soot-blowing, control equipment failure, process
problems, fuel problems, other known causes (see
definitions below), and unknown causes. The same
format could be used for all EER pollutants:
opacity, 803, NOX, and TRS.
(B) Major Considerations
o A simple breakdown into general categories will
allow for a more effective evaluation of the
general types of problems experienced during a
quarter at a particular facility. For example,
excessive exceedances attributed to start-up
and shutdown at a facility may require no
further review of specific incidents noted in
the underlying EER, and satisfactory follow-up
may be limited to some form of off-site contact.
Excessive exceedances attributed to equipment
failure, on the other hand, may justify a more
thorough review of the specific incidents and
may ultimately warrant a site visit.
-------
- 7 -
The selected categories reflect the most common
groups of reasons given for excess emissions.
More precise groupings are possible, and are even
preferred by many agencies (additional categories
usually describe equipment and operator failures
in greater detail and often include other
categories designed to define excusable exceedances,
e.g., excusable malfunctions and maintenance).
For purposes of this guidance, however, it is
recommended that a very simple selection be
adopted as a minimum; then, if specific agencies
want to require further summarization, they may do
so independently.
The recommended categories change and expand those
currently summarized in the Subset. The "other known
causes" category is needed to ensure that all excess
emissions are included in the summary. The "fuel
problems" category is needed for SC>2 emissions,
since it is the most common reason for SO2
exceedances. "Equipment failure" has been redefined
as "control equipment failure" to allow for ease in
distinquishing "process problems," which should be
added as a new category. Adding these categories
may inhibit the comparison of new summary data to
old summary data in many instances (it is not clear
how extensive this inhibition will be); however,
this seems justified to ensure that future
comparisons will be based on all of the data and will
include the basic reasons for exceedances. At some
future time EPA may wish.to reevaluate the summary
categories for specific pollutants or source
categories and make changes that are appropriate in
view of the actual experience.
Potential inaccuracies due to source summarization.
Some concern has been expressed that summary
categories are not meaningful because either source
operators do not really know the reason for an
exceedance and simply put down what seems to be a
convenient explanation or they cannot make the
known reason fit into one of the available
categories. Neither concern seems to be a valid
reason for foregoing the proposed summarization.
First, the small number and very general nature of
the proposed reason categories should make the
selection easier this may also be improved by
adopting a uniform definition of each reason (the
-------
- 8 -
recommended reason categories are not considered to
be controversial). Second, an "unknown" category
is provided for persons who really do not know why
the exceedance occurred (it is a criminal offense
under S 114 of the Clean Air Act to intentionally
misrepresent such data). Although there is some
likelihood for error in categorization, such errors
should be discoverable through EER review and
corrected through simple follow-up.
o Sending an inappropriate signal to sources.
Concern has been expressed that categories
should be limited to NSPS exceptions and
possibly additional exceptions typical of those
included in most State regulations. Other
categories may have an adverse effect because
sources will key to those specific problems and
tend to ignore the importance of categories not
specifically mentioned. In response to this
concern, it is felt that categories should be
selected primarily for the purpose of
management assistance, and that a logical break-
down according to the most frequently reported
reasons will be most useful. Such a breakdown
should not result in an inappropriate signal to
sources, if the agency in fact conducts a
diligent review and follow-up program.
VI. THE REASON CATEGORIES SHOULD HAVE STANDARDIZED DEFINITIONS "
(A) Substantial confusion exists among agencies and
sources on the definition of reason categories.
This confusion may be corrected and should be
eliminated in future guidance. The following are
proposed definitions for each reason category:
o "Startup" as defined in 40 C.F.R. § 60.2 means
"the setting in operation of an affected
facility for any purpose." If certain excess
emissions during startup are caused by a control
equipment failure or a process problem, that
portion of the exceedance should be reported as
a control equipment failure or a process problem.
All other excess emissions during startup should
be reported under "startup/shutdown," even
through there may have been some additional
intervening cause.
-------
- 9 -
"Shutdown" as defined in 40 C.F.R. § 60.2 means
"the cessation of operation of an affected
facility for any purpose." It applies to the
process of shutting down and not to a period of
downtime after the completion of this process.
The same qualification for excess emissions due
to equipment failure during startup also applies
during shutdown.
"Sootblowing" refers to the periodic removal of
soot, slag and/or fly ash from the firebox walls
or the tubes of fuel-burning equipment by the use
of compressed air, steam or water. (Delaware Air
Pollution Regulation No. 1, § 2.)
"Control Equipment failure" means any on-site
control equipment failure. It does not include
fuel or conveying equipment, or boiler or other
industrial process equipment. It is .intended to
cover all failures whether or not they are
excusable or inexcusable as malfunctions under 40
C.F.R. § 60.2, and even though the underlying
reason for the failure is not known.
"Process Problems" are intended to cover on-site
equipment failures other than control equipment.
Operational problems (e.g., load change), would
also be covered. When distinguishing between
process and control equipment, any equipment
necessary for the process would be considered
process equipment, even though it may have a role
in emissions control (e.g., the I.D. fan).
"Fuel problems" are intended to cover any problem
relating to the quality of the fuel ultimately
burned at non-FGD facilities. Blending or cleaning
problems would also be characterized as "fuel
problems," as would the use of high sulfur fuel
because of an interruption in the supply of
complying fuel, or because of a supplier's error,
or an error in coal sampling and analysis results,
etc.
"Other known causes" are intended to cover all
known causes of excess emissions not already
covered. An example is excess emissions during
control equipment maintenance.
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- 10 -
"Unknown cause" is intended to apply to all
excess emissions for which the operator must
guess at the reason (even though his guess
might be a good one). It would not apply to
an equipment failure even though the reason
for failure is not known.
The issue relating to malfunctions. Currently
40 C.F.R. § 60.11(c) excuses a source for non-
compliance with opacity standards during
malfunctions; however, § 60.11(d) requires that
such a source must still comply with good air
pollution control practices to minimize emissions.
No specific summary category for malfunctions
has been selected; instead, all control equipment
and process problems will be included whether
or not they may be excusable. This should avoid
potential confusion due to differences in opinion
about what constitutes an excusable malfunction.
The net effect should be to provide EPA unre-
stricted information to help screen for potential
malfunction problems. Effective implementation
of § 60.11(d) in this regard will normally require
further review of the underlying report, and
ultimately, communication with the source.
VII. THE EER SUMMARY SHOULD ALSO INCLUDE SIMILAR INFORMATION
AND CATEGORIES FOR THE CEMS SYSTEM
(A) Explanation
Information would include the total number of
incidents during which the monitoring system is
out-of-service or malfunctioning, the total
duration of such incidents, information allowing
for appropriate normalization of reported data,
and a breakdown of this information according to
the following reason categories defined below:
monitor equipment malfunction; non-monitor
equipment malfunction; other known cause; and
unknown cause.
(B) Major Considerations
o All of the same considerations that apply to
summarization of exceedance data apply to
summarization of monitoring system data.
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- 11 -
(C) The following are proposed summary categories for
monitor performance data.
o "Monitor equipment malfunction" refers only to
the monitor equipment, and not to accessory
equipment such as the computer analyzer or the
strip chart recorder. "Malfunction" refers to
any period during which the monitor is not
operating or is producing inaccurate data,
except during periods of calibration, maintenance,
or other quality assurance activities.
o "Non-monitor equipment malfunction" refers to all
equipment other than the monitor equipment that
are necessary to transfer, analyze and record data
from the monitor equipment.
o "Quality assurance" refers to any period during
which the monitoring system is out-of-service for
the purpose of calibration, maintenance, or other
quality assurance related activities. Corrective
action immediately following a malfunction
(detected during the quality assurance evaluation),
however, should be classified under the appropriate
malfunction category.
o "Other known cause" is intended to cover all other
known reasons for monitoring downtime or
inaccuracy.
o "Unknown cause" is intended to cover circumstances
in which there is inaccurate or no data without an
apparent explanation. If a data recorder fails
and produces inaccurate data, and the reason for
failure is not known, this would be categorized
under "non-monitor equipment malfunction." However,
if data is clearly inaccurate, and a data recorder
failure is suspected but cannot be determined, it
should be classified as "unknown cause."
VIII. REVISION AND AGENCY RELIANCE ON THE CEM SUBSET OF CDS
(A) Explanation
Currently the Subset does not include the same break-
down of CEMS performance categories. This additional
analytical capability will be useful to EPA as it
enters a new phase of reliance on CEMS as a
continuous compliance targeting aid. This capability
would be substantially enhanced by also providing
sorting capability according to monitor brand.
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- 12 -
The minimum EER summary information described above
should be entered into CDS for all NSPS and any
other source required to submit EERs to EPA. EPA
should perform this task until it is taken over by
each State.
(B) Major Considerations
o The CEM Subset will provide a useful reference for
EPA. CDS provides a useful source of data for
defining compliance experience on a categorical
basis. As such, it should facilitate compliance
program planning at the federal level, by enabling
EPA to target sources, localities and States where
compliance problems are more extensive.
o The CEM Subset should be revised to include the
minimum summary information indicated in the
above recommendations. This would include a
summary of incident frequency, information
permitting normalization of data, and a revision
of reason categories for exceedances and CEMs
problems. In addition, data analysis functions and
screening according to pre-determined targeting
criteria should be added. These changes will
facilitate EPA use of the Subset for more
effective planning and targeting.
o This will require a new effort on the part of
most EPA Regional Offices, but the burden should
be relatively insignificant. The effort will be
largely subsumed by the more general task of
establishing and conducting a new EER review
program; data review and analysis for the latter
objective should also accomplish the former.
Resources can be saved by delegating the job to
a para-professional. Moreover, the existence of an
EER summary should make the effort substantially
easier.
o In most Regional Offices and States the receipt of
summarized data will not result in an initial time
savings for EER review. Individual EERs will
usually be reviewed in any case; CDS will provide
an additional, rather than an alternative,
evaluation capability. However, this may change in
the future after the CEM Subset of the CDS is
programmed to allow for more sophisticated data
analysis, and as agencies begin to adopt targeting
practices that include the more sophisticated
analysis.
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- 13 -
o Many States will not use the system for
targeting. Many States that have highly
experienced inspectors with a long-term knowledge
of sources and a fairly simple targeting program,
are not interested in using CDS for EER
evaluations. However, source EER summarization
in a format convenient to CDS may resolve some
State concerns about the effort involved, as
well as the difficulty of ensuring the quality
of data analysis in independent local or State
regional offices. The Subset may also serve
as an effective check for the inspector and
should prove to be an efficient aid in the
transfer of institutional knowledge to new
inspectors.
IX. A UNIFORM REPORTING FORMAT SHOULD BE ESTABLISHED FOR NSPS
SOURCES
(A) Explanation
The format should be the same for all sources and
should be designed to ensure that EER summary elements
are clearly indicated on an incident-by-incident
basis. In addition, the uniform format should be
adaptable to requests for additional information from
specific agencies.
(B) Major Considerations
o A uniform format will promote consistency in
content since much of it is controlled by the
reporting format. Currently received formats
vary so significantly from source to source
and State to State that information from one
source's EER often cannot be compared to
information from another's. Although this
problem might be corrected by simply defining
more precisely the desired content, standardizing
the format will make it easier to ensure that
the content is the same. Content problems that
are duplicated among several sources can then be
addressed more efficiently, as can periodic
changes in format which may be appropriate.
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- 14 -
o A uniform format will facilitate review and
evaluation of EERs. Effective review for many
sources is currently stymied by significant
variations in format. Many formats make it
difficult to interpret much of the reported data
for individual sources; and the differences from
source to source make it difficult to conduct
comparative analysis of performance experience.
A uniform format will not only assist in solving
problems of EER interpretation, but should enable
the review to be simpler and more efficient.
o Most State reviewers prefer a uniform format.
This should facilitate State assumption of EER
review responsibility.
o The format must be flexible enough to allow for
agencies to obtain additional information. This
is very important since most EER requirements
vary to some degree from State to State, and
many occasionally acquire different types of
information for individual sources.
X. EPA SHOULD INITIATE A MINIMUM EER REVIEW PROGRAM IN THE
REGIONAL OFFICES
(A) Explanation
This program should include the quarterly review of all-
EERs required to be submitted to EPA. This would include
all NSPS EERs (whether or not the NSPS program has been
delegated to a specific State), and those PSD and SIP
EERs that are being filed in the Regional Office. The
minimum review program should include:
o A determination of timeliness.
o A determination of completeness.
o A review of the EER summary to determine whether the
source should be targeted for follow-up. This review
should be conducted according to a specific targeting
strategy prepared by the Regional Office. (See example
criteria in Recommendation No. XI.)
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- 15 -
o A more detailed evaluation of EERS targeted for
follow-up according to criteria established by the
Regional Office.
o A periodic audit of EERs to ensure that the summary
is accurate.
o Prior to the time that source-prepared summaries are
available, Regional Office personnel should prepare
their own summaries, ensuring to the extent possible
that the recommended summary information is obtained.
o A specific allocation of staff hours and
responsibility for EER review.
o A system of staff and management accountability for
EER review.
o A strategy to encourage State agency assumption of
an effective EER review program.
(B) Major Considerations
o Lack of an EER Review Program adversely affects EPA's
credibility among sources and may result in poorer
compliance efforts. A major source criticism of EPA's
GEMS program has been that it requires a source
investment in time and resources to install and
operate GEMS and report GEMS data, and that EERs are
not used at all by most agencies and rarely even
reviwed. In sum, there is a lack of credibility
involving GEMS directly associated with the absence of
EER review and follow-up. This affects both the
quality of EER data, as well as quality assurance
programs involving GEMS performance and the use of
GEMS for emission control at some sources.
An independent EPA EER Review Program will fill a
performance gap in State EER review. Many States
have indicated that they will not adopt EER review
and follow-up procedures unless EPA establishes and
commits to EER review guidelines. Others have
indicated informally that they will conduct no EER
review regardless of EPA's policy unless EPA provides
specific resources for the review. Still others are
committed to some limited level of review and would
undoubtedly benefit by EPA guidance and leadership.
Only a very few States have active, comprehensive
EER review programs. It is felt that the most
effective spur to State action will be an initial
comprehensive effort by EPA, followed by a more and
more selective effort as State agencies demonstrate
their ability to implement effective EER programs on
their own.
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- 16 -
XI. EACH REGIONAL OFFICE SHOULD ESTABLISH TARGETING CRITERIA
FOR EER FOLLOW-UP
(A) Explanation
Criteria for targeting and recommendations for
follow-up should vary according to the different
areas of review: (1) compliance with EER
requirements; (2) emissions performance; (3) CEMS
performance.
The urgency and severity of agency follow-up might
be partly controlled by the severity of the problem
documented in the EER. For instance, an incomplete
EER or CEM data might be considered significant if
the source had a history of poor emission control,
or if it previously submitted high quality reports
and high levels of CEM performance. Therefore, it
is recommended that each agency devise its own set
of criteria and recommended follow-up actions for
each of the three areas noted above. Example
criteria which might be useful when formulating an
agency's undividual one are included in Section IV
of the "Attachment."
(B) Major Considerations
EPA should not specify nationally applicable review
and follow-up criteria. Regional Office contacted
during this project want the freedom to develop
criteria to suit their own specific circumstances.
There is general agreement that the criteria should
vary among source categories and even subcategories
(especially with regard to specific cut points
justifying follow-up action). However, examples
should be useful to those Regional Offices and States
who currently have no organized approach to EER
review.
o Specifying a Review and follow-up protocol as a
part of general EPA guidance. Regional Offices
contacted during this project want the freedom
to develop criteria to suit their own specific
circumstances. However, this should not restrict
the development and presentation of example
criteria. An example should be useful to those
Regional Offices and States who currently have no
organized approach to EER review.
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- 17 -
Should there be a protocol at all? Concern has
been raised that development of specific criteria
for review and follow-up will have an overall
negative effect. It has been pointed out that
mere preparation of a protocol does not ensure
that it will be implemented, and that it may be
too confining and either restrict the Region's
flexibility in an inappropriate way or be ignored.
It has also been argued that establishing targeting
criteria changes the underlying standard and will
result in relaxed compliance efforts; and even
though EPA may try to keep the protocol secret, it
will inevitably become public, since efforts must
be made to encourage State adoption of similar
procedures.
A follow-up program should not be delayed pending
institution of uniform format and summary
requirements. Although current EER content and
format problems will restrict the extent to which
agencies are able to develop effective and uniform
follow-up criteria, it should be possible to
proceed with some type of follow-up program based
on individual source reports. The follow-up effort
should be devoted to correcting deficiencies in
content, and follow-up criteria should not require
major changes in content or format. Major changes
should be required only once, in a single nationwide
effort.
Targeting criteria must be expected to vary among
source categories and some believe that they must
vary from source to source.
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APPENDIX A - 3
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Sample Form
10/3/84GEMS GE3E3AL COMPLIANCE AUDIT DATA SHEET
(40 C.F.R. Part 60, Subpart D) APPENDIX A-3
Instructions and Explanation
ITEM 1; Audit Results
ITEMS 2-4: Standard Source Identification Information
ITEM 5; Emission Requirements
Normally the emission limits and exceptions will be those specified in Subpart D; however,
in some circumstances, variations may apply as a result of a special permit, enforcement,
etc. Note the specific exception and the specific regulation or requirement in which it is
contained (e.g., "operating permit" or "order," etc.). "Description of Control System" is meant
to provide space for identifying the basic control system (e.g., "hot side ESP rated 99.2%" or
"long term low sulfur coal contract").
ITEM 6; CEMS Compliance Status
In general, answer yes/no and provide other information as requested:
o "Type of CSA/CEM Requirement" Enter the type of requirement (e.g., NSPS regulation,
permit, enforcement order, etc.). "
o "Dates CEMS Installed/Operational" Enter the date of installation and the date the
CEMS began operating.
o "Date(s) of PST?" Enter symbol "P" with the most recent date passed. If it passed,
then recently failed, both occurrences might be noted (e.g., P-7/19/81; F-6/4/84).
o "Is Source Filing EERs? To Whom?" Yes/no. If yes, specify to whom by entering
"State," "EPA" or "State & EPA."
o "Do EERs Indicate Emissions Problems?" Yes/no. If "yes," provide more information in
l"Jiii a or in an attached sheet.
o "Po EERs Indicate CEMS Problems?" Yes/no. If "yes," provide more information in ITEM
3 or in an attached sheet.
o "Do EERs Comply with Reporting Requirements?" Yes/no. If "no," provide more information
in ITEM 3 or in attached sheet.
o "Results of Aaencv Field Audit" If not conducted, enter "n/a." If conducted, enter
"P" (passj, "F" (failed), or "Inc" (Incomplete), and the date for the most recent
audit. If "F," more detailed information should be provided in ITEM 8 or in an
attached sheet.
ITEM 7; Basic CEMS Identification Information
ITEM 8: Additional Baseline Information/Comments
In addition to expanded information on prior items, other baseline information may be
iided (<
plans, etc
included (e.g., a summary of a quality assurance plan, test schedules or monitor replacement
:7T.~
ITEM 9; Follow-up Action Plan (If Appropriate)
In follow-up action is necessary, note recommended follow-up action, management
concurrence, etc.
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Sample Form
10/3/84
CEM5 GENERAL COMPLIANCE AUDIT DATA SHEET
40 C.F.R. Part 60, Subpart D
(See Instruction Sheet)
APPENDIX 3(Cont:
1. Audit Results
Follow-up
Recommended
(Yes/No, see * 8)
(Name)
(Date)
3. Plant/0nit(s)
Address
Source Type
Size
4. QMS Contact
(Name)
(Position)
(Telpnone No.)
5. Emission Requirements
j Emission
! Limitations
Opacity |
|
SO, |
N0x i
Exceptions/
Type of Exception
Description of
Control System
6. GEMS Compliance Status
Opacity
SO,
^x
Type of
CSA/CZMS
Requirement
Date(s)
GEMS In-
stalled/
Operational
/
/
/
Date(s)
of PST
Is Source
Filing
EERs?
To Whom?
/
/
/
Do EERs
Indicate
Emissions
Problems?
Do EERs
Indicate
CEMS
Problems?
Do EERs
Comply w/
Reporting
Requirements?
Results
of Agency
Field
Audit
-------
APPENDIX 3(Cont.)
7. Basic Monitor Information
Opacity
SO,
N0x
CO,
o,
Monitor MaXe,
Model & Serial (lumber
Recorder Type
and Model
Computer/
Software
Other
8. Additional Baseline Information/Comments
9. Follow-up Action Plan (If Appropriate)
-------
APPENDIX A - 4
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- 2 -
APPENDIX 4 (Cont)
Subpart Source Category
R PRIMARY LEAD SMELTERS
Z FERROALLOY PRODUCTION
FACILITIES
AA STEEL PLANTS:
ELECTRIC ARC FURNACES
Pollutant
Opacity, SO2
Opacity
Opacity
BB KRAFT PULP MILLS
Recovery Furnace
Lime kiln, digester
system, brown stock
washer system, multiple
effect evaporator system,
black liquor oxidation
system, or condensate
stripper system.
Opacity
TRS (dry basis)
TRS (dry basis)
HH LIME MANUFACTURING PLANTS
Rotary Lime Kilns
Opacity3
a Does not apply when there is a wet scrubbing emission
control device.
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APPENDIX A-4
NSPS SOURCE CATEGORIES WHICH ARE
REQUIRED TO USE CONTINOUS EMISSION MONITORS
(as of October 1, 1984)
Subpart
D
Da
G
H
J
N
p
0
Source Category
STEAM GENERATORS
Solid Fossil Fuel
Liquid Fossil Fuel
Gaseous Fossil Fuel
ELECTRIC UTILITY STEAM
GENERATING UNITS
Solid Fossil Fuel
Liquid Fossil Fuel
Gaseous Fossil Fuel
NITRIC ACID PLANTS
SULFURIC ACID PLANTS
PETROLEUM REFINERIES
FCCU
Combustion of Fuel Gases
Sulfur Recovery Plant
IRON AND STEEL PLANTS
PRIMARY COPPER SMELTERS
PRIMARY ZINC SMELTERS
Pollutant
Opacity, SO2, NOX
Opacity, SO2, NOX
NOX
Opacity, SO2 (at inlet and
outlet of control device), NOX
Opacity, SO2 (at inlet and
outlet of control device), NOX
NOX
NOX
SO2
Opacity, CO
SO2 or H2S
S02a, H2Sb, TRSb, TRSb
Opacity, SO2
Opacity, SO2
a For oxidation control systems.
b For reduction control systems not followed by incineration.
-------
TECHNICAL REPORT DATA
-------
TECHNICAL REPORT DATA
(Please read Instructions on the rt-.-rnt before completing}
1. REPORT NO.
340/1-84-015
3. RECIPIENTS ACCESSION NO.
4. TITLE AND SUBTITLE
Technical Guidance on the Review and Use of Excess
Emission Reports (EERs)
5. REPORT DATE
October 1984
6. PERFORMING ORGANIZATION CODE
7. AUTHOH(S)
8. PERFORMING ORGANIZATION REPORT NO.
Louis R. Paley, SSCD, OAQPS, EPA
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
N/A
11. CONTRACT/GRANT NO.
N/A
12. SPONSORING AGENCY NAME AND ADDRESS
Stationary Source Compliance Division, OAQPS (EN-341)
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA 340/1
IS. SUPPLEMENTARY NOTES
Technical guidance to air compliance offices of EPA
18. ABSTRACT
The objective of this guidance is to assist EPA Regional Offices in- proceeding
expeditiously, and in a nationally consistent manner, with the review and follow-up of
EER data from NSPS Subpart D and other source categories where the monitoring system
is not the compliance method. The guidance suggests that agencies initiate this
three-phase EER review and follow-up program concurrently with the development of a
thorough inventory of CEMS-affected sources and the determination of the compliance
status of these sources with CEMS installation and operating requirements. The
guidance recommends the implementation of a methodical procedure to review and follow-
up on EERs derived'from sources which the agency believes for the most part are in
compliance with their emission, monitoring, and reporting requirements. In general,
the procedures are not designed primarily for use on known violators or sources
which have had a long history of non-compliance. Although the guidance outlines a
program primarily based upon Agency experience with EERs from large boilers, the
guidance can be used for the review and follow-up of EERs derived from continuous
emission monitoring systems required by most Federally-enforceable regulations
(most current applications of CEMS data, other than direct compliance determinations
with emission standards such as in Subpart Da).
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATl Field/Group
Compliance
Compliance Data System (CDS)
Continuous Emission Monitoring Gysterns (CEMf3)
Excess Emission Reports (EERs)
Guidance
New Source Performance Standards (NSPS)
13. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (TIlis Report!
N/A
21. NO. OF PAGES
20. SECURITY CLASS (This page)
N/A
22. PRICE
EPA Perm 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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