United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
(2251A)
EPA/315/B-98/004
November 1998
www.inece.org
SOURCE SELF-MONITORING
REQUIREMENTS:
INTERNATIONAL COMPARISON
Capacity Building Support Document
International Training Workshop
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Source Self-Monitoring, Reporting, and
Recordkeeping Requirements:
International Comparison
Environmental Compliance and Enforcement
Capacity Building Resource Document
August, 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
TABLE OF CONTENTS
Page
PREFACE vii
ACKNOWLEDGMENTS ix
EXECUTIVE SUMMARY xi
1 INTRODUCTION 1-1
1.1 SCOPE AND PURPOSE ; 1-1
1.2 INFORMATION DEVELOPMENT 1-1
1.3 DOCUMENT ORGANIZATION 1-4
2 OVERVIEW OF SOURCE SELF-MONITORING, REPORTING, AND
RECORDKEEPING 2-1
2.1 INTRODUCTION 2-1
2.2 PROGRAM OBJECTIVES OF SOURCE SELF-MONITORING,
REPORTING, AND RECORDKEEPING 2-1
2.3 DESIGN IMPLICATIONS OF PROGRAM OBJECTIVES 2-4
2.4 LEGAL MECHANISMS AND LEVEL OF IMPLEMENTATION OF
SOURCE SELF-MONITORING REQUIREMENTS 2-5
2.4.1 Legal Mechanisms for Implementing Source Self-Monitoring
Requirements '. 2-5
2.4.1.1 Statutes 2-6
2.4.1.2 Regulations 2-7
2.4.1.3 Permits 2-7
2.4.1.4 Policies 2-8
2.4.2 Level of Implementation of Source Self-Monitoring Requirements . . . 2-8
2.5 VOLUNTARY MECHANISMS AND STANDARDS FOR
PERFORMANCE MEASUREMENT AND MONITORING IN
ENVIRONMENTAL MANAGEMENT SYSTEMS 2-11
3 SCOPE OF SOURCE SELF-MONITORING REQUIREMENTS 3-1
3.1 INTRODUCTION 3-1
3.2 APPROACHES FOR SELECTING ACTIVITIES SUBJECT TO SOURCE
SELF-MONITORING REQUIREMENTS 3-1
3.3 EXAMPLES OF HOW COUNTRIES SELECT ACTIVITIES SUBJECT
TO SOURCE SELF-MONITORING REQUIREMENTS 3-2
3.3.1 Imposing Source Self-Monitoring On All Activities/Entities 3-2
3.3.2 Imposing Source Self-Monitoring On Specified Categories 3-3
3.3.3 Imposing Source Self-Monitoring Based on Specific Pollutants 3-5
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Self-monitoring, Reporting, and Recordkeeping Requirements
4 SELF-MONITORING REQUIREMENTS 4-1
4.1 GENERAL DESIGN FACTORS 4-1
4.2 SELF-MONITORING REQUIREMENTS FOR AIR PROGRAMS .... 4-1
4.2.1 Parameters 4-1
4.2.2 Monitoring Techniques 4-4
4.2.2 Monitoring Frequencies 4-4
4.3 SELF-MONITORING REQUIREMENTS FOR DRINKING WATER
PROGRAMS .'./. .... 4-9
4.3.1 Parameters 4-10
4.3.2 Monitoring Techniques 4-14
4.3.2.1 Analyses 4-14
4.3.2.2 Costs of Sample Collection and Analysis . . 4-15
4.3.3 Monitoring Frequencies 4-16
4.4 SELF-MONITORING REQUIREMENTS FOR WATER PROGRAMS 4-18
4.4.1 Monitoring Parameters 4-18
4.4.2 Monitoring Techniques 4-21
4.4.3 Monitoring Frequencies 4-21
5 ANALYSIS OF REPORTING AND RECORDKEEPING REQUIREMENTS ... 5-1
5.1 INTRODUCTION 5-1
5.2 REPORTING - DESIGN FACTORS 5-1
5.2.1 Information Needs 5-1
5.2.2 Reporting Frequency 5-2
5.2.3 Reporting Format 5-3
5.3 REPORTING - COUNTRY COMPARISON 5-3
5.3.1 Reporting Information Needs 5-3
5.3.2 Reporting Frequency 5-5
5.3.3 Reporting Format 5-5
5.4 RECORDKEEPING - DESIGN FACTORS 5-8
5.5 RECORDKEEPING - COUNTRY COMPARISON 5-8
6 DATA QUALITY ASSURANCE, VERIFICATION, AND MANAGEMENT . . 6-1
6.1 INTRODUCTION 6-1
6.2 DATA QUALITY ASSURANCE ACTIVITIES - DESIGN FACTORS . . 6-1
6.3 DATA QUALITY ASSURANCE ACTIVITIES - COUNTRY
COMPARISON 6-1
6.4 DATA VERIFICATION ACTIVITIES - DESIGN FACTORS 6-4
6.5 DATA VERIFICATION ACTIVITIES - COUNTRY COMPARISON ... 6-4
6.6 DATA MANAGEMENT - DESIGN FACTORS 6-6
6.7 DATA MANAGEMENT - COUNTRY COMPARISON 6-6
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ENFORCEMENT OF SELF-MONITORING REQUIREMENTS 7-1
7.1 INTRODUCTION i. 7-1
7.2 TRACKING OF NONCOMPLIANCE WITH SELF-MONITORING
AND REPORTING REQUIREMENTS 7-1
7.3 NUMBER AND TYPE OF ENFORCEMENT ACTIONS TAKEN
FOR VIOLATIONS OF SELF- MONITORING AND REPORTING
REQUIREMENTS 7-3
REFERENCES
GLOSSARY
APPENDIX A-l
APPENDIX A-2
APPENDIX Ar3
APPENDIX A-4
APPENDIX A-5
APPENDIX A-6
APPENDIX A-7
APPENDIX B-l
APPENDIX C-l
APPENDIX D-l
LIST OF APPENDICES
U.S. Program Requirements - Air
U.S. Program Requirements - Water
U.S. Program Requirements - Drinking Water
U.S. Program Requirements - Toxic Release Inventory
U.S. Program Requirements - Solid Waste
U.S. Program Requirements - Pesticides
U.S. Program Requirements - Toxic Substances
Mass-Flow Check Values for The Netherlands Emissions Regulations
Self Monitoring Frequencies for U.K. Drinking Water Program
India's Annual Statements
APPENDIX E-l Electronic Reporting Requirements for U.S. Utilities Under Air Program
APPENDIX F-l Information on Other U.S. Data Management Systems
APPENDIX G-l Standard Methods for Air Monitoring - The Netherlands
APPENDIX H-l Reporting Forms Under Canada's Vinyl Chloride and Lead Smelter
Regulations
APPENDIX H-2 Enhanced Monitoring Report Form -U.S. Air Program
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APPENDIX 1-1 Fact Sheet on Norwegian INKOSYS Database
APPENDIX J-l Norway's Internal Control Regulations
LIST OF EXHIBITS
Exhibit 1-1. Program Examples 1-3
Exhibit 2-1. Use/Purpose of Self-monitoring Data 2-3
Exhibit 2-2. Design Implications Presented by Different Self-Monitoring Program
Objectives 2-5
Exhibit 2-3. Level of Source Self-Monitoring Implementation 2-10
Exhibit 3-1. Categories of Activities/Entities Subject to Additional Source Self-
Monitoring Regulation hi The Netherlands 3-3
Exhibit 3-2. Prescribed Processes Under United Kingdom Integrated Pollution
Control 3-4
Exhibit 4-1. Air Parameter Characteristics and Rationale for Requiring Self-
Monitoring 4-2
Exhibit 4-2. Parameters Monitored in Air Programs 4-3
Exhibit 4-3. Monitoring Techniques for Air Emissions 4-5
Exhibit 4-4. Monitoring Techniques Applicable to Air Emissions and Analytical
Methods for Manually Obtained Stack Data 4-6
Exhibit 4-5. Frequency Of Self-Monitoring In Air Programs 4-7
Exhibit 4-6. The Netherlands Guidance for Type and Frequency of Air Monitoring . . 4-8
Exhibit 4-7. Germany's Administrative Regulation on Air Conservation . 4-9
Exhibit 4-8. Drinking Water Monitoring Parameters and Associated Rationale for
Monitoring 4-11
Exhibit 4-9. Parameters Monitored in Drinking Water Programs 4-13
Exhibit 4-10. Sampling Techniques for Water Samples 4-14
Exhibit 4-11. Relative Cost of Analysis 4-16
Exhibit 4-12. Frequency Of Self-Monitoring Requirements In Drinking Water
Programs 4-17
Exhibit 4-13. Parameters Monitored in Water Programs 4-19
Exhibit 4-14. Parameters Monitored In Water Programs 4-20
Exhibit 4-15. Frequency of Self-Monitoring Requirements for Sampling and
Analysis hi Water Programs 4-22
Exhibit 4-16. Self-Monitoring Frequencies in the United States Water Program .... 4-23
Exhibit 5-1. Reporting Program Information Needs 5-4
Exhibit 5-2. Reporting Frequency 5-6
Exhibit 5-3. Reporting Format 5-7
Exhibit 5-4. Country Comparison of Recordkeeping Requirements 5-9
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 6-1. Required Data Quality Assurance Activities for Regulated Entities that
Self-Monitor 6-2
Exhibit 6-2. The Netherlands Air Program . 6-3
Exhibit 6-3. Example of United States Pretreatment Program Self-Certification
Statement 6-4
Exhibit 6-4. Data Verification Activities Conducted by Regulatory Agencies 6-5
Exhibit 6-5. Types of Inspections in United States Water Program 6-6
Exhibit 6-6. Data Management Procedures and Public Accessibility 6-8
Exhibit 7-1. Examples of Programs that Track Noncompliance with Self-Monitoring
and Reporting Requirements . . : 7-2
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Self-monitoring, Reporting, and Recordkeeping Requirements
VI
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Self-monitoring, Reporting, and Recordkeeping Requirements
PREFACE
This document, Source Self-Monitoring, Reporting, and Recordkeeping Requirements: an
International Comparison, was originally prepared as one of five Environmental Compliance and
Enforcement Capacity Building Technical Resource Documents that were developed to support
the Fourth International Conference on Environmental Compliance and Enforcement held in
Chiang Mai, Thailand, April 22-26, 1996 and ongoing exchange under the International Network
for Environmental Compliance and Enforcement. It was maintained as a pre-publication draft to
accommodate additional country examples. This final version has been updated for use at the
Fifth International Conference in Monterey, California, November 16-20, 1998 along with several
new capacity building documents. These documents were developed as resource documents to
be used by government officials and others who have responsibility for developing and/or
enhancing environmental compliance and enforcement programs. The Resource Documents
include: '•
Financing Environmental Permit, Compliance and Enforcement Programs,
Source Self-Monitoring, Reporting, and Recordkeeping Requirements: an
International Comparison
Multimedia Inspection Protocols,
Communications Strategies for Environmental Enforcement Programs, and
Transboundary Trade in Potentially Hazardous (Waste, Pesticides and Ozone
depleting) Substances.
International Inspector Training Compendium, Course and Program Comparison
Country Progress/Self Assessment Reports on Environmental Compliance and
Enforcement
» Citizen Enforcement: Tools for Effective Participation
Consistent with the goals of the Executive Planning Committees for the Fourth and Fifth
International Conferences to build capacity internationally for environmental compliance and
enforcement, this document addresses source self-monitoring, reporting and recordkeeping as a
cornerstone to compliance monitoring. Source self-monitoring constitutes those activities that are
required to be undertaken by regulated entities to monitor and report on their environmental
compliance. This document presents comparative information on how different countries use
source self-monitoring requirements as a form of compliance monitoring within their
environmental enforcement programs. The information presented can be used by government
officials to help design or enhance their own environmental enforcement programs with the
objective of achieving a higher level of compliance.
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Self-monitoring, Reporting, and Recordkeeping Requirements
Source Self-Monitoring, Reporting, and Recordkeeping Requirements: an International
Comparison, and the other documents listed above are available on the International Network for
Environmental Compliance and Enforcement's (INECE) Internet site: http://www.inece.org.
They also are available from the INECE Secretariat at the addresses below. Finally, the INECE
Secretariat seeks your comments as to whether these documents serve their intended purpose and
how they might be improved. Please send comments in writing to the INECE Secretariat in care
of Ms. Wasserman or Mr. Gerardu at the following addresses:
Ms. Cheryl Wasserman
Associate Director for Policy Analysis
Office of Federal Activities
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M Street MC 2251-A
Washington, D.C. 20460
FAX 1-202-564-0070
PHONE 1-202-564-7129
E-MAIL wasserman.cheryl@epa.gov
or
Mr. Jo Gerardu
Head, Strategy, Planning and Control Division
Inspectorate for the Environment
The Netherlands Ministry of Housing, Spatial Planning and the Environment
BPC680
P.O. Box 30945
2500 GX Den Haag
The Netherlands
FAX 1-31-70-339-1300
PHONE 1-31-70-339-2536.
E-MAIL gerardu@IMH-HI.dgm.minvrom.nl
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Self-monitoring, Reporting, and Recordkeeping Requirements
ACKNOWLEDGMENTS
This document was developed with the support of Science Applications International Corporation
under U.S. Environmental Protection Agency Contract 68-W2-0026, Work Assignment 39-11.
Technical direction was provided by Ms. Cheryl Wasserman of U.S. Environmental Protection
Agency's Office of Enforcement and Compliance Assurance, in cooperation with the conference
sponsors and Executive Planning Committee members, each of whom, along with their
governments or organizations, must be recognized for their support in reviewing and commenting
on the draft outline and early drafts of the document.
• Dr. Adegoke Adegoroye, Nigeria,
• Mrs. Jacqueline Alosisi de Larderel, United Nations Environment Programme, France,
• Mr. Antonio Azuela, Mexico ,
• Ms. Susan Becker, United Nations Environment Programme, France,
Mr. Christopher Currie, Environment Canada,
Mr. William Eichbaum, WWF,
Dr. Ossama El-Kholy, Egypt,
Mr. Marius Enthoven, European Commission,
Mr. J. William Futrell, ELI, United States,
Ms. Vivianne Blanlot, Chile,
Mr. Marco Antonio Gonzalez Salazar, Costa Rica,
Dr. Francois Hanekom, South Africa,
Mr. Steven A. Herman, United States,
Mr. Jalaluddin Bin Ismail, Malaysia,
Mr, Zbigniew Kamienski, Poland,
Dr. Pakit Kiravanich, Thailand,
Mr. Sun Lin, UNEP,
Mr. Robert Reiniger, Hungary
• Dr. David Slater, United Kingdom,
• Ms. Rachel A. Vasquez, The Philippines,
• Mr. Pieter J. Verkerk, The Netherlands,
« Mr. Zhang Hongjun, People's Republic of China
Finally, the document could not have been developed without the generous assistance of the
following individuals who provided the detailed information on their country programs:
• Mr. Christopher Currie, Environment Canada,
• Dr. Manfred Putz, Germany,
• Mr. Robert Reiniger, Hungary National Authority for the Environment,
• Dr. B. Sengupta, India Central Pollution Control Board,
• Mr. Jo Gerardu and Mr. Robert Glaser, The Netherlands Inspectorate for the
Environment,
• Mr. Jens Erik Pettersen, Norway State Pollution Control Authority,
• Mr. Alun James, United Kingdom, Her Majesty's Inspectorate of Pollution,
• Mr. Padaic Larkin, Environmental Protection Agency, Ireland, and
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• Cheryl Wasserman, Mr. John Rasnic, Mr. Brian Maas, Mr. Jon Jacobs, and
Mr. David C. Nielsen of the United States Environmental Protection Agency.
These individuals expended significant effort to gather information, complete tables, respond to
questions, provide relevant reference materials, and review draft documents. Because the
information they provided has been essential to the completion of this report, these individuals
deserve special thanks for the tune, effort and patience they committed to this project.
A final note of appreciation goes to two summer interns at the U.S. Environmental Protection
Agency, Ms. Watcharee Limanon and Mr. Johns Hopkins, who helped to incorporate new
information and update the text prior to final publication.
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EXECUTIVE SUMMARY
SYNOPSIS OF INTERNATIONAL COMPARISON OF SOURCE SELF-MONITORING,
REPORTING, AND RECORDKEEPING REQUIREMENTS
Capacity Building Support Document
for
Environmental Compliance and Enforcement Programs
Purpose
Consistent with the goals of the Fourth International Conference on Environmental Compliance
and Enforcement, its international sponsors, and the Executive Planning Committee, this
document addresses source self-monitoring, reporting, and recordkeeping as a cornerstone to
compliance monitoring. Source self-monitoring, reporting, and recordkeeping constitute those
activities that are required to be undertaken by regulated entities to monitor and report on their
environmental compliance. This document presents comparative information on how different
countries use source self monitoring requirements as a form of compliance monitoring within their
environmental enforcement programs.
Scope
Information and data on self-monitoring, reporting, and recordkeeping requirements was solicited
from various countries throughout the world. Information provided by the following countries is
contained in the document:
Canada
India
The Netherlands
Germany
Ireland
Norway
Hungary
Mexico
United Kingdom
United States
In addition, limited information on self-monitoring requirements on programs in Israel and Japan
that was obtained from available reference sources is included.
Subject Areas
The document is organized based on the key design issues that country officials should consider
when developing orjjnhancing their self-monitoring, reporting, and recordkeeping requirements as
part of their compliance monitoring programs. Specific chapters cover the following design
issues:
What is source self-monitoring? What program objectives can be used to achieve self-
monitoring? How are data used? Through what legal mechanisms is self-monitoring
imposed? At what levels of government are self-monitoring requirements imposed?
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Self-monitoring, Reporting, and Recordkeeping Requirements
• Who must conduct self-monitoring? What industries should be subject to source self-
monitoring requirements? Should this include all of an industry or some subset?
• What source self-monitoring activities are required? What parameters must be
monitored, at what frequency, using which method?
• What information must be reported and-what records must be maintained? What
information must be reported to the regulatory agency, in what format, at what frequency,
and to whom? What information must be maintained and for how long?
• What quality assurance and data validation procedures are implemented and how are
data managed? What procedures are conducted to ensure the accuracy of the self-
monitoring data (by both the regulated community and the regulatory agency)? How are
data managed by the regulatory agency?
• How is self-monitoring enforced?
Within each chapter, the factors and/or criteria typically used by countries in answering these
design questions are discussed. Country-specific examples are provided that illustrate how these
factprs have been utilized hi the development of various countries' programs. Detailed country-
specific information (for example, copies of reporting forms) is included in the Appendices as
reference material.
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Self-monitoring, Reporting, and Recordkeeping Requirements
1 INTRODUCTION
1.1 SCOPE AND PURPOSE
Compliance monitoring is a fundamental component of an effective environmental
compliance and enforcement program. Compliance monitoring allows the regulated
community and the government to document compliance, detect and correct violations, obtain
evidence to support enforcement actions, and evaluate program progress.1
Beyond identifying compliance monitoring as fundamental to enforcement programs,
participants at the Second International Conference on Environmental Enforcement
(Budapest, Hungary, 1992) reached a consensus regarding the importance of source self-
monitoring as a means of supplementing traditional compliance monitoring methods (for
example, conducting inspections, relying on citizen complaints, or conducting monitoring of
environmental conditions near regulated facilities) whenever it is cost-effective to do so.
Source self-monitoring was recognized as an important form of compliance monitoring
because it offers certain desirable attributes: increasing awareness within the regulated
community, deterring noncompliance, facilitating data collection, promoting public access to
compliance-related information, leveraging other compliance monitoring resources, and
facilitating enforcement.
This document summarizes and contrasts how several countries use source self-monitoring
requirements to conduct compliance monitoring within their respective environmental
enforcement programs. The purpose of this analysis is to share alternative approaches to
source self-monitoring activities so conference participants and the growing network of
governmental and non-governmental officials can use such information as they see fit to
design or enhance their own environmental enforcement programs.
1.2 INFORMATION DEVELOPMENT
The information presented in this document was developed by requesting data regarding
source self-monitoring, recordkeeping, and reporting requirements from the following
countries:
• Canada,
• Germany,
• Hungary,
• India,
• Ireland,
• Mexico,
Wasserman, C.E., Principles of Environmental Enforcement, U.S. Environmental Protection Agency,
Second International Conference on Environmental Enforcement, Proceedings, Vol. I., Budapest,
Hungary (Sept. 22-25, 1992), pgs. 15, 79.
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Self-monitoring, Reporting, and Recordkeeping Requirements
• The Netherlands,
• Norway,
• United Kingdom, and
• United States.
These countries were selected based on several factors, including prior contact and access to
preliminary information indicating that they have source self-monitoring requirements hi
place, as well as on each country's willingness to provide such information. Although a
cross-section of developing, transitional, industrial, and rapidly industrializing countries was
sought from all regions of the world, the countries included are not deemed to be
representative of all programs.
In some tables throughout the text, information has been included for other countries (for
example, Japan and Israel) based on available references or unsolicited submissions of
information.
Each country was requested to complete an information collection guide that asked for data
regarding seven distinct aspects of their programs. These included: 1) self-monitoring
requirements; 2) reporting requirements; 3) recordkeeping requirements; 4) data quality
assurance; 5) data management; 6) data use; and 7) types of enforcement actions.
Exhibit 1-1 illustrates on a country-by-country basis those programs for which data were
provided.
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Self-monitoring, Reporting, and Recordkeeping Requirements
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1. Very few emitters; they usually make a self-declaration.
2. Mobile sources are regulated under Air (Prevention and Control) Act.
3. Noise, odor, groundwater, surface water, operating parameters of on-site WWTP, pollution emission register, environmental management
plan, firewater retention, and bund integrity.
4. Municipal wastes are regulated under the Waste Substances Act.
5. Hazardous wastes are regulated under the Chemical Wastes Act.
6. For entities regulated by permit.
7. For non-Integrated Pollution Control facilities, there is no self monitorhlg. Monitoring is done by the National Rivers Authority - discharge
environmental monitorhlg. New legislation on "urban waste water treatment" will require self monitoring from 1988.
8. Radioactive substances.
9. Emergency Planning and Community Right-to-Know Act.
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Self-monitoring, Reporting, and Recordkeeping Requirements
1.3 DOCUMENT ORGANIZATION
The information on the various countries is presented in Chapters 2-7. These Chapters are
organized based on the key design issues that present themselves when designing or
enhancing an enforcement program. These key design issues, and the corresponding
Chapters of the document, are:
Chapter 2 An overview of source self-monitoring. What is source self-monitoring?
What program objectives can it be used to achieve/How are data used?
Through what legal mechanisms is self-monitoring imposed? At what
level of government is self-monitoring implemented?
Chapter 3 Who must conduct source self-monitoring? What industries should be
subject to source self-monitoring requirements? Should this include all
of an industry or some subset?
Chapter 4 What source self-monitoring activities are required? What parameters
must be monitored, at what frequency, using which method?
Chapter 5 What information must be reported and what records must be
maintained? What information must be reported, hi what format, at
what frequency, and to whom? What information must be maintained
and for how long?
Chapter 6 What quality assurance and data validation procedures are
implemented, and how are data managed? What procedures are
conducted to ensure the accuracy of the self-monitoring data (by both
the regulated community and the regulatory agency)? How are data
managed by the regulatory agency?
Chapter 7 How is self-monitoring enforced?
Within each chapter, the factors and/or criteria typically used by countries in answering these
design questions are discussed. Country-specific examples are then provided that illustrate
how these factors have been utilized in the development of various countries' programs.
Detailed country-specific information (for example, copies of reporting forms, listing of
approved analytical methods) is included hi the Appendices as reference materials.
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Self-monitoring, Reporting, and Recordkeeping Requirements
2 OVERVIEW OF SOURCE SELF-MONITORING,
REPORTING, AND RECORDKEEPING
2.1 INTRODUCTION
Source self-monitoring, reporting, and recordkeeping constitutes one of four basic approaches
to conducting compliance monitoring as part of an environmental enforcement program.1
This section examines different program objectives that can be served by these activities, and
the implications for designing or enhancing a program posed by these different objectives. It
also provides background on how source self-monitoring is implemented. For purposes of
this document: ;
Self-monitoring is any activity undertaken by a facility or entity to measure an
emission, discharge, release, or performance parameter, or to observe operations,
processes or activities with the purpose of identifying potential emissions, discharges,
or releases.
Recordkeeping is documentation or records required to be maintained by the regulated
facility regarding its regulated activities or processes. Such documentation must
generally be maintained for a defined period of tune and must be available to the
regulatory authority for review (for example, during inspections).
Reporting is the submission of information or self-monitoring data periodically and/or
upon the request of the enforcement authority.
2.2 PROGRAM OBJECTIVES OF SOURCE SELF-MONITORING, REPORTING,
AND RECORDKEEPING
As a specific form of compliance monitoring, source self-monitoring may serve several
distinct objectives within an environmental program. These objectives include:
Enforcement - Source self-monitoring data can identify violations of environmental
standards and provide the regulatory authority with data or other documentation of
such violations. Thus, such monitoring data can serve as the basis for an enforcement
action. Such monitoring may also provide information that serves as the basis for
follow-up monitoring (that is, an inspection), which also may result in an enforcement
action. In addition, information obtained through source self-monitoring can support
the development of an enforcement strategy. This occurs when such information is
used to help target enforcement resources at high priority problems.
Increasing Awareness Within the Regulated Community - Source self-monitoring
promotes environmental awareness within the regulated community. Such monitoring,
reporting and recordkeeping requirements compel the regulated community to become
1 The other methods are conducting inspections, relying upon citizen complaints and conducting
monitoring of environmental conditions near regulated facilities.
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Self-monitoring, Reporting, and Recordkeeping Requirements
involved in the monitoring process. There are several natural consequences of such
involvement. First, the regulated community becomes more knowledgeable about its
environmental performance. Second, management personnel at regulated facilities
increase their role in assuring environmental compliance. Finally, the increased
awareness promotes the early detection of noncompliance, which allows a facility to
quickly identify and remedy environmental problems.
Deterrence - Source self-monitoring activities deter violations of environmental
standards because they ensure that violations are discovered and reported. Self-
monitoring and reporting requirements combine to fulfill the first tenet of deterrence —
ensuring that a violation will be detected. In addition, because regulated facilities are
involved hi the monitoring process and are therefore more aware of their compliance
status than they would otherwise be, they may be viewed as having greater
responsibility for curing minor problems before they become significant. This also
helps deter violations.
Data Collection - Source self-monitoring may be used to collect various types of
environmental data. Such data may be very basic (for example, identification of the
regulated community), hi the realm of general information (for example, indicating
general environmental performance/management activity), or compliance-specific (for
example, indicating compliance or noncompliance with specific environmental
standards). These different types of data may be compiled in data bases and have
many potential uses, including targeting areas for regulation or enforcement, targeting
specific chemicals or activities for regulation, characterizing the practices and
processes used by the regulated community, and assessing general environmental
conditions.
Public Access - Source self-monitoring information also may be made publicly
available, either directly or through a regulatory agency. Such access promotes
increased public scrutiny of environmental performance, which may come in the form
of citizen enforcement suits (where authorized) or informal pressure on a facility to
improve performance. Both promote unproved environmental compliance.
Leveraging Compliance Monitoring Resources - Finally, source self-monitoring allows
regulatory agencies to place a portion of the compliance monitoring burden on the
regulated community. This subjects all regulated entities to compliance monitoring,
which dramatically increases the impact of the compliance monitoring program
compared to a program that relies solely on inspections.
In designing or enhancing an environmental compliance monitoring program, source self-
monitoring may be used to promote one, some, or all of these objectives. As an example of
how these objectives are pursued by the countries reviewed, Exhibit 2-1 presents data on
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which programs use source self-monitoring to achieve specific objectives. Because the
objectives of increasing awareness, deterrence, and leveraging resources are more general
objectives that are achieved to some extent through all forms of source self-monitoring, these
are not addressed in the exhibit.
In addition to these objectives, countries may have to consider international standards when
designing or enhancing a self-monitoring, reporting, and recordkeeping program. For
example, several countries are now requiring facilities to be certified in ISO 14001 or other
similar environmental management standards. Norway requires its facilities to have in place
an internal control system to ensure that regulatory requirements are met. These Internal
Control Regulations, with guidelines, are contained in Appendix I. Likewise, several
countries are developing similar standards with which facilities must comply. Usually, such
standards or specifications have a component that addresses compliance tracking through
required self-monitoring and reporting.
2.3 DESIGN IMPLICATIONS OF PROGRAM OBJECTIVES
Different compliance monitoring program objectives require different capabilities in a source
self-monitoring system. As a result, the structure of a source self-monitoring program is
affected by the objectives sought to be achieved by the program. For example, a source self-
nTonitoring program that is used to identify cases warranting enforcement action must identify
violations of applicable standards in sufficient detail and be based upon sufficiently reliable
data to support initiation of an enforcement action. In contrast, a program that uses source
self-monitoring primarily to increase the awareness of the regulated community with regard
to its environmental compliance status (and, perhaps, secondarily to deter environmental
violations) may be broad hi scope but requires less active data management by the regulatory
agency. Exhibit 2-2 summarizes the basic design implications presented by different source
self-monitoring program objectives.
As indicated above, key aspects of a country's self-monitoring program, including its scope,
the level of specific information required, the amount of documentation needed, the extent
and nature of reporting requirements, and the degree of active management of data
necessary by the regulatory agency, are affected by the objective(s) of the source serf-
monitoring program. The key point is that program objectives drive the design of the source
self-monitoring programs and, thus, such objectives must be clear when designing or
enhancing a program.
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Exhibit 2-2. Design Implications Presented by Different Self-Monitoring Program
Objectives
<•.*•? objectives ••"-
* *• A <*
>•- DesiredJErograni-Charactefistic
Enforcement
Must identify violations
Must document violations
Data must be reliable
Should identify all violations, but need not
provide data unrelated to violations
Provide high degree of specificity in data
Use specified methods for gathering and
analyzing data
Increase Awareness
Broad scope
Require management involvement
Require monitoring of all significant
program components
Require management certification of data/
reports
Data need not be actively managed by
regulatory agency
Deterrence
Broad scope
Must include basic elements for
detecting violations
Require monitoring of all significant
program components
Require reporting and/or recordkeeping as
necessary to achieve deterrence
Data need not be actively managed by
regulatory authority
Data Collection
Data are useful, complete, and accurate
Data are easily usable
Base data needs on assessment of use
Impose standard format to extent feasible
Public Access
Data are useful, complete, and accurate
Data are easily usable
Base data needs on assessment of use
Impose standard format to extent feasible
Leverage Resources
Requirements address key areas
System is self-implementing
Base program on priority concerns
Require self-monitoring and reporting of
key data elements
2.4 LEGAL MECHANISMS AND LEVEL OF IMPLEMENTATION OF SOURCE
SELF-MONITORING REQUIREMENTS
2.4.1 Legal Mechanisms for Implementing Source Self-Monitoring Requirements
Self-monitoring requirements may be imposed by various legal authorities or regulatory
mechanisms, including national or local statutes, regulations, permits (or licenses or
authorizations), or policies.
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2.4.1.1 Statutes
Generally, requirements for self-monitoring are authorized through environmental laws
(statutes), either in an expressed and explicit self-monitoring requirement, or in a general
expression of authority for information collection and/or reporting. Where self-monitoring is
imposed through statute, the key design question involves determining whether and to what
extent the statute should specify the nature of the self-monitoring requirements versus
providing discretion for determining the nature of these requirements to the government
agencies responsible for implementation.
Providing general statutory authority takes
advantage of the agency's expertise hi
knowing when self-monitoring will work and
integrating self-monitoring with other,
complementary program elements (for
example, compilation, organization and use of
self-monitoring data; follow-up compliance
monitoring and enforcement actions).
Examples of a statutory requirement imposing
self-monitoring and a general authorization for
information collection are provided below:
Countries Using Statutes to Impose
Self-monitoring Requirements
• Germany (air, water, drinking water,
solid nonhazardous waste)
• Hungary (all programs except air and
pesticides) /
» The Netherlands (drinking .water;
chemical and toxic substances)/
... Such [hazardous -waste generator] standards shall establish requirements respecting
— (6) submission of reports to the Administrator (or the State agency in any case in
which such agency carries out a permit program pursuant to this subchapter) at least
once every two years, setting out — (A) the quantities and nature of hazardous waste
... generated during the year; (B) the disposition of all hazardous waste ...; (C) the
efforts undertaken ...to reduce the volume and toxicity of waste generated; and (D) the
changes in volume and toxicity of waste actually achieved ... (U.S., Resource
Conservation and Recovery Act, 42 U.S.C. § 6922(a)(6)).
(2) A State Board may give directions requiring any person who in its opinion is ...
discharging effluent or trade effluent into any such stream or well, to give such
information as to the ... discharge at such times and in such form as may be specified
in the directions. (India, The Water (Prevention and Control of Pollution) Act, 1974,
§20.(2)).
Directly mandating self-monitoring or reporting restricts the discretion that may be exercised
by the implementing agency or department. Such a direct approach may make sense where a
country wants to impose self-monitoring requirements but does not anticipate developing
regulations to implement its environmental laws.
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2.4.1.2 Regulations
Self-monitoring is often imposed through
regulations, pursuant to a general grant of
statutory authority. Regulations tailor the
authority provided by statutes through the use
of the expertise of the administrative agency
or department (including its understanding of
how all of the specific components of its
environmental programs fit together) to
achieve the desired policy objectives. One
design issue presented by imposing self-
monitoring through regulations is how much
flexibility to provide to implementing
authorities. A second issue is determining
when the burden (including the collective
burden from all self-monitoring requirements)
imposed on the regulated community is too great. Most of the environmental laws reviewed
are not so prescriptive as to require self-monitoring. Rather, the administrative or regulatory
level of government hi each country has imposed self-monitoring requirements. Note that
imposition of self-monitoring requirements through regulations may also involve applying
such provisions through permits as well. Examples of regulatory provisions that impose self-
monitoring are provided below:
6. (1) The operator shall submit to the Minister for each calendar quarter, not later
than 30 days after the end of the quarter, a report in the form set out in (a) Schedule
I, in respect of any release of vinyl chloride form a process vent; (b) Schedule II, in
respect of any release of vinyl chloride from a polymerization reactor that is opened;
(c) Schedule III, in respect of any release of vinyl chloride from all sources
downstream of the slurry stripper or resin stripper; and (d) Schedule IV, in respect of
any release of vinyl chloride from ... any source referred to in paragraphs (a) to (c).
(Canada, Vinyl Chloride Release Regulations, 1992).
9. (1) The occupier generating hazardous waste and operator of a facility for collection,
reception, treatment, transport, storage, and disposal of hazardous waste shall maintain
records of such operations in Form 3. (2) The occupier and operator of a facility shall
send annual returns to the State Pollution Control Board in Form 4. (India Hazardous
Waste Rules, S.). 594(E), Ministry of Environment and Forests, 1989).
2.4.1.3 Permits
Permits, licenses, and authorizations consist of documents that specify the conditions under
which regulated facilities operate. Because they are facility-specific, permits allow for self-
monitoring requirements (that is, monitoring parameters, monitoring frequency, reporting
frequency) to be tailored to the particular needs of the facility. Some advantages of imposing
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requirements are applicable to a particular facility (that is, facilities have a difficult time arguing
they were unaware of their own permit conditions), the specific requirements are clear and known
to the facility, and the permit serves as an enforceable document. However, design issues include
determining how specific such requirements should be and how much discretion should be
delegated to permit writers. The more discretion provided to permit writers, the less consistent
source self-monitoring requirements will be program-wide.
2.4.1.4 Policies
Although self-monitoring requirements may be
imposed through policy, this is rare. Rather, it is
much more common for policy to be used to
specify or clarify how self-monitoring (for
example sampling and reporting) should be
conducted. For example, India reports that it
uses policy to implement self-monitoring
requirements in its air and solid waste programs.
Similarly, The Netherlands identifies policy as a
mechanism for implementing some requirements
in its air program. The United States also uses
policy to impose self-monitoring, but exclusively
to clarify requirements imposed through permits
or regulations.
2.4.2 Level of Implementation of Source Self-
Monitoring Requirements
Most countries distribute responsibility for the
implementation and enforcement of source self-
monitoring requirements among three levels of
government — national, regional/provincial/state,
and local — depending on the country's
institutional and industrial structure as well as the environmental medium.
drinking water at|d eiemlcal ^r toxfo ,
"'
'ff
The level of government used to implement source self-monitoring requirements affects three
design issues. First, whether a country imposes source self-monitoring requirements at a national,
regional, or local level impacts the degree of uniformity of data produced by such monitoring.
Depending on the intended use of the data, this may affect its utility (for example, data addressing
national hazardous waste management trends must use common terminology/definitions and units
of measurement).
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The second issue associated with the level at which source self-monitoring requirements are
implemented pertains to the type of data collected. Regional and local implementation allow
for more tailoring of source self-monitoring requirements. Such tailored requirements can
support regional and local levels of government, but may not support national program
needs.
The final issue involves resources available to implement a source self-monitoring program.
The scope and significance of a source self-monitoring program must be matched with the
availability of governmental resources to implement the program. Exhibit 2-3 indicates the
level of government at which source self-monitoring is implemented for countries and
programs addressed.
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Self-monitoring, Reporting, and Recordkeeping Requirements
2.5 VOLUNTARY MECHANISMS AND STANDARDS FOR PERFORMANCE
MEASUREMENT AND MONITORING IN ENVIRONMENTAL
MANAGEMENT SYSTEMS
Universal recognition of the importance of source self-monitoring to sound environmental
performance is expressed in the voluntary International Standards for Environmental
Management Systems established through the International Standards Organization in
September 1996. These standards, ISO 14001, include provisions for not only establishing
performance objectives and targets, but also for measurement and monitoring. Specifically,
Section 4.5.1 of the ISO 14001 Standard requires that facilities:
• Establish and maintain documented procedures to monitor and measure, on a regular
basis, the key characteristics of its operations and activities that can have a significant
impact on the environment. This shall include the recording of information to track
performance, relevant operational controls and conformance with the organization's
objectives and targets.
• Monitoring equipment shall be calibrated and maintained and records of this process
shall be retained according to the organization's procedures
• The organization shall establish and maintain a documented procedure for periodically
evaluating compliance with relevant environmental legislation and regulations.
ISO 14001 requires facilities not only to monitor their activities in general, but also to
monitor some key areas — particularly those areas that could have a significant impact on the
environment, and those for which regulatory standards exist. ISO 14001 also requires that
monitoring be conducted in accordance with recognize monitoring procedures, including
instrument calibration.
Thus, the international standard requires monitoring, not only of end-of-pipe emissions or
discharge monitoring to meet a compliance standard, but also to enable a facility to
continuously improve its environmental performance. Voluntary source self-monitoring
allows a facility to measure its targets and objectives, and to revise procedures if data
indicate targets and objectives are not being met. Voluntary monitoring also allows a facility
to determine which controls are necessary to minimize environmental impacts in cases where
the regulatory authority does not prescribe a specific level of control. Finally, voluntary
monitoring allows a facility to set realistic performance goals, as it can measure emissions as
a factor of production or discharge impacts during varying levels of precipitation.
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3 SCOPE OF SOURCE SELF-MONITORING REQUIREMENTS
3.1 INTRODUCTION
The first issue presented in developing or enhancing an environmental compliance and
enforcement program through the use of source self-monitoring is determining who should be
required to conduct self-monitoring. This question involves determining:
• Which activities/entities should be subject to source self-monitoring requirements?
• Should all or some subset of certain categories of activities or an industry be subject to
such requirements?
3.2 APPROACHES FOR SELECTING ACTIVITIES SUBJECT TO SOURCE SELF-
MONITORING REQUIREMENTS
There are basically three approaches to determuiing which activities/entities should be subject
to source self-monitoring requirements. These approaches include imposing source self-
monitoring requirements on:
• All activities/entities within a new program area,
• Defined categories of activities/entities, and
• Activities/entities that generate specified pollutants.
The most basic approach to selecting those activities/entities subject to source self-monitoring
requirements is to impose such requirements on all activities/entities within a new program
area. Under this approach, all activities/entities subject to the program area of concern (for
example, hazardous waste generators) would be subject to source self-monitoring
requirements. This approach is simple, uses source self-monitoring to full advantage, and is
fair. It also may be more protective of health, safety, and the environment because it does
not exempt sub-categories of activities/entities from self-monitoring requirements. However,
subjecting all entities within an environmental program to self-monitoring requirements may
impose a significant burden on both the regulated community and the regulatory agency.
Thus, it is important that this burden is commensurate with the purpose of such monitoring.
A second approach for defining the scope of source self-monitoring requirements is to
impose such requirements on defined categories of activities/entities. Under this approach,
only specified categories of facilities are subject to source self-monitoring requirements.
Categories may be based on then: propensity to ,pose high risks to health, safety, or the
environment, or the fact that certain activities/entities, which might individually pose
relatively low risks to society, are prevalent in a country or region. This approach offers the
advantage of targeting source self-monitoring requirements based on risk. However, this
approach requires the regulatory agency to develop a methodology to determine which
categories should be subject to source self-monitoring.
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The third approach to selecting activities/entities subject to source self-monitoring
requirements is to impose such requirements on those activities/entities that generate
specified pollutants. Under this approach, any activity/entity generating, for example, sulfur
dioxide, would be required to comply with specified source self-monitoring requirements.
This approach directly addresses pollutants of concern and avoids some of the burden of
having to target specific categories of activities/entities. However, targeting pollutants may
capture some unintended activities and impose an unjustified monitoring/reporting burden
upon such activities.
Each of the approaches identified above may be subject to specific exceptions that, in effect,
modify the scope of the self-monitoring requirements. Two common exceptions include 1)
activities conducted by small businesses and 2) activities conducted by entities that do not
meet specified process/production size criteria. Under some programs, small businesses1 are
excepted from having to comply with source self-monitoring requirements. Generally, this is
done to reduce the regulatory burden on small businesses, which are often viewed as posing
less risk to health, safety, and the environment, and generally have .fewer resources available
to meet regulatory responsibilities. In addition, because small businesses often represent a
large number of entities within a given regulatory scheme, this exception reduces the
administrative burden on the regulatory agency.
Some programs also exempt from self-monitoring requirements those entities that do not
meet specified process/production size criteria. This exception is premised on the idea that
smaller operations pose less risk to health, safety, and the environment than larger
operations. This exception also reduces the administrative burden imposed on both the
regulated community and responsible regulatory agency.
3.3 EXAMPLES OF HOW COUNTRIES SELECT ACTIVITIES SUBJECT TO
SOURCE SELF-MONITORING REQUIREMENTS
3.3.1 Imposing Source Self-Monitoring On All Activities/Entities
One program area where countries tend to impose source self-monitoring requirements on all
entities subject to the program area is drinking water. In the drinking water program area,
most countries impose self-monitoring, reporting, and recordkeeping requirements on
community water systems. Generally, community water systems are the entities responsible
for providing the public with safe drinking water. Because of the importance of this service,
all such systems must monitor the levels of contaminants to prevent adverse effects on human
health.
Another example of where source self-monitoring requirements are applied to all entities
subject to program regulations is the under part of the United States' hazardous waste
program. Under this program, all hazardous waste generators that ship hazardous waste off-
Small businesses are defined differently between programs. For example, the United States uses number
of employees as one criterion for determining what constitutes a small business.
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Self-monitoring, Reporting, and Recordkeeping Requirements
site for treatment must submit a biennial report to the United States' Environmental
Protection Agency identifying where the waste was shipped, the transporter used, waste
identification and quantity information, and other relevant information. This information
enables United States' Environmental Protection Agency to create a data base capable of
tracking significant hazardous waste transactions and trends in waste generation and
management.
3.3.2 Imposing Source Self-Monitoring On Specified Categories
There are many examples of programs that impose source self-monitoring requirements on
specified categories of activities/entities. This approach is common in programs that regulate
air and water pollution because, often, the standards imposed under these programs are
developed on an industry-by-industry basis. For example, under its air pollution program,
The Netherlands establishes basic requirements that are generally applicable and also
establishes additional specific requirements that are applicable to the categories of
activities/entities listed in Exhibit 3-1.
Exhibit 3-1. Categories of Activities/Entities
Subject to Additional Source Self-Monitoring Regulation in The Netherlands
Specific standards are included for the following:
.Manure processing plants
Sugar factories
Production of starch and starch derivatives
Wood processing
Coking plants
Asphalt mixing plants
Chlorine production
Polyvinyl chloride production
Production of acrylonitrile
Production of plastics containing acrylonitrile
Claus plants (for sulphur production and use in gas
cleaning)
Production of nitrogen-based fertilizer
Ammonia plants
Plants for production, formulation, or packaging of
pesticides
Silicon carbide production
Coarse ceramics industry
Mineral fibre production
Pig iron production; iron ore sintering
Pig iron production; iron ore pelletizing
Pig iron production; blast furnaces
Oxygen steel production
Primary aluminum production
Thermal reclamation of metals from cables and
similar plants
Iron and steel foundries and smelting plants
Surface treatment of metals with nitric acid
Production of carbon anodes
Pyrolysis plants
, Plants for the thermal cleaning of contaminated soil
These categories either have been identified as posing significant risk to health, safety, or the
environment, and/or exist in significant numbers to warrant regulatory control. An example
of where industries have been selected for monitoring based on their propensity to contribute
to the country's pollution problem is Hungary. In Hungary, industrial emissions contribute
approximately 40-45 percent of the country's air: pollution. As a result, Hungary has
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Self-monitoring, Reporting, and Recordkeeping Requirements
targeted incinerators of commercial and communal waste under its category of stationary
sources.2 Both the United States air and water programs impose source self-monitoring
requirements through regulations that address specific categories of industries (See, 40
C.F.R. Part 60, and 40 C.F.R. Part 401, et seq.) (See Appendices A-l, A-2).
Not all of the countries reviewed specify the categories of entities subject to source self-
monitoring requirements on a program-by-program basis. The United Kingdom has recently
revised its environmental programs to address a common set of activities/entities. The
United Kingdom has chosen to control "pollution of the environment"3 through Integrated
Pollution Control of prescribed processes and substances.4 The prescribed substances are
divided into lists according to whether they are released into the air, water, or land. The
prescribed processes have been identified as the most potentially polluting or technologically
complex industrial processes throughout England and Wales. These prescribed processes are
listed in Exhibit 3-2.
Exhibit 3-2. Prescribed Processes Under United Kingdom Integrated Pollution Control
Fuel and Power Industry
Combustion (> 50 megawatts) Boilers and Furnaces
Gasification
Carbonization
Combustion (remainder)
Petroleum
Waste Disposal Industry
Incineration
Chemical Recovery
Waste Derived Fuel
Mineral Industry
Cement
Asbestos
Fibre
Glass
Ceramic
Chemical Industry
Petrochemical
Organic
Chemical Pesticide
Pharmaceutical
Acid Manufacturing
Halogen
Chemical Fertilizer
Bulk Chemical Storage
Inorganic Chemical
Metal Industry
Iron and Steel
Smelting
Non-ferrous
Other Industry
Paper Manufacturing
Di-isocyanate
Tar and Bitumen
Uranium
Coating
Coating Manufacturing
Timber
Animal and Plant Treatment
2 "Hungary," BNA International. End. Rep. (May 1994), p. 162.
3 Section 1(3) of the United Kingdom's Environmental Protection Act of 1990.
4 The Environmental Protection (Prescribed Processes and Substances) Regulations 1991 specifically
defines the prescribed substances.
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Self-monitoring, Reporting, and Recordkeeping Requirements
3.3.3 Imposing Source Self-Monitoring Based on Specific Pollutants
Pollutants may also define which entities must conduct self-monitoring and keep up-to-date
with reporting and recordkeeping requirements. For example, The Netherlands has set
ambient-based standards for sulphur dioxide and particulates, nitrogen oxide, and carbon
monoxide and smoke. Based on sources that emit these pollutants, approximately 350 plants
fall under the requirements of The Netherlands' Air Pollution Act.5 As discussed above, the
United Kingdom's Integrated Pollution Control also uses pollutants, in concert with industrial
process, as a second criterion for imposing environmental regulation, including self-
monitoring requirements. The Irish EPA requires facilities to prepare a Pollution Emission
Register of the most environmentally significant chemicals used on-site. This includes an
inventory of all chemicals used and a prioritization of the chemicals to determine which ones
warrant a detailed mass balance study.
Another example of this approach as implemented hi the United States is the Toxic Release
Inventory, required under the Emergency Planning and Community Right-to-Know Act (42
U.S.C. §11001-11050). Under this program, specified industrial facilities are required to
report environmental releases of specified toxic chemicals.6 These data are compiled in a
national data base, known as the Toxic Release Inventory.
Finally, the chemical and toxic substance area may be viewed as imposing source self-
monitoring based on pollutants, because the monitoring and reporting requirements imposed
under these programs are linked to specific chemical substances.
Dr. Lucas Bergkamp, "Dutch Environmental Law: An Overview of Recent Trends," BNA International.
End. Rep. (February 24, 1993), p. 145. :
Note that the Toxic Release Inventory reporting is also premised on facility size and the amount of toxic
materials managed — which reflects how these factors are often combined within environmental
programs. However, the primary criterion for determining reporting requirements is the specific
chemical released.
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Self-monitoring, Reporting, and Recordkeeping Requirements
4 SELF-MONITORING REQUIREMENTS
4.1 GENERAL DESIGN FACTORS
General factors to consider when designing or enhancing a source self-monitoring program
under any environmental program include:
Parameters - After regulated processes, activities, or entities have been identified,
typical parameters generated (i.e., types of pollutants) and the characteristics of those
parameters are determined. Characteristics (that is, toxicity to human health and the
environment) of the parameters in air emissions, wastewater discharges, or releases to
land and whether there are national, regional, or local standards for the parameters
must be considered when designing a self-monitoring program.
Mass of Parameters Released - The potential impact of any release is related to the
quantity as well as the toxicity of the parameter. Thus, in designing a self-monitoring
program, the potential size of the release from the specific process or entity is often
considered. This is why countries often have increased self-monitoring requirements
for processes with a higher production or design capacity and consequently higher
parameter releases.
Monitoring Techniques - Available techniques for quantifying parameters in releases
to the environment must be considered. The selection of monitoring techniques in a
self-monitoring program may be affected by detection limits and suitability for
particular sample matrices.
The application of these general factors in specific self-monitoring programs for air
emissions, wastewater discharges, drinking water supplies, and releases to land are discussed
in the following sections.
4.2 SELF-MONITORING REQUIREMENTS FOR AIR PROGRAMS
This section discusses parameters, monitoring techniques, and self-monitoring frequencies
applicable in the design of self-monitoring requirements for air programs. This section also
includes examples that illustrate how countries have used design factors presented in Section
4.1 in developing their specific air emissions self-monitoring programs.
4.2.1 Parameters
Parameters are generally regulated and included in self-monitoring programs because of their
adverse effects on human health and the environment. Characteristics of typical air
parameters and the rationale for their inclusion in air self-monitoring programs are described
in Exhibit 4-1. Exhibit 4-2 presents the parameters monitored in selected countries' air self-
monitoring programs.
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-1. Air Parameter Characteristics and Rationale for Requiring Self-Monitoring
Sulfur Dioxide (SO2) is a pungent, colorless gas that is formed primarily by the combustion of sulfur-
containing fossil fuels. Compared to air, the gas is quite heavy. Sulfur dioxide is a major air pollutant that
is unhealthy for plants, animals and humans, and is corrosive to structural materials. It is one of the two
constituents in air that is responsible for the acid rain problem that exists in parts of the world (the other
constituent being NOX).
Carbon. Monoxide (CO) is a colorless, odorless, very toxic gas produced by any process that involves the
incomplete combustion of carbon-containing substances. Carbon monoxide is found in exhaust gases from
both mobile and stationery sources that burn fossil fuels.
Nitrogen Oxides (NOJ are gases formed primarily from atmospheric nitrogen and oxygen when combustion
takes place at a high temperature and with an excess of oxygen [compared to the theoretical (stoichiometric)
requirement for complete combustion of the fuel]. The nitrogen oxides composing NOX are nitric oxide
(NO) and nitrogen dioxide (NO2). Nitric oxide is generally the predominant nitrogen oxide in combustion
exhaust gas, but after discharge to the atmosphere, it is oxidized further to the more toxic and acidic
nitrogen dioxide. Nitrogen dioxide contributes to acid rain and is responsible for the reddish brown color of
polluted air. Upon photochemical reaction with certain volatile organic fumes, nitrogen dioxide forms
oxidants that lead to dangerous levels of highly toxic ozone in the lower troposphere (where most flora and
fauna exist).
Volatile Organic Compounds (VOCs) are those organic compounds that participate in atmospheric
photochemical reactions that form ozone. If a monitoring technique for total organic compounds also
measures nonreactive organic compounds, these nonreactive compounds may be excluded when determining
compliance with a standard.
Metals: There are a considerable number of toxic metals that may occur as solid compounds, and thus as a
portion of the particulate matter that may be emitted to the atmosphere. Only mercury is stable enough and
has a sufficient vapor pressure to occur hi elemental form as an air emission. Other metals occur primarily
as oxides, carbonates, sulfates, or in combination with silicon or aluminum as silicates or alluminates.
Particulate Matter (PM) is any material, except water hi uncombined form, that is airborne and exists as a
liquid or solid at standard conditions of temperature and pressure. In some regulatory jurisdictions PM10,
which is that portion of PM loading hi an air emission that is equal or less than ten microns in equivalent
diameter, is the regulated parameter. PM having an equivalent diameter of more than ten microns (PM10) is
apt to fall to earth quickly and less likely to be drawn into the human respiratory system. PM10 is more
likely to enter the respiratory system where any toxic components can enter the blood system relatively
easily. (The United States also regulates PM2.5 pollution).
Opacity can be defined as the degree to which emissions reduce the transmission of light and obscure the
view of an object in the background. Zero opacity represents 100 percent transmission of light, whereas 100
percent opacity represents zero transmission of light. In many jurisdictions, emissions of 20% opacity are
the maximum permissible, but the allowable value may, in some circumstances, be as low as 0-5%.
Although somewhat related, the PM and opacity parameters are not identical. Intuitively one would suspect
that the greater the PM value in a given air emission, the greater the opacity and this is qualitatively correct.
However, the relationship is not necessarily linear or quantitative.
Hydrogen Chloride (HCl) in air emissions normally exists as an aqueous compound dissolved hi water
vapor. HCl may have acute health effects and can cause damage to structural materials.
4-2
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
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4-3
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
4.2.2 Monitoring Techniques
Techniques for monitoring air emissions include: continuous emissions monitoring; periodic
monitoring (that is, stack sampling followed by chemical and/or physical analysis); surrogate
monitoring; visual or olfactory monitoring and process material balances. Descriptions of
these air monitoring techniques, including advantages and disadvantages, are presented in
Exhibit 4-3. The specific monitoring technique used in a self-monitoring program will vary
depending on certain factors, such as parameters monitored, available technology, and the
type of data needed (for example, precise data to determine compliance or data to be used as
early indication of a problem).
Exhibit 4-4 contains a summary of monitoring techniques commonly used for parameters
typically monitored hi air emissions. Additional information on each of the analytical
methods is briefly discussed in the glossary. Although not discussed in this document, it is
important to note that there are problems such as interference associated with some of the
analytical techniques. Self-monitoring requirements established in regulations generally state
that analyses must be performed using specified techniques (discussed in Section 6.1).
4.2.3 Monitoring Frequencies
In general, required self-monitoring frequencies are based on several factors including type
and size of facility, type and concentration of emission parameters, and mass flow. Required
self-monitoring frequencies are also affected by limitations of monitoring techniques. For
example, technology is available to conduct continuous monitoring of CO, SO2, NOX, and
opacity but is not generally available to conduct continuous monitoring of all types of volatile
organic compounds. The Irish EPA has implemented a pilot program of continuous
monitoring of emissions through the Internet so that the Agency can access continuous
emission data at any time.
Exhibit 4-5 contains information on frequencies of self-monitoring hi selected countries' air
programs. Selected country examples illustrating how these design factors are used are
provided following Exhibit 4-5.
4-4
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-3. Monitoring Techniques for Air Emissions
Continuous
emissions monitoring
Based on several different technologies, all incorporating three basic systems:
sampling, monitoring or analyzing, and data acquisition and reporting/handling.
Extractive (use of a sampling probe to remove and transport a gas sample to a
remote analyzer) or in-situ (no remote analyzer, directly monitor and sample the gas
within the stack or duct).
Requires the largest up-front capital expenditures, possibly exceeding an outlay of
several hundred thousand U.S. dollars.
Eliminates hazards associated with manual stack sampling, provides accurate
emissions data hi real time, and if incorporated into the process central system, can
improve and stabilize process control efficiency.
Is only available for certain pollutants.
Several countries explicitly name continuous emissions monitoring as the monitoring
technology of choice.
Periodic sampling
(including stack
sampling)
Most labor intensive, requires skilled technicians or engineers (sometimes working
under onerous weather conditions on outside stack platforms).
Sampling protocols are precisely described and must be adhered to; sampling
equipment is also generally complex and must be precisely designed and operated.
The proper capture and transport of samples to a laboratory is also strictly dictated
by protocol. Problems that may be encountered include sample degeneration,
adsorption onto the sample container, and sample contamination by the container.
If properly carried out, probably the most accurate means for determination of
particulates and metals, and possibly also for volatile organic compounds in some
processes during periods of operational stability.
Surrogate
Used to indicate relative performance and/or process variation, data not used to
demonstrate compliance with a specific numeric emissions limit.
For process, measurements of parameters such as feed rate or production rate, flow
rate, pressure, temperature at thermal dryer outlet. For control devices,
measurements of parameters such as afterburner combustion temperature, carbon
adsorber stream flow and bed temperature, emission capture system flow rate and
exhaust ventilation rate.
Visual or olfactory
Most basic form of monitoring and very inexpensive.
Limited usefulness because of subjectivity. Good for early indication of problems of
"nuisance" parameters of smoke and smell.
Process material
balance
Relatively inexpensive means of assessing air emissions.
Particularly useful for volatile organic compounds in certain printing or coating
operations where volatile organic compounds may not be completely evaporated
from the inks or coatings applied at the production unit. These volatile organic
compounds may evaporate slowly and over extended periods of time during storage
and shipping.
4-5
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-4. Monitoring Techniques Applicable to Air Emissions and Analytical
Methods for Manually Obtained Stack Data
Samples
Continuous
Emissions
Monitoring
(CEM)
Other
Monitoring
Methods
Analytical
Methods
Applicable
to Samples
Non-Dispersive Infrared
Spectroscopy
Ultraviolet Absorption
Fourier Transform Infrared
Spectroscopy
Infrared Absorption
Chemiluminescence
Visible Light Transmission
Tribo-electric Effect
Atomic Absorption
Spectroscopy
Stack Sampling
Process Material Balances
Algorithms
Atomic Absorption
Spectroscopy
Mass Spectroscopy
Flame lonization Detector
Photoionization Detector
Inductively Coupled Plasm
High Pressure Liquid
Chromatography
Environmental Protection
Agency Method 5 or
Equivalent
Parameter
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4-6
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
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4-7
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
The Netherlands. The Netherlands has a fairly sophisticated method for determining the
type of self-monitoring required for air emissions. The Netherlands program is primarily
based on two design factors: the type of parameter and the mass of parameter released. The
Netherlands Emissions Regulations set out the following required forms of "inspection"1:
• No fixed inspection obligation,
• Regular inspection of the functioning of control devices,
• Separate monitoring of emission-relevant parameters at an appropriate frequency,
• Monitoring of emission-relevant parameters, and
• Continuous emissions monitoring.
The required inspection regime applied to each regulated source is determined by the ratio of
mass flow (usually treated) permitted under the license to the "mass flow check level" for
specific parameters set out in the regulations. As an example, a facility has been licensed for
a total mass flow of 500 gram/hour of particulates and the mass-flow check level for
particulates is 1000 grams/hour (Ratio = 500/1000 =.5). Using the guidance in Exhibit 4-
6, this entity would be required to regularly inspect equipment functioning. Monitoring of
emission-relevant parameters is required where equipment sensitive to malfunctions is
involved. A summary of the mass-flow check levels in the Netherlands Emissions
Regulations for various parameters is included in Appendix B-l.
Exhibit 4-6. The Netherlands Guidance for Type and Frequency of Air Monitoring
Inspection
regime
Ratio of permitted mass flow to
mass flow check level
Range of inspection options
0.00
No fixed inspection obligation, or where equipment
sensitive to malfunction is involved, regular inspection of
equipment functioning.
Regular inspection of equipment functioning, or where
equipment sensitive to malfunction is involved,
monitoring of emission relevant process parameters
emission-relevant parameters.
K..<2
Monitoring of emission-relevant parameters, or separate
monitoring with a frequency of at least once in three
years, or in exceptional cases, regular inspection of
equipment functioning may suffice.
1 The term "inspection" when used in this context does not refer to an inspection performed by the
regulatory authority. Rather inspection and monitoring refers to the assessment of emissions, emission-
relevant parameters and/or the operation of control devices that are required as part of the license with
respect to air emissions.
4-8
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Inspection
regime
3
4
Ratio of permitted mass flow to
mass flow check level
2<..<5
5<..
Range of inspection options
Monitoring of emission-relevant parameters, or separate
monitoring with a frequency of at least once a year, or
in the case of heavy fluctuations in emissions, where
necessary, continuous measurement.
Monitoring of emission-relevant parameters, or
continuous monitoring, or in exceptional cases, separate
monitoring with a frequency of at least twice a year.
Germany. Germany's requirements for air emissions monitoring are found in the
Administrative Regulation on Air Conservation and are shown in Exhibit 4-7. Germany's
program is also based on the type of parameter and amount of parameter released.
Continuous monitoring is required when levels for certain parameters (for example, SO2,
NOX, CO) are exceeded. Regular (for example, daily monitoring) is required for
carcinogenic and toxic substances (for example, benzene and cadmium) when particular
levels are exceeded. In all other cases, monitoring is required when the plant starts
operations and every three years thereafter. In addition, there are supplementary monitoring
regulations for 13 heavy metals and nonmetallic,elements and for random monitoring of
dioxins and furans (not shown hi Exhibit 4-7).
Exhibit 4-7. Germany's Administrative Regulation on Air Conservation
Emission standards
for:
35 inorganic
compounds; 150 organic
compounds; and 23
carcinogenic compounds
Continuous monitoring
if emission fluxes are
exceeded for:
- Dust
- SO2, CO, HC,
NOx, HF, C,
C12, H2S
(for example, SO2 flux
>50 kg/h)
Regular monitoring
(for example, daily)
for carcinogenic and
highly toxic
compounds,
if fixed emission fluxes
are exceeded
(for example, benzene
>250 g/h)
Otherwise (every three
years, 4-6 half hour
averages)
4.3 SELF-MONITORING REQUIREMENTS FOR DRINKING WATER
PROGRAMS
This section discusses general design factors associated with designing or enhancing a self-
monitoring program for drinking water. It then provides examples that illustrate how
selected countries use these design factors in their current programs.
4-9
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
4.3.1 Parameters
Generally, parameters are included in drinking water self-monitoring programs because of
their potential for adverse effects on human health. Characteristics of typical drinking water
parameters and the rationale for their inclusion in self-monitoring programs are described in
Exhibit 4-8. Exhibit 4-9 presents the parameters monitored in selected countries' drinking
water programs.
4-10
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-8. Drinking Water Monitoring Parameters and Associated Rationale for
Monitoring
Microbiological. Water contains many microbes including bacteria, viruses, and protozoa. Some of these
organisms are harmless but others can cause disease if present in drinking water supplies. Common
diseases include gastroenteritis, typhoid, dysentery, hepatitis, and giardiasis. Disease causing
microorganisms (often associated with human or animal feces) are difficult to detect in drinking water.
Therefore, monitoring for an indicator organism (a microorganism whose presence is evidence that the
water is contaminated with human or animal feces) is often conducted instead. Coliform bacteria and fecal
streptococci are two common indicator organisms. Both are excreted hi large numbers by humans and
other warm-blooded animals. The presence of these indicator organisms in drinking water supplies indicate
fecal contamination and the possible presence of disease causing microorganisms.
Inorganic Chemicals. Inorganic chemicals include metals, nitrate/nitrite, chlorides, sulfate, fluoride, and
hardness.
Metals. Toxic metals are capable of causing a variety of human health problems. For instance, health
effects related to the consumption of too much lead include impaired blood formation, anemia, brain
damage, increased blood pressure, premature birth, low birth weight, and nervous system disorders.
Young children are especially at risk from high levels of lead in drinking water.
Nitrate/Nitrite. Although adults can consume large quantities of nitrates with no adverse effects, ingestion
of excessive nitrate may cause methemoglobinemia in infants, particularly in those under three months old.
The nitrate is reduced to nitrate in the infant's intestine. Nitrite absorbed into the blood can interfere with
oxygen transfer.
Chlorides. Chlorides may cause off-taste and add to total dissolved solids and scale in drinking water
distribution systems. The presence of chlorides may also indicate contamination.
Sulfate. High levels of sulfate can have a laxative effect.
Fluoride. The correct concentration of fluoride in drinking water can help prevent tooth decay. However,
excessive amounts of fluoride cause mottling (stained spots) on teeth.
Hardness. The major constituents of hardness are calcium and magnesium. Hardness causes scale.
Synthetic Organic Chemicals. Drinking water may contain trace amounts of toxic organic chemicals.
Toxic organic chemicals including pesticides, solvents, polychlorinated biphenyls, and dioxins are cancer-
causing substances and can also cause other chronic health effects.
Trihalomethanes. Trihalomethanes can result from the chlorine used in disinfection interacting with
organic substances present in water supplies. Chloroform, bromodichloromethane, dibromochloromethane,
bromoform, and dichloroiodomethane have been detected in drinking water supplies, particularly treated
surface waters. Some trihalomethanes such as chloroform have been demonstrated to be carcinogenic to
laboratory animals.
Volatile Organic Compounds. Some volatile organic compounds are carcinogens (for example, vinyl
chloride) or mutagens. Phenols impart objectionable taste and odor at low concentrations. The toxicity of
phenols varies, depending on chlorination of the phenolic molecule.
4-11
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-8. Drinking Water Monitoring Parameters and Associated Rationale for
Monitoring (continued)
Radionuclides Radioactivity in drinking water can be from natural or artificial radionuclides.
Radionuclides are radioactive isotopes that emit radiation as they decay. Radium, uranium, and radon are
significant in drinking water. All of these occur in nature. Ingestion of uranium and radium in drinking
water may cause cancer of the bone or kidney. Radium and uranium enter the body through ingestion
while radon (a gas) is usually inhaled after being released into the air during showers and baths.
Radionuclides in drinking water occur primarily in ground water systems. Naturally occurring
radionuclides are seldom found in surface waters.
Corrosivity. Corrosion products are unappealing, cause deterioration of water systems, and may have
health effects. In addition, corrosive water can have an unappealing taste and odor.
Other. Other parameters typically monitored hi drinking water include the following:
Turbidity is the interference of light passing through water and is caused by insoluble particles.
Turbidity in drinking water supplies can cause interference with disinfection, interfere with coliform
testing, and act as a food source for microorganisms.
Color may indicate the presence of dissolved organics, which may lead to trihalomethane formation.
Color also causes aesthetic problems.
Presence of an odor makes water unappealing to drink and may indicate contamination.
Water with a pH of less than 6.5 is corrosive, water with a pH of greater than 8.5 will form scale
and cause water to taste bitter.
Alkalinity is a measure of a water's capability to neutralize acids. Bicarbonate, carbonate, and
hydroxide ions are the primary contributors to alkalinity. Alkalinity is a measure of water's
capacity to absorb hydrogen ions without significant pH change.
4-12
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
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4-13
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
4.3.2 Monitoring Techniques
Techniques for sampling drinking water include grab and composite sampling. Description
of these monitoring techniques, including advantages and disadvantages, are presented in
Exhibit 4-10.
Both grab and composite samples can either be collected manually or with automatic
samplers. Manual sampling requires less equipment but is labor intensive. Automatic
samplers require less time but are costly and require maintenance. For certain parameters
(for example, pH and flow), continuous monitoring may be conducted.
Exhibit 4-10. Sampling Techniques for Water Samples
Composite samples
Samples collected over time (either by continuous sampling or by combining
individual grab samples)
Reflect average characteristics of water supply or waste stream during the sample
period
Useful in determining average characteristics of water supply or waste stream,
particularly if parameter concentrations or flows are variable
Flow Proportional: Volume of samples collected is proportional to water flow at
time of sampling. Flow proportional samples can be obtained by collecting
various sample volumes at equal time intervals or by collecting a constant sample
volume per unit flow
Time proportional: Consist of constant volume sample aliquots collected in one
container at equal time intervals.
Grab samples
Individual samples generally collected over a period of time not exceeding 15
minutes.
Represent the water or waste stream only at the time the sample is collected and
may be appropriate for batch discharges, constant conditions, screening for specific
parameters, or when extreme conditions such as high pH are characteristic of the
water supply or waste stream.
May be appropriate for parameters that tend to change or decompose during a
period of composting (for example, pH, cyanide, total phenols, volatile organic
compounds).
May be appropriate for oil and grease samples since oil and grease tend to adhere
to sampling equipment
4.3.2.1 Analyses
Many parameters are unstable and may alter in composition prior to analysis. To ensure that
samples remain representative, they should be analyzed as soon as possible after collection.
4-14
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Certain parameters, such as pH, are often analyzed in the field. If immediate analysis is not
possible, samples should be preserved to minimize the changes in parameter concentrations
between collection and analysis. Preservation methods include cooling, pH adjustment, and
chemical fixation. Even properly preserved samples should be analyzed within certain
holding tunes. Holding tunes depend on the pollutant being analyzed.
The complexity of analytical methods available range from simple test kits to complex
instruments, such as gas chromatography/mass spectrometry (GC/MS). Field test kits have
been developed for a wide range of sample analyses (including metals) and provide a
relatively inexpensive alternative to laboratory analysis. Analytical methods used should be
appropriate for the sample matrix and for the parameter being analyzed and should provide
the desired result. For example, analytical methods used for solid wastes should not be used
for drinking water analyses. Many countries require regulated facilities to perform analysis
using specified standard sampling and analysis procedures or methods.
The method detection limit is also an important consideration. It is important to use
analytical methods with detection limits significantly lower than the adverse effect level being
managed. For example, both flame ionization and graphite furnace atomic absorption
spectrophotometry can be used for metals analysis. However, graphite furnace atomic
absorption generally can detect parameters in lower concentrations than flame ionization.
Therefore, graphite furnace may be the preferred method if the metals concentrations are
relatively low. The analytical method used should achieve detection limits low enough to
adequately characterize the sample in relation to applicable limitations. For example, if the
drinking water limit for lead is 0.05 mg/1, the analytical method used should achieve a
detection level at least as low as 0.05 mg/1.
4.3.2.2 Costs of Sample Collection and Analysis
The cost of analysis varies, depending on the parameter being analyzed and the analytical
method chosen. Generally, the cost of analysis increases with increasing complexity of
analysis and analytical equipment needed. Costs also increase as detection limits decrease.
Exhibit 4-11 provides a summary of the relative cost of analysis for different parameters
commonly monitored.
4-15
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-11. Relative Cost of Analysis
Parameter
Metals:
Test Kit
Atomic Absorption
Volatile/Synthetic Organics
Gas Chromatography
Gas Chromatography/Mass
Spectrometry
Phenols
Biochemical Oxygen Demand
Chemical Oxygen Demand
Total Suspended Solids
Coliform
pH
Turbidity
Oil and Grease
Radionuclides
Whole Effluent Toxicity
Low
^
^
/
/
/
/
^
Moderate
/
/
/
/
High
/
/
/
4.3.3 Monitoring Frequencies
Drinking water self-monitoring frequencies are generally based on factors such as the
regulated parameter, population served by the drinking water system, and the drinking water
source (that is, ground or surface water).
Exhibit 4-12 provides information on the monitoring frequencies in the drinking water
program for several countries. Selected country examples that illustrate how these factors
are used are provided following Exhibit 4-12.
4-16
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
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4-17
August 1998
-------
Self-monitoring, Reporting, and Recordkeeping Requirements
United Kingdom: Self-monitoring is required at supply points and at consumer taps.
Required self-monitoring frequencies for the different regulated parameters are based on
the volume of drinking water distributed for domestic and food production purposes.
Three levels of self-monitoring frequencies may be imposed: 1) reduced, 2) standard,
and 3) increased. Reduced self-monitoring frequencies for certain parameters differ
depending on whether ground water or surface water is used. Frequencies based on the
criteria described above range from one to 365 samples per year. An example frequency
table for drinking water monitoring is provided in Appendix C-l.
United States: Self-monitoring frequencies for microbiological parameters are based on
the population served by the system. Self-monitoring frequencies for other regulated
parameters may vary depending on whether ground water or surface water is used.
Monitoring frequencies range from once every three years to 500 samples monthly.
Frequencies may be reduced after initial monitoring if parameters are not detected, or are
detected only at very low levels, well below adverse effects levels. Resampling at
increased frequencies may be required if analytical results indicate that a violation has
occurred.
Hungary: Hungary requires self-monitoring of various parameters (e.g., microbiological,
inorganic, synthetic organic, radionuclides, and other specified parameters) on a weekly
basis. Self-monitoring is required for large water companies on a daily basis.
4.4 SELF-MONITORING REQUIREMENTS FOR WATER PROGRAMS
This section discusses general design factors associated with designing or enhancing a self-
monitoring program for water. It then provides a comparison of how selected countries use
these design factors in their current programs.
4.4.1 Monitoring Parameters
Parameters are included in water self-monitoring programs because of their potential for
adverse effects on water bodies (e.g., streams, lakes, rivers) including aquatic life and on
human health of people using the water body for recreational purposes or as a drinking water
supply. Specific parameters and the associated rationale for their inclusion hi self-monitoring
programs, are described in Exhibit 4-13. Exhibit 4-14 presents the parameters monitored hi
selected countries' water programs.
4-18
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-13. Parameters Monitored in Water Programs
Biochemical Oxygen Demand/Chemical Oxygen Demand. Soluble organics such as Biochemical Oxygen
Demand cause depletion of dissolved oxygen in the receiving water. The Biochemical Oxygen Demand test
measures the biodegradable organic carbon present in the wastewater. By definition, Biochemical Oxygen
Demand is the quantity of oxygen required for the stabilization of the oxidized organic matter present after
five days of incubation at 20°C. The Chemical Oxygen Demand test measures the total organic carbon
except for certain aromatic compounds. Since the Chemical Oxygen Demand test utilizes an oxidation-
reduction reaction, other reduced substances, such as sulfides, sulfites, and ferrous iron, will also be
oxidized and reported as Chemical Oxygen Demand.
Suspended Solids. Sedimentation of suspended solids can cause a buildup of decomposing organic matter
in sediments, resulting in oxygen depletion. Suspended solids also interfere with light transmission and
thus photosynthetic activity.
Coliform. The presence of coliform bacteria may indicate inadequate disinfection of wastewater prior to
discharge.
Residual Chlorine. Chlorine disinfection of wastewater results in residual chlorine. Chlorine is highly
toxic to aquatic life.
pH. Maintaining a certain pH of surface waters protects aquatic life and controls adverse chemical
reactions such as the dissolution of metal ions. In addition, the toxicity of some substances is affected by
pH.
Dissolved Oxygen. Maintaining adequate dissolved oxygen concentrations in receiving water protects
aquatic life, enhances recreational use of the water, and reduces odors due to decomposition of organic
matter.
Ammonia. Dissolved ammonia can contribute to oxygen depletion by nitrification. Un-ionized ammonia is
also highly toxic to aquatic biota.
Oil and Grease. The presence of oil and grease may cause aesthetic, health, and environmental problems
in the receiving water.
Toxics Pollutants. Metals, phenols, volatile organic compounds, cyanide, pesticides, and polychlorinated
biphenyls may be toxic to aquatic life and may pose human health problems. Volatile organic compounds
may also cause air pollution problems.
Whole Effluent Toxicity. Toxicity is a characteristic: of a substance or group of substances that causes
adverse effects in organisms. Adverse effects include increased morbidity (the rate of occurrence of
disease), and mortality (the rate of occurrence of death), as well as effects that limit an organism's ability
to survive in nature, such as impaired reproductive ability. Toxicity of a substance is measured by
observing the responses of organisms to increasing concentrations of that substance. Whole Effluent
Toxicity is designed to evaluate the toxicity of the entire waste stream and not individual pollutants. Whole
Effluent Toxicity tests are techniques to determine the toxicity of water or effluent by measuring the
responses of organisms to solutions containing various percentages of effluent and dilution water. Whole
Effluent Toxicity testing is useful in assessing environmental hazards, especially where the mix of potential
problems is complex. Quantitative analytical tests cannot demonstrate the interaction of chemicals and are
not sensitive to variabilities such as acidity, hardness, solubility, or the effects on living organisms. Whole
Effluent Toxicity testing integrates these variables and can indicate when chemicals have reached toxic
levels even if the identity of the chemical is unknown.
4-19
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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4-20
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
4.4.2 Monitoring Techniques
The monitoring techniques applicable in water programs are the same as those hi drinking
water programs. Refer to Section 4.3.2 for a discussion of monitoring techniques and
associated issues.
4.4.3 Monitoring Frequencies
Required self-monitoring frequencies for water discharges from entities may be based on
several factors, including the type of entity (that is, specific processes and operations), the
parameter being monitored, the size of the entity, the variance of the parameter being
monitored, the degree of "change" resolution required, and the environmental and human
health risk being managed. Exhibit 4-15 presents a comparison of monitoring frequencies hi
water programs for selected countries. In some countries, the frequency may increase in
cases where limits have been exceeded, and decrease hi cases where the regulated parameters
have not been detected for a defined period of tune (see Canadian example below). In
Hungary and The Netherlands, the frequency varies depending on the entity's parameters and
can range hi The Netherlands from once a year to daily. In Norway, the frequency varies
and is specified in the permit, and, hi Ireland, the frequencies and parameters sought depend
on industry and the receiving environment.
The following are examples that illustrate how self-monitoring frequencies are established by
selected countries:
• Canada: Canada requires self-monitoring for pulp and paper manufacturers and metal
mining operations. Frequency of monitoring can range from continuously to monthly.
Pulp and paper mills are required to monitor biochemical oxygen demand three tunes a
week, total suspended solids daily, acute lethality weekly (using Daphnia magna) and
monthly (using rainbow trout), and pH, flow, and electrical conductivity continuously.
If a facility fails the monthly acute lethality test using rainbow trout, the test frequency
is increased to weekly. In addition, pulp and paper facilities are required to self-
monitor 2,3,7,8-TCDD and 2,3,7,8-TCDF during each month hi which the chlorine
bleach plant was operating. If no measurable concentrations are detected for three
months, the frequency is dropped to quarterly. The regulated facility may have a
qualified laboratory on-site to collect and analyze the samples or it may hire outside
contractors to collect or analyze the samples.
• United Kingdom: Non-Integrated Pollution Control dischargers to waters regulated by
the National Rivers Authority are not required to conduct self-monitoring. Instead, the
National Rivers Authority monitors consented dischargers and recovers the associated
costs through the Charging for Discharges Scheme. The frequency of National Rivers
Authority sampling varies and may range from quarterly to weekly. Self-monitoring
requirements for Integrated Pollution Control facilities are contained hi authorizations;
self-monitoring frequencies vary, depending on the type of facility.
4-21
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 4-15. Frequency of Self-Monitoring Requirements for Sampling
and Analysis in Water Programs1
Monitoring
Parameters
Biochemical Oxygen Demand
Chemical Oxygen Demand
Total Suspended Solids
Coliform
Residual Chlorine
pH
Dissolved Oxygen
Ammonia
Oil and Grease
Metals
Phenols
Organics
Cyanide
Pesticides
Polychlorinated Biphenyls
Whole Effluent Toxicity
Country
>
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1. This table applies only to those facilities that discharge directly to the environment.
2. Germany requires that all parameters be monitored as established in the permit or authorization.
3. The emitters determine the characteristic pollution compound of the industry, the frequency is very different.
4. This example was obtained from an integrated pollution control license granted by the Ireland Environmental
Protection Agency to a pharmaceutical manufacturer.
5. This includes all organic solvents in use in the process, which are likely through normal process operation to
be diverted to wastewater effluent streams.
6. Frequency varies for each industry, ranging from once a year to daily.
7. Frequency is as specified in the permit. In general, larger facilities will require proportional composite 24
hour samples and analysis.
8. Integrated Pollution Control: Monitoring is prescribed in authorizations and requirements are different for
different types of facility. Continuous monitoring is required in some cases. Non-Integrated Pollution
Control: National Rivers Authority does its own monitoring under new wastewater treatment regulations,
self-monitoring will be required for biochemical oxygen demand, chemical oxygen demand, suspended solids
(1 degree treatment only).
9. All pollutants limited in the permit must be monitored at least once annually.
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Self-monitoring, Reporting, and Recordkeeping Requirements
• United States: Certain types of facilities (based on facility processes and operations)
are required to obtain discharge permits that contain self-monitoring requirements.
The frequency of self-monitoring required may depend on the type and size of entity,
type of treatment used, discharge volume and characteristics, receiving stream
characteristics, and the entity's compliance history. At a minimum, all permitted
facilities are required to self-monitor once a year. Exhibit 4-16 illustrates possible
self-monitoring frequencies based on flow.
Exhibit 4-16. Self-Monitoring Frequencies in the United States Water
Program
Plant Capacity (Million Gallons Per Day)
0-0.099
0.1-0.99
1.0-4.99
More than 5.0
Self-Monitoring Frequency
Quarterly
Monthly
Weekly
Daily
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August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
5 ANALYSIS OF REPORTING AND RECORDKEEPING
REQUIREMENTS
5.1 INTRODUCTION
This section focuses on the reporting and recordkeeping requirements associated with self-
monitoring programs. From the regulatory agency's viewpoint, there are several important
reasons for establishing reporting requirements. The regulatory agency can:
• Ensure an entity is meeting its self-monitoring responsibilities.
• Determine the compliance status of an entity.
• Use the reported information to assist targeting efforts, identify problem areas
earlier, and collect information on specific entities, industries, or sectors.
In addition:
• Reporting acts as a deterrent to noncompliance.
• A facility identifies itself as being subject to specific regulations.
• Information submitted on compliance is much more extensive than could be
collected by an inspector at the site. ;
• Reporting compliance data to the regulatory agency directs the attention of higher
level facility management to achieving and maintaining compliance.
Recordkeeping requirements may also be incorporated into environmental compliance and
enforcement programs to ensure that specific information about a facility's operations or
releases is available for an extended period of time hi case it is required for an enforcement
action.
The following sections examine the general design factors to consider when developing or
enhancing a reporting program (Section 5.1) and compare the reporting requirements of
several countries (Section 5.2). Section 5.3 discusses general design factors for
recordkeeping and Section 5.4 compares recordkeeping requirements hi several countries.
5.2 REPORTING - DESIGN FACTORS
When designing or enhancing a reporting program, a regulatory agency must consider three
general design factors: 1) information needs, 2) reporting frequency, and 3) reporting
format.
5.2.1 Information Needs
The first and most important decision the regulator must make is: "What information do I
need from the regulated community?" In any self-monitoring program, information that
5-1
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
identifies a specific entity must be reported, including name, location, and any particular
facility identification numbers (for example, permit numbers, hazardous waste generator
identification number). In addition to this basic information, the ways of reporting
information may include:
• Report all self-monitoring data.
• Report only data/information in response to specific compliance situations or
occurrences.
• No reporting required, recordkeeping only.
The reporting requirements imposed by the regulatory agency depend primarily on the
ultimate end use of the reported data. If the end use of the data is to assist the regulator in
making compliance determinations, the reporting requirement may specify that all data from
self-monitoring be reported. This level of information will allow the regulatory agency to
make an accurate determination of compliance. It will also allow the regulatory agency to
determine if an entity is conducting all of the required self-monitoring, and thus, presents a
deterrence to noncompliance.
In some cases, reported data are used by the regulatory agency to identify and trigger follow-
up actions, such as compliance inspections, or to identify entities or industrial sectors that
require special attention (for example, compliance assistance). In these cases, it may only be
necessary to report data that relate to specific situations or occurrences, such as
noncompliance, exceptions, emergencies, or calamities. These reports notify the regulatory
agency there may be a problem and allow it to track the facility more closely and also to
respond to a threatening situation. In some situations, reporting may not be necessary and,
in these cases, the regulatory agency may only stipulate recordkeeping requirements.
5.2.2 Reporting Frequency
The end use of the reported data (that is, the purpose of collecting the data) determine the
frequency of reporting. The regulatory agency must ensure that the tuning of the reports
supports its purpose (for example, determining compliance, targeting for inspections). The
regulatory agency should determine how often it needs self-monitoring data to 1) achieve its
environmental compliance and enforcement goals and 2) effectively track an entity's
environmental trends and make accurate assessments of environmental performance, as well
as compliance status. Reporting frequency may be:
• Annually or at other fixed intervals (for example, semi-annually, quarterly,
monthly),
• In cases of noncompliance, exceptions, or other specific occurrences, and
• Immediately, in the case of emergencies or other calamities.
With fixed interval reporting, infrequent reporting may make it difficult for the regulatory
agency to make accurate assessments of an entity's environmental performance, as the
reports will not provide a cohesive, continuous picture of a facility over time. On the other
5-2
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
hand, reporting too frequently may result in unnecessary burdens on both the regulatory
agency and regulated entities and may also result in information being collected and
submitted that has little added value. The regulatory agency must ensure the reporting
intervals are appropriate to meet its goals. Interval reporting may also be dependent on an
entity's compliance history or size. Entities with good compliance records may not be
required to report as often as those with poor compliance records. Likewise, smaller entities
(both hi size and discharge amounts) may have less of a reporting burden.
Reporting in cases of noncompliance, exceptions, or other specific occurrences allows the
regulatory agency to be informed of all situations out of the normal course of events. This
enables the regulatory agency to take follow-up actions to ensure such a situation does not
occur again. Requiring that emergencies and other calamities be reported immediately will
ensure the regulatory agency is aware of threatening situations and has the ability to respond
immediately if necessary.
5.2.3 Reporting Format
The format of the reported data depends on two things—whether the data are 1) submitted in
electronic form or hard copy, or 2) submitted using a standardized format or form.
Countries that have developed, or are developing, electronic information systems may require
regulated entities to submit reports in a compatible electronic format. This will facilitate the
reporting process for both the regulated entity and the regulatory agency and will also
facilitate the regulatory agency's use of the data, as it will be more accessible and easier to
locate and retrieve. If electronic information management systems are not available, reports
can also be submitted in hard copy.
Another consideration is whether the format should be standardized (that is, mandated use of
specific forms). Standardized forms ensure that proper data are submitted and facilitate
review by the regulatory agency. Nonstandardized reporting may result in incomplete,
different, or incorrect data/information being submitted.
5.3 REPORTING - COUNTRY COMPARISON
The following sections compare several countries' reporting programs. Section 5.3.1
examines information needs, Section 5.3.2 provides information on reporting frequency, and
Section 5.3.3 discusses reporting format.
5.3.1 Reporting Information Needs
Exhibit 5-1 presents the information needs of several countries. Several of the countries
required entities to submit all data and data relating to specific occurrences. For example, in
5-3
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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5-4
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Canada, entities in the air program must report all self-monitoring data and also submit other
types of reports, including malfunction/breakdown reports, air pollution control equipment
reports, release reports, and compliance reports. The United States water program is
similar. Entities must submit all self-monitoring data hi Discharge Monitoring Reports and
must also submit noncompliance reports when permit limits for a specific parameter are
exceeded.
In both India and Norway, regulated entities are required to submit annual reports that
contain self-monitoring data for several different program areas. In India, all industries must
submit an annual report that includes information on:
• Water and raw material consumption,
• Pollution discharged to the environment through water and air emissions,
• Total hazardous and solid wastes from processes and pollution control facilities,
and
• Quantity of solid wastes 1) recycled or reutilized within the unit, 2) sold, or 3)
disposed.
The report also solicits information on the characterizations of hazardous and solid wastes,
disposal practices for the wastes, impact of pollution abatement measures on the environment
and production costs, additional measures or investments proposed for environmental
protection, and any other particulars for improving the quality of the environment.
Norway requires all industries regulated under the air, wastes (both hazardous and
nonhazardous), and water programs to submit a similar report. An example of India's report
is included as Appendix D-l.
5.3.2 Reporting Frequency
Exhibit 5-2 presents the reporting frequencies associated with self-monitoring requirements.
In both Canada and the United States, reporting frequency may vary depending on the type
of report and the compliance status of the entity. For example, in Canada, pulp and paper
mills are required to report self-monitoring data on acutely lethal effluent monthly. Self-
monitoring results for Biochemical Oxygen Demand and suspended solids must be reported
annually. In the United States, if an entity has a good compliance history, it may be
required to only report self-monitoring data semi-annually. However, entities with poor
compliance records may be required to report monthly.
5.3.3 Reporting Format
Exhibit 5-3 provides a country comparison of the type reporting formats used. Those
countries listed in both the standardized and nonstandardized columns currently use both
types of reporting formats hi the specific program area. One specific report may be
standardized, while another is not. The same is true for hard copy/electronic.
5-5
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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5-6
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 5-3. Reporting Format
Program Area
Air
Drinking Water
Solid
Nonhazardous
Waste
Hazardous Waste
Chemical/Toxic
Substance
Water
Multimedia
Standardized
Canada
Germany
India
Ireland
The Netherlands
Norway
United States
Germany
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Norway
India
The Netherlands
Norway
United States
India
Ireland
The Netherlands
Norway
United Kingdom
United States
Canada
Hungary
India
Ireland
The Netherlands
Norway
United Kingdom
United States
India
Ireland
Norway
Nonstandardized
Hungary
The Netherlands
United Kingdom
United States
Hungary
The Netherlands
Germany
The Netherlands
United Kingdom
United States
Hungary
The Netherlands
United Kingdom
United States
The Netherlands
Germany
The Netherlands
Hard Copy
Canada
India
Ireland
The Netherlands
Norway
United Kingdom
United States
Germany
Hungary
The Netherlands
Ireland
The Netherlands
Norway
United Kingdom
United States
Hungary
India
Ireland
The Netherlands
Norway
United Kingdom
United States
India
Ireland
The Netherlands
Norway
United Kingdom
United States
Canada
Hungary
India
Ireland
The Netherlands
Norway
United Kingdom
United States
India
Ireland
Norway
Electronic
United States
Canada
Those countries listed under both categories may require electronic submissions for specific
reports and only hard copy for others. It should be noted that several countries use
5-7
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
electronic systems to manage the data once they are reported. This may result in more
electronic reporting in the future. Electronic reporting is currently required in the United
States air program for utilities. Detailed information on such reporting is found in the
Appendix E-l.
5.4 RECORDKEEPING - DESIGN FACTORS
When designing or enhancing a recordkeeping program, a regulatory agency must consider
several general design factors, including:
• Why records should be kept by a regulated entity,
• What records should be kept, and
• What length of time should the records be retained.
Generally, records are kept to serve as a source of information in the event an enforcement
action is necessary or review of data is necessary at some later date. Historic data on self-
monitoring and reporting can be reviewed to help the regulatory agency determine the past
performance of an entity and to allow the regulatory agency to determine if past practices
and operations were appropriate and in compliance with environmental requirements. When
identifying the records that must be kept by a regulated entity, the regulatory agency must
ensure the data/information will be appropriate to meet its needs. In addition, the records
must be kept a sufficient amount of time to ensure the data are available if needed.
5.5 RECORDKEEPING - COUNTRY COMPARISON
Exhibit 5-4 compares the recordkeeping requirements across program areas of several
countries. Several of the countries have specific requirements for the types of records that
should be kept and the length of time they should be kept. Some of the countries that do not
have specific requirements written into their statutes and regulations (for example, India) may
have a clause that allows the head of the environmental agency to request information from a
regulated entity. To produce such information on request, most entities incorporate their
own system of recordkeeping. On average, the retention period for most records is 3 to 5
years.
In some instances, the recordkeeping requirements for regulated entities are specifically
spelled out hi permits or other types of operating authorization. In the United Kingdom's
water program, for example, recordkeeping requirements for Integrated Pollution Control
regulated facilities are spelled out in the authorization for that specific facility. Usually the
retention time for such records is 4 years for specified records and 1 year for operational
records. However, the tune frames are dependent on the specific authorization.
5-8
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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5-9
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
6 DATA QUALITY ASSURANCE, VERIFICATION, AND
MANAGEMENT
6.1 INTRODUCTION
There are generally two types of activities conducted to ensure the accuracy of self-
monitoring data: 1) data quality assurance activities, and 2) data verification activities. Data
quality assurance activities are conducted by a regulated entity to ensure self-monitoring data
are accurate. Data verification activities are conducted by the regulatory agency to ensure
self-monitoring data are accurate and representative. The following sections (Sections 6.1
and 6.2) examine general design factors associated with these two types of activities and
compare selected countries' programs. Section 6.3 of this chapter then discusses data
management methods and compares several countries' data management procedures and
systems.
6.2 DATA QUALITY ASSURANCE ACTIVITIES - DESIGN FACTORS
To ensure the accuracy of self-monitoring data, the regulated agency may require a regulated
entity to conduct various data quality assurance activities. There are several types of such
activities and the regulatory agency must determine which ones will result in data of the
highest quality. Activities the regulatory agency may require include:
Sampling and analyzing hi accordance with established techniques,
Conducting analysis using established laboratory practices,
Conducting analysis at certified laboratories,
Calibrating equipment hi accordance with established techniques,
Self-certifying monitoring data, and
Participating hi laboratory evaluations.
Any of the above activities, whether by itself or combined with others, chosen by the
regulatory agency will help ensure accurate and valid data are submitted by a regulated
entity. The activities selected will depend hi large part on the environmental policies and
procedures already developed within a specific country. For example, some countries may
not have established techniques for sampling or analysis or may not have certification
programs for laboratories.
6.3 DATA QUALITY ASSURANCE ACTIVITIES - COUNTRY COMPARISON
Exhibit 6-1 provides information on the various data quality assurance activities required
by selected countries. An example regarding data quality assurance activities hi The
Netherlands' air program is provided in Exhibit 6-2.
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August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 6-2. The Netherlands Air Program
Air emission measurements are carried out by an institution approved by the licensing authority and may be
the facility or entity itself. Measurements conducted for enforcement purposes (for example, repeat
measurements after emission standards have been found to have been exceeded) generally may not be carried
out by the facility or entity unless such facility is the only institution qualified or certified to conduct the
measurement and both the regulatory agency and the facility agree.
Measurements should be taken in accordance with procedures specified hi Standards, such as Nederlandse
Praktijkrichtlijnen (Practical Guidelines) (NPR), Nederlandse Voornormen (draft-standards) (NVN),
Nederlandse Normen [Dutch standards (NEN)], European standards (EN) or International Standards (ISO).
The standard methods are presented in Appendix B, page B-10. When there is no standard method, other
measuring techniques may be used.
The United States generally uses all of the various quality assurance activities in its various
environmental programs. For example, in its water program, sampling and analyses must
conform to approved test procedures established by the Environmental Protection Agency for
(1) biological parameters, (2) inorganics, (3) non-pesticide organics, (4) pesticides, and (5)
radiological parameters. It also contains the required containers, preservation techniques,
and holding times for the above parameters. Calibration and performance techniques also
must conform to the requirements established by the Environmental Protection Agency. Such
techniques have been established for all the parameters listed above.
In addition, self certification is required for all reports submitted by a facility in the United
States program. The report must be signed by an authorized person or their authorized
designee and must include a certification stating, under penalty of law, that the information
submitted is true, accurate, and complete. An example self-certification statement used in
the United States pretreatment program is shown in Exhibit 6-3.
Exhibit 6-3. Example of the United States Pretreatment Program Self-Certification
Statement
"I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for knowing violations."
6-3
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
6.4 DATA VERIFICATION ACTIVITIES - DESIGN FACTORS
To further ensure the quality of the reported self-monitoring data, regulatory agencies
conduct independent data verification activities. These activities may include:
• Analyzing duplicate or split samples,
• Inspecting the laboratories that are analyzing samples,
• Inspecting the regulated entities, including their sampling and analysis procedures, and
• Random, unprogrammed check monitoring.
When analyzing duplicate or split samples, the regulatory agency should require the regulated
entity to submit the split or duplicate samples for analysis. The regulatory agency can then
conduct its own analysis and compare the results with the results from the regulated entity.
Inspections of either laboratories or regulated entities will ensure the laboratories or regulated
entities are conducting the sampling and analysis hi accordance with established guidelines
and procedures. Any of these activities, or any combination of them, can help the
regulatory agency determine if the data being submitted by the regulated entity are complete
and accurate. The activities a regulatory agency selects primarily depend on its capabilities
and resources.
6.5 DATA VERIFICATION ACTIVITIES - COUNTRY COMPARISON
Exhibit 6-4 presents a comparison of the data verification activities conducted by selected
countries. In the United States, program-specific inspections (that is, of one media) can
often involve collecting samples for analysis and evaluating the regulated entity's sampling
and analysis procedures. Examples of the different types of inspections conducted in the
United States water program are shown hi Exhibit 6-5.
6-4
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 6-5. Types of Inspections in United States Water Program
Compliance evaluation inspections verify compliance with permit requirements and review overall
operation, maintenance, and sampling procedures.
Compliance sampling inspections include every component of the compliance evaluation inspection, but also
include sampling by inspectors to verify the facility's sampling.
Performance audit inspections include every component of the compliance evaluation inspection, but also
include an in-depth review of the facility's sampling procedures and a review of the laboratory that performs
the analyses.
Laboratory inspections are national performance evaluations conducted annually of all laboratories that are
used by major dischargers. In the evaluation, the Environmental Protection Agency prepares samples with
known constituents and concentrations and sends them to the major dischargers, who then ask their
laboratories to analyze the samples. The laboratories are asked to use the same personnel and methods they
use to conduct regular analyses for the discharger. The Environmental Protection Agency then compares the
results of the laboratories analyses with their own results.
6.6 DATA MANAGEMENT - DESIGN FACTORS
Self-monitoring and reporting requirements result in large volumes of data being transmitted
to the regulatory agency by the regulated entities. Because of these large volumes of data, it
is imperative that the regulatory agency have in place a system and procedures for managing
the data. When enhancing or developing a data management system for its self-monitoring
program, a country must consider certain factors, including:
• Current data management systems, and
• Public availability of the data in those systems.
Basically, there are two types of data management systems: 1) electronic and 2) hard copy
filing systems. Electronic systems make data review, manipulation, and retrievability easier,
but require more resources and expertise to develop and maintain. Hard copy filing systems
require large amounts of space (for filing cabinets) and create a large paper burden on the
regulatory agency.
Public availability is an important part of a self-monitoring program because it creates
another deterrent to noncompliance. By allowing the public to access the data, it can
monitor the environmental performance and compliance of a regulated entity.
6.7 DATA MANAGEMENT - COUNTRY COMPARISON
Exhibit 6-6 compares the data management procedures and public availability of data across
several countries and program areas. As shown in the exhibit, several countries now have
electronic data management systems in place or under development. For example, The
Netherlands is currently developing two data base management systems to manage its
environmental permitting and monitoring data. While the systems are under development, it
6-6
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
will continue to use its traditional means of data management. The United States hazardous
waste program manages data in the Biennial Reporting System, which is a national data base
that 1) provides an overview of the progress of the hazardous waste program by tracking
generation, management, and minimization, 2) assesses the impact of regulatory decisions,
and 3) provides data to develop waste capacity analyses. The system is updated every 2
years (biennially), as reports are submitted every 2 years. The states and the Environmental
Protection Area share the responsibility for ensuring the data quality of the system.
Automated data validation routines and manual assessment analyses are completed on the data
prior to public release. Information on several other United States data management systems
is located in Appendix F-l.
One way of giving the public access to self-monitoring data is to make the information in the
data bases available on computer diskette or by communicating with regulatory agency
computers through modems. The United States makes its data available through both
methods. In addition, the United States has in place the Freedom of Information Act, which
allows members of the public to request and receive information from the regulatory
agencies.
6-7
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 6-6. Data Management Procedures and Public Accessibility
Country
Germany
Hungary
India
Ireland
Mexico
The
Netherlands
Program Area
Air
Drinking Water
Solid Nonhazardous Waste
Water
Air
Drinking Water
Hazardous Waste
Water
Air
Hazardous Waste
Chemical or Toxic Substances
Water
Air
Solid Nonhazardous Waste
Hazardous Waste
Chemical or Toxic Substances
Water
Air
Air
Drinking Water
Solid Nonhazardous Waste
Hazardous Waste
Chemical or Toxic Substances
Water
Data Management Method
Paper Copy
/
/
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^
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^
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^
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^
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^
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Electronic
(data bases)
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^
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^
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Public Access to
Data
(Yes or No)
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
6-8
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Exhibit 6-6. Data Management Procedures and Public Accessibility
Country
Norway
United
Kingdom
United
States
Program Area
Air
Solid Nonhazardous Waste
Hazardous Waste
Chemical or Toxic Substances
Water
Air
Solid Nonhazardous Waste
Hazardous Waste
Chemical or Toxic Substances
Water
Air
Drinking Water
Solid Nonhazardous Waste
Hazardous Waste
Chemical or Toxic Substances
Water
Data Management Method
Paper Copy
/
/
/
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/
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v'
/
Electronic
(data bases)
/
^
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Public Access to
Data
(Yes or No)
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
1. Under development.
6-9
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
7 ENFORCEMENT OF SELF-MONITORING
REQUIREMENTS
7.1 INTRODUCTION
For self-monitoring to work effectively, such programs must achieve a high rate of voluntary
compliance. Ensuring such compliance entails tracking compliance with self-monitoring
requirements and enforcing such requirements where necessary.
7.2 TRACKING OF NONCOMPLIANCE WITH SELF-MONITORING AND
REPORTING REQUIREMENTS
Tracking noncompliance with self-monitoring and reporting requirements involves taking the
actions necessary to determine whether those industries, facilities, or people subject to self-
monitoring or reporting 1) have complied with their obligation to conduct the required
monitoring and, if necessary, submitted required monitoring data and 2) are in compliance
with the substantive environmental program requirements. For example, where determining
violations of groundwater protection standards is the issue of concern, tracking activities
should focus on ensuring that groundwater monitoring data are developed through sampling
and that such data are submitted where they indicate impermissible levels of contamination.
Tracking noncompliance with self-monitoring requirements is important because it serves as a
means of monitoring environmental compliance, provides the impetus for enforcement actions
where necessary, and deters facilities that would ignore either the self-monitoring provisions
or the more substantive requirements that the self-monitoring provisions track. Yet, the
importance of tracking such compliance will vary depending on the objective of the program
(for example, enforcement versus increasing awareness). Exhibit 7-1 shows examples of
programs that track non-compliance with self-monitoring and reporting requirements.
The United States Environmental Protection Agency has recently developed policies that go
as far as encouraging facilities to conduct self-audits and self-report violations in exchange
for reductions in penalties assessed for such violations. A second recent Environmental
Protection Agency policy also encourages small businesses to obtain assistance in
discovering and remedying violations, again in mitigation of penalties. Tracking
noncompliance with self-monitoring requirements is accomplished hi a variety of ways.
Tracking noncompliance with the monitoring or reporting requirement itself is accomplished
either by reviewing reported data as they are submitted (for data that must be reported at
established intervals) and evaluating records during inspections. With regard to determining
substantive violations, in many instances the data are collected and organized into a data
base. This is the case hi Norway, where self-monitoring data are managed hi a data base
that identifies the facility, specifies discharge limits, specifies violations registered through
self-reports, provides a summary of waste generation and discharge of pollutants, and
provides statistical results of authority controls. A description of Norway's environmental
data management system
7-1
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
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7-2 August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
INKOSYS is contained in Appendix J. Similarly, the United States employs numerous data
bases to aggregate self-monitoring and other compliance-related data. For example, the
Permit Compliance System, developed to track compliance with discharge permit limits
under the Clean Water Act, contains a variety Of self-monitoring data, including permit limits
and discharge monitor ing data. Another means of tracking noncompliance with self-
monitoring requirements involves routine review of such data by compliance staff.
Self-monitoring data that must be maintained pursuant to recordkeeping requirements are
normally tracked through inspections. In preparation for an inspection, inspection teams
review the recordkeeping requirements imposed on the facility so that required records are
addressed as part of the inspection. Such records may also be requested by the regulatory
agency to verify compliance or to help determine the need for follow-up inspections, or even
help support general targeting strategies for compliance activities. In some cases, facilities
are required to maintain records for a specified period (for example, 3 years) to preserve the
regulatory agency's ability to track compliance. In other cases, recorded data must submitted
as a report.
Nearly all of the countries reviewed that impose self-monitoring requirements track
compliance with these requirements. Canada, Norway, the United Kingdom, and the United
States all track compliance with self-monitoring requirements in every environmental
program under which such requirements are imposed. India indicated that it tracks such
requirements in its air, hazardous waste and water program areas.
7.3 NUMBER AND TYPE OF ENFORCEMENT ACTIONS TAKEN FOR
VIOLATIONS OF SELF- MONITORING AND REPORTING REQUIREMENTS
Where environmental programs track compliance with self monitoring requirements,
noncompliance with such requirements may become evident. If so, the responsible
regulatory agency will decide whether to implement an enforcement action to compel
compliance. Such enforcement actions serve two functions: compelling compliance with the
self-monitoring provisions (and related substantive requirements), and deterring violations of
self-monitoring and associated requirements.
Preliminary data indicate that all of the countries surveyed that track self-monitoring and
reporting requirements enforce these requirements: Canada (air, water); Germany (air,
drinking water, solid wastes, water); India (air, hazardous waste, water); Mexico (air); The
Netherlands (drinking water); Norway (air, solid waste, hazardous waste, chemical or toxic
substances, water); the United Kingdom (air, pesticides, solid waste, hazardous waste,
chemical or toxic substances, water); and the United States (air, drinking water, pesticides,
solid waste, hazardous waste, chemical or toxic substances, water).
The types of enforcement actions that are brought by these countries for violations of self-
monitoring requirements include most of the enforcement mechanisms generally used in
7-3
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
environmental programs. These include the following:
• Warning letters,
• Ticketing (field citations),
• Formal notices/letters of violation,
• Administrative orders/pollution fines and/or penalties,
• Administrative prosecution,
• Permit actions (withdrawal of permit, revocation of authorization),
• Prosecution: Civil (injunction, civil prosecution), and
• Prosecution: Criminal.
Based on available data, it is apparent that each country has its own hierarchy of enforcement
mechanisms and criteria for determining when each is appropriate. In Norway, common
enforcement actions that may be brought for violations of self-monitoring requirements
include 1) formal letters pointing out the obligation to come into compliance, 2) pollution
fines and reports to prosecuting authorities, and 4) withdrawal of discharge permits.
Similarly, in the United Kingdom,1 common enforcement actions brought for violations of
self-monitoring requirements include 1) prohibition notices, 2) improvement notices, 3)
enforcement notices, 4) revocation of authorization, and 5) prosecution.
In Canada, such enforcement actions may include: 1) warnings, 2) directions by inspectors,
3) ticketing, 4) orders by the Minister (for example, prohibiting activities, recalling
substances or products, requiring more information, interim orders or immediate action), 5)
injunctions, 6) prosecution, 7) penalties and court orders upon conviction, and 8) civil suit by
the Crown to recover costs. Whereas, in the United States, such enforcement actions may
include: 1) informal administrative actions (for example, warning letters, notices of
violation), 2) formal administrative actions (for example, administrative orders,
administrative complaints/litigation), 3) civil judicial actions (for example, injunctions, civil
litigation), and 4) criminal judicial action (for example, criminal litigation).
All of these enforcement actions are administered consistent with each country's
environmental policies. Generally, such policies provide that the more severe enforcement
actions or fines are applied to the most serious violations, based on several factors. These
factors include: the importance of the self-monitoring requirement to the integrity of the
program; the likelihood that health, safety, or the environment will be endangered as a result
of the violation; the anticipated or actual severity of that endangerment; and the compliance
history of the company or facility. For example, a minor violation, such as the late
submittal of a report will, generally, result in a less severe enforcement response (for
example, warning letter or notice of violation). Conversely, a serious violation, such as the
failure of a historically non-compliant facility to submit several months of reporting data that
indicate substantive violations, may warrant the imposition of significant penalties. Program
experience with self-monitoring and reporting requirements suggests that it is important to
Implemented pursuant to Integrated Pollution Control.
7-4
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
distinguish between self-monitoring violations that are minor or "technical" and those that
constitute or hide substantive violations, in order to maintain an appropriate focus within the
environmental enforcement program.
7-5
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
REFERENCES
General
A Report on the Overview of the Canadian Environmental Enforcement Program and the
Breakdown of this Program Between the Different Levels of Governments in Canada.
Richard Kemp, Office of Enforcement, Environment Canada. August 1995.
Bergkamp, Dr. Lucas, Dutch Environmental Law: An Overview of Recent Trends, BNA.
International Reporter, February 24, 1993.
BNA International Environmental Reporter, The Netherlands, September, 1993.
Draft Information Collection Guide, completed by Dr. B. Sengupta, Senior Scientist, Indian
Central Pollution Control Board, no date.
Environmental Enforcement: Environmental Protection Agency Cannot Ensure the Accuracy
of Self Reported Compliance Monitoring. GAO Report, March 1993.
Environmental Glossary, 2nd Ed., Government Institutes, Inc., Rockville, Maryland, 1982.
Environmental Law Enforcement in the 1990s. Enviroline: 93-01586. (Discussion of
environmental enforcement, including use of self-reporting).
Gabby, Shoshana, The Environment in Israel, Ministry of the Environment, Jerusalem.
Israel, 1994, p. 55.
Geddis, Robert. Enhanced Monitoring: High Price, Few Benefits. New Steel, Vol. 10, Iss.
6. June, 1994.
Grimsrud, G.P.; Finnemore, E.J.; Winkler, W.J.; Patton, R.N.; Cohen, A.I. User
Handbook for the Allocation of Compliance Monitoring Resources. December 1976.
(The procedures outlined incorporated Federal regulation requirements for compliance
monitoring to validate self-monitoring reports and support enforcement actions).
International Environmental Reporter, The Bureau of National Affairs, Inc., Washington,
D.C. 20037, March 1993. Sect. 262:0106 - 262:0107, p. 172-173.
McLoughlin & Forster, The Law and Practice Relating to Pollution Control in the United
Kingdom, London: Graham & Trotman, 1982.
OECD, OECD Environmental Performance Reviews: Netherlands, 1995.
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Self-monitoring, Reporting, and Recordkeeping Requirements
Rodland, Gro and Miller, Angela, Norway's Experience in Building an Inspector Corps:
Education and Financing, in the Third International Conference on Environmental
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Russell, Clifford S. Monitoring and Enforcement, Vanderbilt Inst. for Public Policy Studies,
Public Policies for Environmental Protection. 1990.
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implement strict self-monitoring programs).
U.S. Environmental Protection Agency. Environmental Progress and Challenges:
Environmental Protection Agency's Update. August 1988. EPA 230-07-88-033.
U.S. Environmental Protection Agency. Industrial User Inspection and Sampling Manual for
POTWs. April, 1994. EPA 831-B-94-001.
U.S. Environmental Protection Agency. NPDES Compliance Inspection Manual. September
1994.
U.S. Environmental Protection Agency. 1992 (February). Principles of Environmental
Enforcement. Office of Enforcement.
U.S. Environmental Protection Agency, Training Manual for NPDES Permit Writers,
March, 1983. EPA 833-B-93-003.
U.S. General Accounting Office. 1993 (March). Environmental
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Governmental Affairs, U.S. Senate. GAO/RCED-93-21.
Air
An Introduction to Continuous Emission Monitoring Programs. EPA 340/1-83-007.
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Environmental Law Centre prepared for Environment Canada, 1994. Incinerator Emissions.
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Self-monitoring, Reporting, and Recordkeeping Requirements
Pulp and Paper Mill Effluent Chlorinated Dioxins and Furans Regulations, Extract Canada
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45.
Water
American Society for Testing and Materials (ASTM). Annual Book of Standards, Pan 31,
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wastewater dischargers).
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Self-monitoring, Reporting, and Recordkeeping Requirements
U.S. Environmental Protection Agency. 1979a. Handbook for Analytical Quality Control in
Water and Wastewater Laboratories. EPA 600/4-79-019.
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Preservation of Water and Wastewater. EPA 600/4-82-029.
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Self-monitoring, Reporting, and Recordkeeping Requirements
GLOSSARY
Atomic Absorption Spectroscopy (AAS). This analytical method is especially applicable to
the analysis of single metallic element in minor or trace quantities, or of multiple metallic
elements, each one taken separately. The method is based on the absorption of
electromagnetic radiation by vaporized atoms, with the absorption proportional to the
concentration of atoms in a high-temperature chamber. Each atomic species responds to a
distinct radiation energy level, therefore there is no significant error when a mixture of
atomic spices are present in the heated chamber. This method can be applied hi a semi-
continuous manner for on-line emissions monitoring, or as a conventional laboratory
analytical instrument.
Chemiluminescence. Chemiluminescence, which uses no external light source, measures
light given off during specific chemical reactions. Its most common application is NOX
measurement, where the amount of light given off is proportional to the concentration of
chemical reactants.
Environmental Protection Agency Method 5 (or equivalent). The Environmental
Protection Agency Method 5 specifies the equipment, the emissions sampling protocol, and
the method of analysis for analyzing a particulate source. Equipment operators must be
highly trained. Variations of this method are applicable to polychlorinated dibenzo-p-dioxins
and polychlorinated dibenzofurans, and to multi-metals sampling and analysis.
Flame lonization Detector (FID) Gas Chromatography. An FID is a device in which the
measured change in conductivity of a standard flame (usually hydrogen) due to insertion of
another gas or vapor is proportional to the concentration of the gas or vapor.
Fourier Transform Infrared Spectroscopy (FTIR). FTIR most frequently is used when a
large number of compounds must be identified and quantified. The technology relies on a
broad band of infrared light to provide simultaneous measurement of absorption at many
wavelengths. The heart of an FTIR system is on the interferometer, which contains optics to
precisely align and split the light beam. The beam passes through the interferometer,
interacts with the sample and is captured by a light-sensitive detector. The detector translates
the spectral information into an electronic signal. The key to obtaining consistently accurate
readings from an FTIR is maintaining perfectly aligned optics. Most FTIR systems use a
moving mirror to modulate light. In industrial environments, however, low-level vibrations
can interfere with alignment. To combat this problem, an alternately designed FTIR system
may use an interferometer that functions without moving mirrors.
High Pressure Liquid Chromatography (HPLC). HPLC was developed from column
chromatography but it is faster, has a higher separation capacity and a lower limit of
detection. The method is applicable to mixtures of organic compounds.
Inductively Coupled Plasma - Atomic Emission Spectroscopy (ICP). In this method, high-
frequency energy is transferred by inductive coupling to a flow of inert gas such as argon
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
which contains the sample as an aerosol. The energy heats the argon and sample to 10,000
K, causing excitation of the resulting free atoms and ions that emit light. The intensity of
the light is measured and is related to the concentration of the emitting atoms. This method
is specific for metals. The method allows simultaneous analysis of multiple metals compared
to AAS which will analyze one metal at a tune.
Infrared (IR) Absorption. IR, as an optical monitoring technology, identifies carbon
dioxide (CO^, carbon monoxide (CO), SO2 and several hazardous air pollutants found in the
infrared regions of the light spectrum. The middle range of the spectrum is most conducive
to the absorption of water and CO2. Most hazardous air pollutants are better absorbed hi
ranges where water and CO2 absorption is weak. Data collected on a chemical includes the
optimum wavelength for its absorption, its absorption coefficient and its detection limit.
Several factors can interfere with accurate measurements, including multiple absorption peak
ranges of several compounds and high absorption of several chemicals at identical ranges.
Mass Spectroscopy (MS). Mass spectroscopy is a method for creating charged particles hi a
sample and then determining the masses and abundance of charged particles. The use of the
method expanded greatly hi the 1950's when its applicability to structural elucidation of
organic and inorganic compounds was recognized. Mixtures of compounds can thus be
analyzed quantitatively. Is frequently used hi conjunction with other methods, as gas
chromatography.
Non-Dispersive Infrared Spectroscopy (NDIR). NDIR is used to quantify CO, CO2,
ammonia, methane, total hydrocarbons, SO2 and sulfuric acid. NDIR technology typically
uses an optical filter to narrow a broad band of infrared light to the necessary wavelength.
These systems often incorporate fixed optical filters, gas filter correlations or optical filter
wheels. As a rule, NDIR systems are applied when only a few compounds must be
analyzed.
Photoionization Detector (PID). An PID accomplishes the removal of one or more
electrons from a vaporized atom or module by absorption of visible or ultraviolet light. The
wavelength (energy level) of the light that accomplishes this is specific to the atom or
molecule. This amount of ionization is proportional to the concentration of the chemicals in
the sample. This method is applicable to VOCs and other organic and inorganic molecules.
Triboelectric Effect. When two materials are rubbed or collide together, a transfer of
charge takes place from one material to the other. This is also referred to as frictional
electrification. If a sensing probe is inserted hi a stream of particles, a continual transfer of
charge takes place as the particles collide with the probe. Because an electrical path to earth
ground is provided, a small, essentially continuous signal is produced and no voltage exists at
the probe. An electronic signal processing unit monitors the character and level of this
signal, which correlates very closely with the actual mass flow rate.
August 1998
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Self-monitoring, Reporting, and Recordkeeping Requirements
Ultraviolet (UV) Absorption. UV absorption quantifies compounds whose infrared
absorption is difficult to measure, such as NO, NOX and SQj. The UV absorption is
proportional to the concentration of the pollutants present in the sample.
Visible Light Transmission. Visible light transmission, as its name implies, measures the
visible light transmitted across a gas stream to a detector. Since particulates in the gas
stream will reduce the amount of transmitted light, the technology determines opacity and,
subsequently, quantifies particulates. As noted previously there is only a qualitative
relationship between opacity and the quantity of particulates. This is true for several
reasons, as follows:
• The density of the particulates in an emissions stream that can change with time,
altering the mass of particulates emitted, even if the particulates size distribution
remains unaltered.
• The size distribution of the particulates can change with time, destroy ing any
correlation between Opacity and particulates that may have been established prior.
If the size distribution of a particulates stream slides toward larger quantities of
smaller particles, opacity will increase (less light is transmitted).
• Color or reflectivity of the particulates may also change with time.
August 1998
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APPENDIX A-l
U.S. PROGRAM REQUIREMENTS - AIR
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AIR PROGRAM
STATUTE: CLEAN AIR ACT
Regulated Community; New or Modified Stationary Sources: Categories Listed
in 40 CFR Part 60
Enforcement Authority: Federal, State
Self Monitoring Requirements:
• Pollutants (as specified in the permit or National standard)
- Criteria Pollutants: Particulate Matter, Sulfur Dioxide, Nitrogen Oxides, Carbon Monoxide
- VOCs (Emitted From'): Petroleum Storage Vessels, Surface Coating Metal Furniture, Surface
Coating Auto, Rotogravure Printing, Surface Coating Pressure Sensitive Tape/Label
Operations, Surface Coating Large Appliances, Surface Coating Beverage Can, Bulk Gasoline
Terminals, Rubber Tire Manufacturing, Synthetic Organic Chemical Manufacturing
(Equipment Leaks), Polymer Manufacturing, Vinyl/Urethane Coating/Printing), Petroleum
Refineries (Equipment Leaks/Wastewater Systems), Synthetic Fiber, Synthetic Organic
Chemical Manufacturing Air Oxidation Unit Processes/Distillation Operations, Petroleum Dry
Cleaners, On-Shore natural Gas Processing (Equipment Leaks), Magnetic Tape Coating
Facilities, Surface Coating Plastic Parts, Polymeric Coating of Supporting Substrates
- Other Pollutants: Metals (MWCs), Organics (MWCs), Acid Gases (MWCs), Acid Mist
(Sulfuric Acid Plants), Visible Emissions (Various Smelters/Reduction Plants), Fluorides
(Phosphate Fertilizer), Total Reduced Sulfur (Kraft Pulp Mills), Lead (Lead Acid Battery
Plants)
- Opacity: Observation conducted concurrent with initial performance test to demonstrate initial
compliance.
Frequency of Monitoring: As specified in the permit, State Implementation Plan, or National
standard. Generally requires continuous monitoring system for emissions or process parameters (data
reduced to 6-minute averages for opacity/ 1-hour averages for other parameters).
November 1995
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AIR PROGRAM
STATUTE: CLEAN AIR ACT
Recordkeeping Requirements:
• Manufacturers of new vehicles or engines must maintain general and individual records
associated with certification vehicles and engines
- General records include a description of the certification vehicles/engines, the emission
control systems, and test procedures (a proper application for certification fulfills these
requirements)
- Individual records include historical data for certification vehicles/engines (e.g.,
modifications, emissions tests, mileage runs, maintenance, diagnostic tests, other events
affecting the vehicle)
Retention time: All records except emission tests maintained for 6 years from issuance of certificate
of conformity (8 for light duty vehicles model year 1994 and later). Emission tests maintained for 1
year from issuance
• Manufacturers of new vehicles or engines certified under banking or averaging programs must
maintain records for each vehicle/engine and vehicle/engine family (e.g., engine family,
identification number, model year, build date, brake horsepower, destination, assembly plant,
FEL, useful life, projected/actual production volume)
Retention time: Six years from due date from end of model year report
• Various test procedures specify records that must be maintained for each required certification
emissions test
Data Quality Assurance:
Data Use:
Data Management:
Types of Enforcement Actions:
November 1995
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AIR PROGRAM
STATUTE: CLEAN AIR ACT
Regulated Community: Mobile Sources: Motor Vehicles
Enforcement Authority: Federal, State
Self Monitoring Requirements:
• Pollutants: Hydrocarbons, Carbon Monoxide, Nitrogen Oxides, Paniculate Matter
• Auto Manufacturers and EPA test motor vehicles and engines to determine whether they comply
with emission limits. EPA certifies such compliance
• States implement inspection and maintenance programs for areas that do not meet ozone or
carbon monoxide NAAQSs (depending on population and non-attainment designation)
Frequency: EPA certification prior to commercial distribution. State inspections are generally
required annually.
Reporting Requirements:
• States must submit annual (by July of each year) reports to EPA assessing:
- Test data (e.g., number and type of vehicles tested, detailed breakdown of results of
emissions tests)
- Quality assurance data (e.g., number of inspection stations and lanes operating throughout the
year, number of covert audits, number of licensed inspectors and stations, penalties issued,
etc.)
- Quality control report (e.g., number of testing sites and lanes used, number of equipment
audits, audit results, station closures)
- Enforcement report (e.g., enforcement statistics, registration denial data, computer matching
enforcement data, sticker-based enforcement data)
• States must submit biennial (by July of every other year) reports to EPA addressing: changes
made in the program as well as any weaknesses or problems identified and remedial steps taken
• Manufacturers must submit emission defect and recall reports/15 days after finding defect
affecting 25 vehicles/engines or initiating notification
November 1995
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AIR PROGRAM
STATUTE: CLEAN AIR ACT
Reporting Requirements:
• All facilities subject to NSPSs must:
- Notify EPA of date of construction or reconstruction/Postmarked 30 days after such date
- Notify EPA of initial start-up date/Not more than 60 nor less than 30 days prior to such
date
- Notify EPA of actual start-up date/Postmarked 15 days after such date
- Notify EPA of changes that may increase emissions/Postmarked 60 days or as soon as
practicable before the change
- Notify EPA of the date the CEM demonstration commences/Postmarked 30 days prior to
such date
- Notify EPA of date for opacity observation (verifies initial compliance)/Postmarked 30 days
prior to such date
- Notify EPA if continuous opacity monitoring to be used during performance test/Postmarked
30 days prior to performance test
• Owners or operators required to install continuous monitoring systems or monitoring devices
must submit an excess emissions and monitoring systems performance report and/or summary
report form (except when: more frequent reporting specified in Subpart; CMS data used for
compliance determination — quarterly reports required; or more frequent reporting
necessary/Semi-annually, postmarked 30 days after calendar half (quarter)
• Owners or operators must conduct performance tests and report results to EPA/Within 60 days
of achieving maximum production rate — not later than 180 days after start-up
• Additional reporting requirements are specified in certain National standards applicable to
specific industrial categories.
Recordkeeping Requirements:
• All facilities subject to NSPSs must maintain records of the occurrence and duration of:
- any start-up, shut-down, or malfunction
- any malfunction of the air pollution control equipment
- periods during which the continuous monitoring system is inoperative
• Additional recordkeeping requirements are specified in certain National standards applicable to
specific industrial categories.
Retention time: Not specified.
November 1995
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AIR PROGRAM
STATUTE: CLEAN AIR ACT
Data Quality Assurance:
Data Use:
Data Management:
Types of Enforcement Actions:
November 1995
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APPENDIX A-2
U.S. PROGRAM REQUIREMENTS - WATER
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Water Program (Clean Water Act)
The Clean Water Act (CWA) controls discharges of wastewater into the waters of the United States. The
objective of the CWA is "to restore and maintain the chemical, physical, and biological integrity of the
Nation's waters." The CWA identifies certain pollutants and sets required treatment levels for those
pollutants. The pollutants are categorized into three groups: (1) conventional pollutants, (2) non-
conventional pollutants, and (3) toxic pollutants. The CWA also separates the sources of pollution into
two categories: (1) non-point sources, and (2) point sources. Point source discharges are those that enter
receiving waters through a discrete conveyance (e.g., a pipe or ditch), and include both industrial
wastewater and storm water associated with industrial activity. Point source discharges include both
industrial plants and publicly owned treatment works (POTWs). Other discharges, such as diffuse sheet
flow, are considered nonpoint source discharges. Point source discharges must be authorized by a
National Pollutant Discharge Elimination System (NPDES) permit.
NPDES Program
The NPDES program regulates the point source discharge of pollutants directly to receiving waters of the
United States. For discharge of industrial wastewater, either EPA or an authorized State or Indian Tribe
issues an NPDES permit that sets limits on the concentration or mass of specific pollutants allowed to be
discharged from a specific point source; the permit may also include limits on whole effluent toxicity to
assure narrative water quality standards for toxics are achieved. The permit effluent limits may be
technology or water quality-based. Technology-based limits have been established for numerous industrial
categories (national effluent limitation guidelines) and for POTWs (secondary treatment). In addition,
permit limits must assure water quality standards established by the States are achieved, which may result
in limits more stringent than technology-based limits. CWA amendments in 1987 established a specific
program to issue permits to municipal separate storm sewer systems and storm water discharges associated1
with industrial activity. These storm water permits generally include pollution prevention plans and in
certain limited circumstances may impose numeric limits on pollutant concentrations. To implement this
program effectively, general permits are being widely used, in addition to individual permits issued usually
to large municipal systems. These general permits cover many point source storm water discharges
(usually from industry) in a geographic area.
National Pretreatment Program
The National Pretreatment Program regulates the discharges of wastewater from industrial facilities to
POTWs, so called "indirect" discharges. The purpose is to prevent interference with the effective
operation of POTWs and to limit the discharge of pollutants that may otherwise pass through the POTW
inadequately treated. There are general pretreatment standards (i.e., prohibitions) that apply to all indirect
discharges and there are more specific standards applicable to certain categories of industrial dischargers
(i.e., categorical standards). In addition, local discharge limits can be established by POTWs.
Pretreatment programs are typically administered by the local wastewater treatment authority (i.e.,
POTW). However, smaller local wastewater treatment authorities are not required to develop pretreatment
programs; in this case, a pretreatment program may be administered by EPA or the appropriate,
authorized State or Tribe.
Water-1
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Regulated Community: Facilities Discharging Directly to the Environment:
Municipal Wastewater Treatment Plants and Industrial Facilities
Enforcement Authority: Federal, State
Self Monitoring Requirements:
• Pollutants (as specified in the permit or National standard)
- Conventional: BOD (composite); TSS (composite);coliform (grab); residual chlorine (grab);
pH (grab or continuous); DO (grab); ammonia (composite); temperature (in situ); and oil and
grease (grab)
- Toxics: metals (composite); phenols (grab); volatile organics (grab); cyanide (grab); base
neutral/acid extractibles (composite); pesticides (composite); and PCBs (composite)
- Others (as specified): TDS and salinity
- Whole effluent toxicity: acute (grab or composite); and chronic (grab or composite)
• Volume of discharge from each outfall
• Other measurements: pollutants in internal waste streams, frequency and rate of discharge for
noncontinuous discharges, and pollutants subject to notification requirements
Frequency of Monitoring: As specified in the permit - minimum annually
Reporting Requirements:
• Discharge monitoring reports (DMRs) containing monthly monitoring data and any instances of
noncompliance/As specified in the permit
• Any noncompliance that may endanger health or the environment/Verbally within 24 hours;
written within 5 days
• Any planned physical alterations or additions to the permitted facility (under certain
circumstances)/As soon as possible
• Any planned changes that may result in noncompliance/Advance notice prior to change
• Other notifications including transfer to new owner or anticipated (or unanticipated) bypass or
upsets/As soon as possible
Water-2
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Recordkeeping Requirements:
• For all samples: (1) thp date, exact place, and time of sampling or measurements, (2) individual
who performed the sampling or measurement, (3) date of analyses, (4) individual who performed
analyses, (5) analytical techniques or methods used, and (6) results of analyses
• Calibration and maintenance information, original strip chart recordings for continuous
monitoring instrumentation, copies of all reports required by permit, and records of all data used
to complete the application for the permit
Retention time: 3 years
Data Quality Assurance:
Facility OA activities:
« Sampling and analyses must conform to procedures established by EPA at 40 CFR 136, which
contains approved test procedures for (1) biological parameters, (2) inorganics, (3) non-pesticide
organics, (4) pesticides, and (5) radiological parameters. It also contains the required
containers, preservation techniques, and holding times for the above parameters.
• Calibration and performance techniques also must conform to the requirements established by
EPA at 40 CFR 136. Such techniques have been established for all the parameters listed above.
• Self certification (40 CFR 122.22): All reports submitted by a facility must be signed by an
authorized person or their authorized designee and must include a certification stating, under
penalty of law, that the information submitted is true, accurate, and complete.
Water-3
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Enforcement Authority data verification activities:
• Inspections of regulated community:
(1) Compliance evaluation inspections verify the data submitted and records maintained, and
reviews overall operation, maintenance, and sampling procedures
(2) Compliance sampling inspections include every component of the compliance evaluation
inspection, but also include sampling by inspectors to verify the facility's sampling
(3) Performance audit inspections include every component of the compliance evaluation
inspection, but also include an in-depth review of the facility's sampling procedures and a
review of the laboratory that performs the analyses
• Laboratory inspections: National performance evaluations are conducted annually of all
laboratories that are used by major dischargers. In the evaluation, EPA prepared samples with
known constituents and concentrations and sends them to the major dischargers, who then ask
their laboratories to analyze the samples. The laboratories are asked to use the same personnel
and methods they use to conduct regular analyses for the discharger. EPA then analyzes the
results of the laboratories analyses for performance with acceptable limits.
Data Use:
»i
• Data collected through self-monitoring activities are primarily used to:
- Determine compliance and take appropriate enforcement actions
- Identify facilities requiring follow-up inspections
- Develop general targeting strategies for compliance activities
- Target chemicals/activities for regulatory development
- Assess state of the environment
Data Management:
• EPA manages the Permit Compliance System (PCS), which is a database that contains permit,
compliance, and enforcement data on permit-holding facilities. Each record contains information
that: (1) identifies and describes the facility, (2) specifies the pollutant discharge limits, (3)
records the actual amounts of pollutants measured in the discharges (discharge monitoring
reports), and (4) tracks compliance schedules and violations.
• Information from PCS (except enforcement sensitive data and data claimed as trade secret) is
available to the public through Freedom of Information Act (FOIA) requests.
Water-4
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Types of Enforcement Actions:
• Criminal enforcement for (1) negligent violations, (2) knowing violations, (3) knowing
endangerment, and (4) filing false reports or knowingly falsifying, tampering, or rendering
inaccurate any monitoring device or method
• Civil enforcement, such as injunctions, consent decrees, and civil penalties
• Administrative compliance orders and penalties
• Citizen suits
Water-5
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Regulated Community: Facilities with Storm Water Discharges Directly to the Environment
Enforcement Authority: Federal, State
Self Monitoring Requirements:
• Pollutants: conventional or toxic
• Flow or volume of storm water discharges
Frequency: As specified in permit or by industry type - minimum annually
Inspection/site compliance evaluation to determine compliance with Best Management Practices
and Pollution Prevention Plan/Annually
Reporting Requirements:
• Monitoring results/At least annually for industrial activity subject to effluent limitations or
as specified in the permit for industrial activity not subject to effluent limitations
• All instances of noncompliance/At least annually
Recordkeeping Requirements:
• Same as reporting requirements above
• Record summarizing the results of the inspection/site compliance evaluation and a certification
that the facility is in compliance with the plan
Retention time: 3 years
Water-6
November 1995
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WATER PROGRAM
STATUTE; CLEAN WATER ACT
Data Quality Assurance:
Facility OA activities:
• Facility QA activities for the storm water program are the same as those for direct dischargers to
the environment (see page 2).
Enforcement Authority data verification activities:
• Storm water inspections by the enforcement authority are conducted as part of the inspections of
direct dischargers to the environment (see page 3).
Water-7
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Regulated Community: Industrial Facilities Discharging to a Municipal Sewage Collection
System
Enforcement Authority: Federal, State, Local
Self Monitoring Requirements:
• Pollutants (conventional and/or toxic, depending on the specific industry type)
- pH, cyanide, total phenols, oil and grease, sulfide, and volatile organics (minimum of 4
grab samples for each)
- all other pollutants (24-hour composite samples; flow proportioned when feasible)
• Flow measurements, both average daily and maximum daily
Frequency: Within 180 days of effective date of new standard; within 90 days of compliance date
of new standard; and as specified in the permit - minimum of 2 times per year
Reporting Requirements:
• One-time baseline report containing monitoring data/Within 180 days of effective date of new
standard
• One-time initial compliance report containing monitoring data/Within 90 days of compliance
date of new standard
• Continuous compliance reports containing self-monitoring data/Minimum two times per year
• Notify of violation discovered through sampling and analysis/Verbally within 24 hours; written
report within 5 days
• Other:
- Notice of discharges that could cause problems to municipal wastewater system/Immediately
- Notice of substantial changes in the volume or character of pollutants/Prior to change
- Notice of any discharge of hazardous wastes - one-time report/No later than 180 days after
the discharge of the hazardous waste
Water-8
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Recordkeeping Requirements:
• For all samples: (1) the date, exact place, method, and time of sampling; (2) the name(s) of
person(s) taking the samples; (3) date of analyses; (4) who performed the analyses; (5) analytical
techniques/methods; and (6) results/3 years from the date of analyses
Data Quality Assurance:
Facility OA activities:
• Facility QA activities for industrial dischargers to a municipal sewage collection system are the
same as those for direct dischargers to the environment (see page 2).
Enforcement Authority data verification activities:
• Facility inspections of significant industrial users/Minimum annually
• Laboratory inspections/As determined necessary by enforcement authority
• Split samples/As determined necessary by enforcement authority
Data Use:
Note: The information in this section represents the range of possible options; it does not
represent actual information for the U.S. water program.
Determine compliance and take appropriate enforcement actions
Identity facilities requiring follow-up inspections
Develop general targeting strategies for compliance activities
Target chemicals/activities for regulatory development
Assess state of the environment
Water-9
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Data Management:
• Enforcement authority may use hard copies or the Pretreatment Compliance Monitoring and
Enforcement (PCME) database. PCME is a database that assists local municipalities in
implementing their pretreatment programs. It is designed to assist the local pretreatment
authorities track industrial user compliance with applicable pretreatment standards and
requirements. PCME also (1) maintains an inventory of all significant industrial users, (2)
tracks analytical sampling information, (3) tracks required reports, inspections, and enforcement
actions, and (4) determines industrial user compliance.
• All effluent data are available to the public without restriction. Enforcement authorities
generally have procedures dealing with public access to other data/information.
Types of Enforcement Actions:
Notice of violation
Administrative fines
Administrative orders
Civil litigation
Criminal prosecution
Termination of service
Supplemental enforcement responses (e.g., publication of significant violations in newspaper,
increased monitoring and reporting)
Any of the above enforcement actions may be used based on the nature and severity of the
violation. For example, the enforcement action for a report that is 10 days late may be a Notice of
Violation, while the action for falsification of data may be criminal prosecution.
Water-10
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Regulated Community: Preparers of Sludge for Land Application
Enforcement Authority: Federal, State
Self Monitoring Requirements:
• Pollutants: arsenic, cadmium, chromium, copper, lead, mercury, molybdenum, nickel,
selenium, zinc, and percent solids
• Pathogen density parameters: fecal coliform or salmonella, enteric viruses, and Helminth ova
• Vector attraction reduction parameters: percent volatile solids reduction, specific oxygen uptake
rate, pH, and percent solids
Frequency: Ranges from monthly to annually depending on amount of sludge1
Reporting Requirements:
• Concentration of each pollutant monitored and how pathogen and vector reduction requirements
were met/Annually
Recordkeeping Requirements:
• Same as reporting requirements/5 years
Regulated Community: Appliers of Sludge and Domestic Septage to Land
Self Monitoring Requirements:
Domestic septage: Ensure pH is 12 or higher through alkali addition and remains at 12 or higher for
30 minutes/Each batch
Sludge: None
The frequency of monitoring is based on the following (metric tons per 365-day period):
• Once per year for amounts greater than zero but less than 290
• Once per quarter for amounts equal to or greater than 290 but less than 1,500
• Once per 60 days for amounts equal to or greater than 1,500 but less than 15,000
• Once per month for amounts equal to or greater than 15,000.
Water-11
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Reporting Requirements:
• Domestic septage: None
• Sludge: None
Recordkeeping Requirements:
• Domestic septage: For each site: (1) location and number of hectares, (2) date, time, and rate
of application, and (3) nitrogen requirement for the crop or vegetation grown/5 years
• Sludge: For each site: (1) location and number of hectares, (2) date, time, and rate of
application, (3) cumulative amount of each listed pollutant applied, and (4) amount of sludge
applied/Indefinitely
For each site: how management practices, pathogen, and vector requirements were met/5 years
Regulated Community; Preparers of Sludge and Domestic Septage for Surface Disposal
Self-Monitoring Requirements:
• Sludge: Arsenic, chromium, and nickel (if placed in unlined units)
Pathogen density parameters (if sludge is not covered daily with soil): fecal coliform or
salmonella, enteric viruses, and Helminth ova
Vector reduction parameters (if sludge is not covered daily with soil): percent volatile solids
reduction, specific oxygen uptake rate, pH, and percent solids
Frequency: Ranges from monthly to annually depending on amount of sludge (see footnote
on page 9)
• Domestic septage: Ensure pH is 12 or higher through alkali addition and remains at 12 or
higher for 30 minutes/Each batch
Reporting Requirements:
• Sludge: Concentration of each listed pollutant and how pathogen and vector reduction
requirements were met/Annually
• Domestic septage: None
Water-12
November 1995
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WATER PROGRAM
STATUTE: CLEAN WATER ACT
Recordkeeping Requirements:
• Sludge: Same as reporting requirements/5 years
• Domestic septage: None
Owner/Operator of Surface Disposal Site at which Sludge Is Placed
Self-Monitoring Requirements:
• Air inside all structures for methane gas/Continuous, as long as the site is active and for 3
years after site closure
Reporting Requirements:
• Concentration of each pollutant monitored and how management practices and vector reduction
requirements were met/Annually
Recordkeeping Requirements:
• Same as reporting requirements/5 years
Regulated Community: Person Who Incinerates Sludge
Self-Monitoring Requirements:
• Arsenic, cadmium, chromium, lead, and nickel (beryllium and mercury specified by permitting
authority)/Ranges from monthly to annually depending on amount of sludge1
• Total hydrocarbons, oxygen concentration, information to determine moisture content, and
combustion temperatures/Continuously
• Air pollution control device operating parameters (specified by the permitting
authority)/Continuously
Reporting Requirements:
• (1) Concentration of arsenic, cadmium, chromium, lead, and nickel, (2) information that
indicates the requirements in the National Emission Standard for beryllium and mercury were
met, (3) total hydrocarbons concentrations, (4) oxygen concentration and information used to
measure moisture content, (5) combustion temperatures, and (6) values for the air pollution
control device operating parameters/Annually
Water-13
November 1995
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WATER PROGRAM
STATUTE; CLEAN WATER ACT
Recordkeeping Requirements:
• Same as reporting requirements, but also sewage sludge feed rate; stack height; dispersion factor
for the site where the sewage sludge incinerator is located; control efficiency for lead, arsenic,
cadmium, chromium, and nickel; risk specific concentration for chromium; and calibration and
maintenance log/5 years
Note: In the next four sections, the type of information included represents the range of
possible options for completion of these sections; it does not represent actual information
for the U.S. water program.
Data Quality Assurance:
Established sampling and analyses procedures
Established calibration and performance techniques
Established laboratory practices
Required certification (either by self or a third party)
Inspections
Laboratory performance evaluations
Data Use:
Determine compliance and take appropriate enforcement actions
Identify facilities requiring follow-up inspections
Develop general targeting strategies for compliance activities
Target chemical/activities for regulatory development
Assess state of the environment
Data Management:
• Hard copy
• Computer databases
• Available to the public
Types of Enforcement Actions:
• Tracking of noncompliance
• Common enforcement actions for violations, such as failure to self monitor or report
Water-14
November 1995
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APPENDIX A-3
U.S. PROGRAM REQUIREMENTS - DRINKING WATER
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Overview of the Safe Drinking Water Act
Enacted in 1974 and amended in 1986, the Safe Drinking Water Act (SOWA) authorizes the United
States government to establish mandatory and comprehensive national drinking water quality
standards. The goal of these standards is to ensure that the nation's public health is not endangered
by drinking water of unacceptable quality. The regulatory requirements of the SDWA are
administered jointly by the Federal government and States. EPA is responsible for developing the
National Primary Drinking Water Regulations (NPDWR) and policies and the States are responsible
for implementing and enforcing the EPA requirements.
Specifically, the SDWA required EPA to identify contaminants in drinking water that may have an
adverse effect on people's health, and if possible, establish a maximum contaminant level (MCL) for
each contaminant. The MCL is the concentration of a contaminant that cannot be exceeded in the
drinking water. Usually, the established MCLs become the NPDWR and must be adhered to by
public water systems. A public water system is defined as a system that regularly supplies water to
15 or more connections or to 25 or more individuals at least 60 days a year. Most industrial and
commercial systems meet this definition, but only residential systems are required to meet all
NPDWRs. In 1987, in an effort to cover more systems, EPA changed the definition so it would
include schools, offices, and factories that have their own water sypply (i.e., wells).
In addition to developing MCLs, EPA must also establish maximum contaminant level goals (MCLG)
for each contaminant. These MCLGs must be set at a level (1) at which no known or anticipated
adverse effects occur to the health of people and (2) which allows an adequate margin of safety. The
MCLG is almost entirely a health-based determination and is only a goal; it is not an enforceable
standard.
MCLs should be set as close to the MCLG as feasible. The SDWA defines feasible to mean the
MCL that is "feasible with the use of the best technology, treatment techniques, and other means." If
it is infeasible to determine the level of the contaminant, and thus establish an MCL, EPA is
authorized to promulgate an NPDWR requiring the use of a specified treatment technology. While
EPA has yet to do this, it has specified treatment technologies capable of meeting specific MCLs.
If a public water system cannot meet the NPDWR, even using the best treatment technology, it may
apply for a variance. Variances require eventual compliance with the NPDWR and cannot be granted
if they result in an unreasonable risk to public health. Or, if a system cannot meet an MCL for
reasons other than the nature of its raw water supply or cannot install a treatment technology specified
by a primary standard, it can receive an exemption. Exemptions require compliance within 3 years
and cannot be granted if they result in an unreasonable risk to public health.
EPA has also established secondary drinking water regulations. These regulation are designed to
protect "public welfare" from odor and aesthetic problems in the drinking water supply. Secondary
standards, which are only guidelines and cannot be enforced, have been established for chloride,
color, copper, corrosivity, fluoride, foaming agents, iron, manganese, odor, pH, sulfate, total
dissolved solids, and zinc.
-------
1986 amendments:
Mandate issuance of standards for 83 specified contaminants and standards for 25
additional contaminants every three years thereafter
increase EPA enforcement powers
regulate the presence of lead in drinking water systems
The 83 contaminants are divided into six categories: (1) microbials, (2) inorganics, (3) volatile
organic chemicals, (4) synthetic organic chemicals, (5) radionuclides, and (6) miscellaneous.
There are also unregulated contaminants, which must be monitored for but which do not have
NPDWR set yet.
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DRINKING WATER PROGRAM
STATUTE: SAFE DRINKING WATER ACT
Regulated Community: Public Water Supplies and Non-community water systems1
Enforcement Authority; Federal or Authorized States
Section 1. Self-Monitoring Requirements:
• Sampling and analysis of drinking water samples for the following:
- Total coliform/Ranges from 1 to 480 samples monthly
- Asbestos/One time during 9-year period starting 1/1/93
- Turbidity/Daily
- Barium, cadmium, chromium, fluoride, mercury, selenium, nitrate, nitrite (as N)/Annually
for surface water, once every 3 years for groundwater sources
- Organics/Quarterly for first year
- Radionuclides/Quarterly for 1 year, then once every four years
- Total trihalomethanes/Quarterly
- Specified organics
- Sodium/Annually for surface water, once every 3 years for groundwater sources
- Corrosivity/2 times per year
"*
- Lead and copper/every 6 months
- Unregulated organics and inorganics/Quarterly for first year
Non-community water system requirements are not presented and will not be used in this study.
November 1995
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Section 2. Reporting Requirements:
• Results of any test measurement or analysis required/Within (1) the first 10 days following
the month in which the result is received or (2) the first 10 days following the end of
the required monitoring period, whichever is shortest or unless specified elsewhere
• Failure to comply with any National Primary Drinking Water Regulation, including failure
to comply with monitoring requirements/Within 48 hours
• Copy of each type of public notice distributed, published, posted, and/or made available to
the persons served by the system and/or to the media/Within 10 days of completion of
public notice
• Any records required under recordkeeping requirements (see below)/As requested by the
Enforcement Authority
• Monitoring results for unregulated organics and inorganics/Within 30 days of receipt
• Results of analyses for corrosivity/Within the first 10 days of the month following the
month in which the sample results were received
Public Notification
• For noncompliance with MCL, treatment technique, or schedule/publication in newspaper
no later than 14 days after violation; notification by direct mail no later than 45 days
after violation; or for acute risk situations, notification to television and radio stations
for broadcast no later than 72 hours after violation
• For other violations or situations (e.g. failure to monitor, failure to comply with testing
procedures, or if subject to variance or exemption/publication in newspaper within 3
months; notification by direct mail within 3 months after violation; or hand delivery or
posting within 3 months after violation
• For unregulated organics and inorganics, notice of availability of sampling results/With
first set of water bills after receipt of results or written notice within 3 months; for
surface water systems, after first quarter's monitoring
• For sodium, notification to enforcement authority of levels/By written notice by direct
mail within 3 months
November 1995
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Section 3. Recordkeeping Requirements:
• Records of bacteriological analyses/5 years
• Records of chemical analyses/10 years
• Records of actions taken to correct violations/3 years
• Copies of written reports, summaries, or communications to sanitary surveys/10 years
• Records concerning a variance or exemption/5 years following expiration of variance or
exemption
Section 4. Data/Information Quality Assurance:
Regulated Entity Quality Assurance Activities:
Enforcement Authority Data/Information Verification Activities:
• Inspection of regulated entities
Section 5. Data/Information Management:
• The Federal Reporting Data System (FRDS) is the repository for information on public
water supplies. The system contains (1) identification information, (2) noncompliance
events, (3) violations, (4) enforcement actions, (5) identification of significant
noncompliers, and (6) information on variances, exemptions, and waivers.
• Information from FRDS is available to the public either by subscribing to a user account or
through a request to EPA.
Section 6. Data/Information Use:
• Determine compliance and take appropriate enforcement actions
• Identify entities requiring follow-up inspections
• Develop general targeting strategies for compliance activities
• Target contaminants for regulatory development
• Assess state of the environment
November 1995
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Section 7. Types of Enforcement Actions:
• Administrative orders requiring compliance with regulations or other requirements
• Civil penalties for failure to comply with administrative orders
• Administrative penalties for failure to comply with administrative orders
• Criminal prosecution for tampering with a public water supply
November 1995
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APPENDIX A-4
U.S. PROGRAM REQUIREMENTS - Toxic RELEASE INVENTORY
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The Toxic Release Inventory
The Toxic Release Inventory (TRI) is a database developed and maintained by the U.S.
Environmental Protection Agency (EPA) that contains information from facilities on the amounts of
over 300 listed toxic chemicals that the facilities release directly to air, water, or land, or that are
transported (transferred) off-site. The TRI was mandated by the Emergency Planning and Community
Right-to-Know Act (EPCRA), which is based on the premise that citizens have a right to know about
toxic chemicals in their communities. TRI's purpose is to encourage planning for responses to
chemical accidents and to provide the public and government with information about possible
chemical hazards in communities.
Specifically, EPCRA states that facilities that manufacture, process, or otherwise use certain toxic
chemicals in excess of threshold quantities must submit annual reports on the amounts of those toxic
chemicals released into the air, water, and land, or transferred offsite. The annual report, called the
Form R, is only required of facilities that meet certain requirements:
• Have 10 or more full-time employees
• Are in Standard Industrial Classification (SIC) codes 20 through 39 (i.e.,
manufacturing sector)
• Manufacture, process, or otherwise use a listed toxic chemical in excess of the
specified threshold quantity.
Facilities must provide the required information on the Form R and retain onsite copies of all forms,
along with the supporting materials used to develop the information, for a period of three years from
the data of submission.these materials must also be readily available for inspection by EPA or other
authorized organizations. EPCRA also requires EPA to enter the data from each Form R into the
TRI.
The TRI is available on magnetic tape, CD ROM, and software-specific diskettes (by state).
Microfiche versions of the data are available at a library in every U.S. county. The EPCRA
Reporting Center in Washington, DC, offers a reading room and responds to requests for
information. A wide variety of publications are produced, including a National Report (reports may
not be available for all years) that provides an annual overview of the data. TRI is updated
continually on EPA's mainframe computer; Diskettes, CD ROMs, and other means of access are
updated annually. Extensive QA/QC procedures are in place, including verification of data entry,
data quality reports that check for data entry and submitter errors, and verification of critical release
data.
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APPENDIX A-5
U.S. PROGRAM REQUIREMENTS - SOLID WASTE
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Solid Waste Program
The Resource Conservation and Recovery Act (RCRA) addresses the management of solid and hazardous
waste as well as underground storage tanks that contain hazardous substances or petroleum. RCRA
Subtitle C regulations provide "cradle-to-grave" regulation and control of hazardous wastes by imposing
various waste management requirements on generators, transporters, and facilities that treat, recycle, store,
or dispose of hazardous wastes. The statute requires that hazardous waste generators notify EPA of their
activities and comply with a specific set of management standards and manifesting rules. Transporters are
subject to regulations imposing manifesting, packaging, labeling, and handling requirements. Facilities
that treat, store, or dispose of hazardous wastes (TSDFs) must obtain permits (or operate pursuant to
interim status1) that contain technical management standards. TSDFs are also subject to provisions
restricting the land disposal of untreated hazardous wastes. RCRA authorizes EPA-approved States to
assume responsibility for implementing the hazardous waste control program.
Under Subtitle D of RCRA, EPA has developed criteria applicable to the management of solid waste,
which is primarily regulated by State and local governments. The central Subtitle D regulation addresses
municipal solid waste landfills and is intended to be implemented by approved State solid waste permitting
programs. State programs must be consistent with Federal requirements. In contrast to Subtitle C,
Subtitle D provides for no federal enforcement authority.
Subtitle I of RCRA establishes rules for underground storage tanks (USTs) containing petroleum or
hazardous substances. These rules focus on preventing, detecting, and correcting releases of regulated
substances. USTs rules are predominantly implemented by the States.
1 Existing facilities that become subject to hazardous waste regulations are allowed to continue operating under interim
status requirements, which parallel permit standard requirements, while they seek RCRA permits. Requirements presented
below apply to both permitted and interim status treatment, storage, or disposal facilities unless specified.
Solid Waste-1
November 1995
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SOLID WASTE PRtiGRAM
STATUTE; RESOURCE CONSERVATION ANJ> RECOVERY ACT (RCRA)
Regulated Community: Hazardous Waste Generators
Enforcement Authority: Federal/State
Self Monitoring Requirements:
• Determine if waste is listed hazardous waste or exhibits a hazardous characteristic
• Prepare manifest identifying generator, transporter, wastes, and designated facility (if waste is
transported offsite for treatment, storage, or disposal
• Compile data on wastes generated, transporters, and treatment, storage, and disposal facilities
(TSDFs) [for Biennial Report]
Reporting Requirements:
• Exception Report/If large quantity generators do not receive a copy of the manifest within
45 days
• Biennial Report/Every 2 years
Recordkeeping Requirements:
• Test results and waste analyses/3 years from date waste was sent to TSDF
• Copies of signed manifests/3 years from date waste accepted
• Copies of Biennial Reports and Exception Reports/3 years from due date of report
Regulated Community: Hazardous Waste Transporters
Self Monitoring Requirements:
• Verify accuracy of hazardous waste manifest
Reporting Requirements:
• Notice to the National Response Center and written report to the Department of Transportation
of any discharge of hazardous waste during transport
Solid Waste-2
November 1995
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SOLID WASTE PROGRAM
STATUTES RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Recordkeeping Requirements:
• Manifests/3 years from date waste was accepted by initial transporter
• For shipment delivered to the designated facility by water (bulk shipment) a copy of shipping
papers containing all the information required on the manifest (excluding the EPA ID numbers,
generator certification, and signatures) must be retained/3 years from date waste was accepted
by the initial transporter
• For shipment by rail, a copy of the manifest and shipping papers must be maintained/3 years
from date waste was accepted by the initial transporter
• For shipments out of the U.S, a copy of the manifest must be maintained/3 years from date
waste was accepted by the initial transporter
Solid Waste-3
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Regulated Community:
Waste TSDFs: General
Self Monitoring Requirements:
• Chemical and physical analysis of hazardous waste/Prior to treating, storing, or disposal (new
analysis required if change in process)
• Verify manifest or shipping paper
• Identify and reconcile discrepancies in manifests
• Inspect for conditions that could cause release of hazardous waste or pose threat to human health
or the environment/Based on self-developed schedule
• Ground water monitoring program:
- Detection monitoring for indicator parameters: specific conductance, total organic carbon,
and total organic halogen/When exceedances are detected
- Compliance monitoring: for conformance with limits for listed hazardous constituents
detected in ground water and reasonably expected to be derived from waste in regulated units
- Corrective action monitoring: for conformance with limits for listed hazardous constituents
detected in ground water and reasonably expected to be derived from waste in regulated units
by removing the hazardous constituents or treating them in place
Interim status facilities:
• Develop ground-water sampling and analysis plan:
- Pollutants affecting drinking water: arsenic; barium; cadmium; chromium; fluoride; lead;
mercury; nitrate; selenium; silver; endrin; lindane; methoxychlor; toxaphene; 2,4-D; 2,4,5-
TP; radium, gross alpha, gross beta, turbidity, coliform bacteria
- Parameters establishing ground water quality: chloride, iron, manganese, phenols, sodium,
and sulfate
- Parameters used as indicators of ground-water contamination: pH, specific conductance, total
organic carbon, and total organic halides
Solid Waste-4
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Reporting Requirements:
• Contingency plan to local police, fire departments, hospitals, and State and local emergency
response teams
• Copy of signed manifest to generator/Within 30 days of delivery
• Report for waste not accompanied by a manifest/Within 15 days of receiving the waste
• Biennial report with generator, waste, and treatment, storage, and disposal data/Every 2 years
Ground Water Monitoring:
• Notify EPA of statistically significant contamination or exceedance of applicable concentration
limits/Within 7 days
• Reports on effectiveness of corrective action program/2 times a year
• For interim status facilities:
- Notify if significant increase in pH, specific conductance, TOC, or total organic
halogens/Within 7 days
- Ground water quality assessment plan/Within 15 days
— Results of the plan/Annually
- If no increase:
— Concentrations of drinking water constituents/Quarterly
— Results of pH, specific conductance, TOC, and total organic halogens
monitoring/Annually
Solid Waste-5
November 1995
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SOLID WASTE PROGRAM
STATUTE; RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Recordkeeping Requirements:
Note: Because many TSDF requirements related to non-release/routine operations are designed to
be self-monitoring without the official transmitted to EPA/State, records must be retained onsitefor
at least 3 years to allow for observations by inspectors.
• Waste analysis plan/Maintain for 3 years
• Contingency plan/Maintain for 3 years
• Manifests/3 years from date of delivery
• Inspection log/3 years from the date of each inspection
• Operating log: waste received; treatment, storage or disposal method/date; location and quantity
of waste; records of waste analyses; incidents; inspections; notices; closure estimates;
minimization certification; and land disposal restriction data/Maintain until closure of facility
• Ground water monitoring data/In operating record
Interim status facilities: •
• Sample analyses from groundwater plan/In operating record
Regulated Community: Hazardous Waste TSDFs: Containers
Self-Monitoring Requirements:
• Inspect container storage areas for leaks and deterioration/Weekly
Reporting Requirements:
• None
Recordkeeping Requirements:
• None
Solid Waste-6'
November 1995
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SOLID WASTE PROGRAM
STATUTE; RESOXJRCE CONSERVATION AND RECOVERY ACT (RCRA)
Regulated Community: Hazardous Waste TSDFs: Tanks
Self-Monitoring Requirements:
• Assess (in writing) existing tank systems without secondary containment:
- follow established schedule for inspecting overfill controls
- inspect aboveground portions of the tank, monitoring data and leak detection equipment, and
materials and areas surrounding the tanks
- inspect cathodic protection systems/Within 6 months and annually thereafter
- inspe'ct or test sources of impressed current/Bimonthly
• Conduct waste analyses or obtain documentation regarding compatibility of interim status tank
system used to treat or store a hazardous waste substantially different from the waste previously
treated or stored, or using a different process than previously used
Reporting Requirements:
• For new tank systems, assessment regarding system's integrity for storing hazardous waste
Recordkeeping Requirements:
• Tank integrity assessment/Maintain on file for 3 years
• Inspected items in the operating record
Regulated Community; Hazardous Waste TSDFs: Surface Impoundments
Self-Monitoring Requirements:
• Inspect to detect evidence of malfunction in or improper operation of overtopping controls,
sudden drops in levels, and signs of deterioration in containment devices/Weekly and after
storms
• Interim status impoundments: inspect freeboard/At least daily
• Conduct waste analyses or obtain documentation regarding compatibility of impoundment used to
treat or store a hazardous waste substantially different from the waste previously treated or
stored, or using a substantially different process than previously used
Solid Waste-7
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Reporting Requirements:
• None
Recordkeeping Requirements:
• Amount of liquid removed from each sump for new, lateral expansions, and replacement
impoundments/Weekly during active life and closure period; monthly after final cover
Regulated Coinmunity: Hazardous Waste TSDFs: Waste Piles
Self-Monitoring Requirements:
• Inspect to detect malfunctions in or improper operation of run-on/run-off control systems, proper
functioning of wind dispersal control systems, and proper functioning of leachate collection and
removal systems/Weekly and after storms
• Analyze interim status units that receive hazardous wastes that may be incompatible with wastes
in the pile/Before adding wastes to pile
Reporting Requirements:
• None
Recordkeeping Requirements:
• Amount of liquid removed from each sump for new lateral expansions and replacement
piles/Weekly during the active life and closure period
Regulated Community: Hazardous Waste TSDFs: Land Treatment
Self-Monitoring Requirements:
• Monitor unsaturated zone, including the soil and soil-pore liquid, to determine whether
hazardous constituents migrate out of the treatment zone
• Interim status facilities: Conduct additional waste analyses to determine (1) whether any
constituent exceeds Toxicity Characteristic levels, (2) for listed hazardous wastes, the level of
constituents that caused the waste to be listed as hazardous, and (3) where food chain crops are
grown, the concentration of arsenic, cadmium, lead and mercury, unless owner has
documentation the constituent is not present
Solid Waste-8
November 1995
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SOLID WASTE PROGRAM
STATUTE; RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Reporting Requirements:
• Notify EPA in writing of significant increases in hazardous constituents below the treatment
zone/Within 7 days
Recordkeeping Requirements:
• Hazardous waste application dates and rates (in operating record)
Regulated Community: Hazardous Waste TSDFs: Landfills
Self-Monitoring Requirements:
• Inspect to detect (1) malfunctions in or improper operation of run-on/run-off controls, (2) proper
function of wind dispersal control systems, and (3) proper functioning of leachate collection and
control systems/Weekly and after storm events
Reporting Requirements:
• None
Recordkeeping Requirements:
Amount of liquid removed from sump for new lateral expansions and replacement landfills/Weekly
during active life and closure period; monthly after closure
Solid Waste-9
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
- ' • • - ., ^ j j
Regulated Community; Hazardous Waste TSDFs; Incinerators
Self-Monitoring Requirements:
• Identify and quantify hazardous constituents in feed and verify waste feed is within applicable
permit limits
• Visually inspect for leaks, spills, fugitive emissions/Daily
• Test emergency waste feed cutoff system/Weekly
• Monitor combustion temperature, waste feed rate, indicator of combustion gas velocity, and
carbon monoxide/Continuously
• Interim status facilities: conduct analyses sufficient to obtain steady state operation and
determine pollutants emitted (minimum - determine heating value, halogen and sulfur content,
and concentration of lead and mercury unless documented not present)
• Monitor instruments related to combustion and emission control/Every 15 minutes
Reporting Requirements:
• None
Recordkeeping Requirements:
• Monitoring and inspection data (in operating log)
Regulated Community: Hazardous Waste TSDFs; Drip Pads
Self-Monitoring Requirements:
• Existing drips pads: assess for conformance with applicable design and performance
standards;upgrade as necessary/Annually
• Inspect to detect evidence of: (1) malfunctions in or improper operation of run-on/run-off
controls, (2) proper functioning of leak detection system, and (3) deterioration of the drip pad
surface/Weekly and after storms
Solid Waste-10
November 1995
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SOLID WASTE PROGRAM
STATUTE; RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Reporting Requirements:
• Upgrade plans/No later than 2 years before upgrades are complete
• Drawings and certification for upgrades/Upon completion
Recordkeeping Requirements:
• None
Regulated Community: Hazardous Waste TSDFs: Air Emission Standards2 fo* Process Vents
and Equipment Standards3
Self-Monitoring Requirements:
• Routine monitoring to detect leak from process vents, pumps in light liquid service compressors,
sampling connecting systems, etc.
Reporting Requirements:
• Report outlining which valves and connectors were not fixed during preceding 6 mpnths/2 times
a year
Recordkeeping Requirements:
• Design documentation and monitoring, operating, and inspection information for each closed-
vent system and control device (in operating log)
• Information describing the different types of equipment regulated; leaks detected and repairs
undertaken; design documentation, and monitoring, operating and inspection information;
information regarding valves subject to regulation; and design capacity information for waste
management unit (in operating log)
2 Applies to TSDFs with process vents associated with distillation, thin-film evaporation, solvent
extraction, or air or steam stripping operations that manage hazardous wastes with organic
concentrations of at least 10 ppmw that are managed in units subject to permit requirements or
recycling units at facilities otherwise subject to permit requirements.
3 Applies to TSDFs with process vents associated with distillation, fractionation, thin-film
evaporation, solvent extraction, or air or steam stripping operations that manage hazardous
wastes with organic concentrations of at least 10-ppmw that are managed in units subject to
permit requirements or recycling units at facilities otherwise subject to permit requirements.
Solid Waste-11
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Regulated Community; Hazardous Waste TSPFs: Containment Buildings
Self-Monitoring Requirements:
• Obtain certification that design meets design and performance requirements
• Inspect monitoring and leak detection data as well as building and surrounding area/At least
weekly
Reporting Requirements:
• Notify EPA of releases/Verbally within 7 days, written within 14 working days
• Notification/Upon completing repairs and cleanup
Recordkeeping Requirements:
• Releases (in operating record)
• Findings from monitoring and leak detection data and building/grounds/In operating log
• Description of procedures used to maintain integrity of areas lacking secondary containment (in
operating log)
Regulated Community; Hazardous Waste TSDFs; Thermal Treatment (Tnterim Status Only)
Self-Monitoring Requirements:
• Analyze waste not previously treated in process for heating value, halogen and sulfur content,
and lead and mercury, unless documented not present.
• Monitor temperature and emission control instruments/Every 15 minutes
• Observe stack plume/Hourly
• Inspect process/Daily
Reporting Requirements:
• None
Solid Waste-12
November 1995
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SOLID WASTE PROGRAM
STATUTE; RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Recordkeeping Requirements:
• Waste analysis records
• Records of inspections/3 years
Regulated Community: Hazardous Waste TSDFs: Chemical, Physical, Biological Treatment
(Interim Status Only)
Self-Monitoring Requirements:
• Conduct waste analysis or obtain documentation of similar treatment for waste not previously
treated in process or new process
• Inspect discharge control/safety equipment and monitoring data/Daily
• Inspect treatment process and discharge confinement structure materials/Weekly
Reporting Requirements:
• None
Recordkeeping Requirements:
• Waste analysis records
• Records of inspections/3 years
Solid Waste-13
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Regulated Community; Hazardous Waste Burned in Boiler and Industrial Furnaces QBIFs)
Self-Monitoring Requirements:
• Analyze hazardous waste for expected listed constituents
• Monitor feed rates/composition of hazardous waste/feedstocks, CO, HC, oxygen
• Sample/analyze hazardous waste, residues, emissions/Upon request
• Visually inspect BIF/Daily
• Test automatic cutoff system/Weekly
• Interim status facilities: Provide certification of pre-compliance data (facility, process, emissions
data)
• Provide certification of compliance data (based on emissions testing)
Reporting Requirements:
• None
Recordkeeping Requirements:
• Information from self monitoring (in operating log)
• Interim status facilities: All data in operating record/Until closure of unit
Regulated Community: Municipal Solid Waste Landfills
Self Monitoring Requirements:
• Detect and prevent hazardous waste and PCBs from disposal in MSWLFs
• Groundwater monitoring:
- Detection monitoring for inorganics and organics - if significant increases over background
levels, conduct assessment monitoring
- Assessment monitoring for inorganics and organics
- Establish background for compounds detected
- Continue monitoring/2 times a year
Frequency: During active life and post-closure care
Solid Waste-14
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Reporting Requirements:
• Notify State of location of recordkeeping information
• Notify State of significant increases noted under groundwater detection or assessment monitoring
Recordkeeping Requirements:
• Location restriction demonstration, inspection records, remediation plans, design documentation
for leachate or condensate placement, closure/post-closure care plans and associated data,
financial assurance documentation, and small community exemption data
• Significant increases noted under detection or assessment monitoring/In operating log
Regulated Community: Underground Storage Tanks (USTs) Containing Hazardous Substances
and Petroleum
Self Monitoring Requirements:
• Test steel USTs with cathodic corrosion protection/Within 6 months of installation and every
3 years thereafter
• Inspect impressed current systems/Every 60 days
• Monitor petroleum and existing hazardous USTs for releases (using automatic gauging, vapor
monitoring, ground water monitoring, interstitial monitoring, or other methods/Every 30 days
• As an alternative, inventory controls and tightness testing/Every 5 years until 1999 or 10 years
after installation or upgrade, whichever is later
• Inspect new hazardous USTs for releases/Every 30 days
• Investigate all suspected UST releases, including system and site checks/Within 7 days of
suspected release
Solid Waste-15
November 1995
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SOLID WASTE PROGRAM
STATUTE: RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Reporting Requirements:
• Notify State or local supervisory agency of new tank and provide description of tank
• All releases/Within 24 hours
• Unusual operating conditions, monitoring results indicating release, corrective actions planned or
taken, and permanent closure or change in service
• Spills or overfills of 25 gallons of petroleum or exceedance of reportable quantities of hazardous
substance/Within 24 hours
Recordkeeping Requirements:
• Analysis of site corrosion potential, documentation of operation of corrosion protection system,
documentation of system repairs, compliance with release detection requirements, results of site
investigation at closure, release detection system performance claims, and documentation of
maintenance and repair of release detection equipment
• Sampling, testing, and monitoring results/1 time a year
Note: In the next four sections, the type of information included represents the range of
possible options for completion of these sections; it does not represent actual information
for the U.S. solid waste program.
Data Quality Assurance:
Established sampling and analyses procedures
Established calibration and performance techniques
Established laboratory practices
Required certification (either by self or a third party)
Inspections
Laboratory performance evaluations
Data Use:
Determine compliance and take appropriate enforcement actions
Identify facilities requiring follow-up inspections
Develop general targeting strategies for compliance activities
Target chemical/activities for regulatory development
Assess state of the environment
Solid Waste-16
November 1995
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SOLID WASTE PROGRAM
STATUTE; RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
Data Management:
« Hard copy
• Computer databases
• Available to the public
Types of Enforcement Actions:
• Tracking of noncompliance
• Common enforcement actions for violations, such as failure to self monitor or report
Solid Waste-17
November 1995
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APPENDIX A-6
U.S. PROGRAM REQUIREMENTS - PESTICIDES
-------
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FONGICIDE, AND ROBENTICIDE ACT
Regulated Commtmityt All Pesticide Producers*
Enforcement Authority; State
Self Monitoring Requirements:
None
Reporting Requirements:
• For each pesticide produced, the amount (1) produced during the past year, (2) sold or
distributed during the past year, or (3) estimated to be produced during the current
year/Annually on or before March 1
1 For purposes of this study, the term pesticide refers to all pesticides, pesticide active ingredients, or pesticide
devices.
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
Recordkeeping Requirements:
• Records showing product name, registration number, amounts per batch, and batch
identification/2 years
• Records showing brand names and quantities of pesticides produced/2 years
• Records showing the following information regarding the receipt by the producer of all
pesticides, including:
- brand name of the pesticide or device, or common or chemical name of the pesticide active
ingredient
- name/address of shipper
- name of delivering carrier
- date received
- quantities received/All for 2 years
• Records showing the following information regarding the shipment of all pesticides:
- brand name of pesticide or device or the common or chemical name of the pesticide active
ingredient
- name/address of consignee
- name of originating carrier
- date shipped or delivered for shipment/All for 2 years
• Inventory records (i.e., quantities in stock that were produced)/Until next inventory record is
prepared
• Copies of all domestic advertising of the restricted uses of any RUP/2 years
• For pesticides manufactured for export only:
- copies of the specification or directions of the foreign purchaser for the production of such
pesticides
- copies of labels or labeling
- copies of a statement signed by the foreign purchaser acknowledging that he/she understands
that such pesticide is not registered for use in the U.S. and cannot be sold for use in the
U.S./AH for 2 years
• Records of the method of disposal, date of disposal, location of the disposal site, and the type
and amount of pesticides disposed of/20 years (may forward to EPA after 3 years)
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
• Records of any tests performed on human beings, including:
- names/addresses of subjects
- dates of tests
- types of tests
- written consent of subjects
- all information/instructions given to subjects about the tests/All for 20 years (may forward
to EPA after 3 years)
• Records containing research data relating to registered pesticides, including all information
submitted in support of registration, all underlying raw data, and interpretations and evaluations
of data/As long as the registration is valid and the producer is in business
Regulated Community: Holders of Pesticide Registrations (Registrants)
Self Monitoring Requirements:
• Certify that those pesticides required to be in child-resistant packaging meet the established
effectiveness, compatability, and durability standards/When applying for registration or within
6 months of notification that the pesticide must be in child-resistant packaging
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
Reporting Requirements:
• If registrant has additional factual information regarding unreasonable adverse effects on the
environment, report the following information:
- All lexicological studies
- Epidemiological studies
- Efficacy studies
- Studies of dietary or environmental pesticide residues
- Toxic or adverse effect incident reports
- Failure of performance incident reports
- Dietary or environmental pesticide residue incident reports
Frequency of reporting: Immediately, but no later than 15 working days after information becomes
known
• For those pesticides required to be in child-resistant packaging, a certification statement
containing (1) name and EPA registration number of the product to which the certification
applies, (2) registrant's name and address, (3) date, (4) name, title, and signature of the
company official making the certification, and (5) a statement that the packaging meets the
established effectiveness, compatability, and durability standards/When applying for
registration or within 6 months of notification that the pesticide must be in child-resistant
packaging
Recordkeeping Requirements:
• For those pesticides required to be in child-resistant packaging:
- description of the package including (1) the dimension and composition of container and (2)
the closure or child-resistant mechanism
- copy of the certification statement (see above)
- one of the following types of records verifying the package is child resistant: (1) test data
based on established protocol, (2) test data, not based on established protocol, or
measurements of the package and an explanation as to why the data or measurements
demonstrate the package is child resistant, (3) test data on a different package and an
explanation of why the data demonstrate the package is child resistant, or (4) written evidence
indicating testing was conducted in conformance with the established protocol
- Records verifying the package meets the established compatibility and durability standards
Retention time: As long as the registration of the pesticide is in effect
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICJDE ACT
Regulated Community: Experimental Use Permittees
Self-Monitoring Requirements:
None
Reporting Requirements:
• Reports containing the following information:
- name/address of shipper of any pesticide covered by the permit and place or places from
which shipped
- name/address of consignee
- amount of each shipment
- total quantities of the pesticide shipped and used during the reporting period
- total quantities of technical material imported to formulate pesticides covered by the permit
- list of states into which shipments were made
- summaries of the progress made and data obtained during the report period
Frequency of reporting: Every 3 months
• Final report containing the following information:
- all data gathered during the testing program
- description of the disposition of any pesticide containers and any unused pesticides including
amounts disposed of and the method and site of disposition
- method of disposition of affected food and/or feed
Frequency of reporting: 180 days after expiration of the permit
Recordkeeping Requirements:
None
Regulated Community: Commercial Applicators
Self-Monitoring Requirements:
None
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
Reporting Requirements:
None
Recordkeeping Requirements:
• Name and address of the person for whom the pesticide was applied
• Location of the pesticide application
• Target pest(s)
• Specific crop or commodity and site to which the pesticide was applied
• Year, month, day, and time of application
• Trade name and EPA registration number of pesticide applied
• Amount of pesticide applied and percentage of active ingredient per unit of pesticide used
• Type and amount of pesticide disposed of, method of disposal, date(s) of disposal, and location
of disposal site
Retention time: 2 years from date of application
Regulated Community: Restricted Use Pesticide (RtJP) Retail Dealer
Self-Monitoring Requirements:
None
Reporting Requirements:
• Business name and name and address of all dealerships/60 days after becoming an RUP retail
dealer
• Revisions, as appropriate, to initial report/Within 10 days of any changes to initial report
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
Recordkeeping Requirements:
• When a retail dealer makes an RUP available to a certified applicator, the following records
must be kept:
- Name and address of the residence or principal place of business of each person to whom the
pesticide was made available
- Certification number on the document evidencing that persons certification, the State that
issued the document, the expiration date of the certification, and the categories in which the
applicator is certified
- Product name, EPA registration number, and the State special local need registration number
- Quantity of the pesticide made available for use
- Date of the transaction
• When a retail dealer makes an RUP available to an uncertified person for application by a
certified applicator, the following records must be kept:
- Name and address of the residence or principal place of business of each person to whom the
pesticide was made available for use by a certified applicator
- Name and address of the residence or principal place of business of the certified applicator
who will use the restricted use pesticide
- Certified applicator's certification number, the State that issued the certification document,
the expiration date of the certification, and the categories in which the applicator is certified
- Product name, EPA registration number, and the State special local need registration number
- Quantity of the pesticide made available for use
- Date of the transaction
Retention time: 2 years after the date of the transaction for all records
November 1995
-------
PESTICIDES PROGRAM
STATUTE: FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
Data/Information Quality Assurance:
Entity OA activities:
Enforcement Authority data/information verification activities:
• Inspections of regulated entities
Data/Information Management:
• The Section 7 Tracking System contains the information submitted by pesticide producers in the
yearly reports (using standardized forms)
Data/Information Use:
Types of Enforcement Actions:
• Civil penalties
• Criminal penalties
November 1995
-------
APPENDIX A-7
U.S. PROGRAM REQUIREMENTS - Toxic SUBSTANCES
-------
-------
TOXIC SUBSTANCES PROGRAM
STATUTE: TOXIC SUBSTANCES AMD CONTROL ACT
Regulated Community: Manufacturer, Importer, processor,
(and sometimes distributor) of chemical substances or mixtures
specified by the regulations
Enforcement Authority: Federal
Note: Only Section 8 self-monitoring, reporting, and recordkeeping requirements are
included in this table.
Self Monitoring Requirements:
• Must complete a Preliminary Assessment Information Report (PAIR) that includes:
- Name and address of plant
- Quantity of chemical manufactured or imported for use or sale
- Process information such as quantity lost to the environment and in wastes
- Worker information such as number per processes, number of workers by type of work
- Manufactured and by-products
- Customer/industrial products produced
- Trade names
- Customer's process categories/Within 60 days after chemical is listed
- Chemical identity
• Must complete a Comprehensive Assessment Information Report (CAIR) that includes:
- Manufacturer, importer, and processor information
- Manufacturer, importer, and processor volume and use
- Processor raw material identification
- Physical/chemical properties
- Environmental fate
- Economic and financial information
- Manufacturing and processing information
- Residual treatment, generation, characterization, transportation, and management
- Worker exposure
- Environmental release/Within CAIR coverage period (designated by EPA once
chemical is listed)
November 1995
-------
TOXIC SUBSTANCES PROGRAM
STATUTE: Toxic SUBSTANCES AND CONTROL ACT
Self Monitoring Requirements (continued):
• Must complete an Inventory Update Report (IUR) that includes:
- Chemical identity
- Production volume at each site location
- Plant site location
- Site-limited status/Once every 4 years
• Must keep record of allegations of any substance or mixture of significant adverse
reaction/As they are made
Reporting Requirements:
• PAIR/Within 60 days after chemical is listed
• CAIR/Within CAIR coverage period (designated by EPA once chemical is listed)
• lUR/Once every 4 years
• Health and safety studies for listed chemicals, including:
- Any studies on a listed substance or mixture that are unpublished
- Ongoing studies
- Initiated studies
- Studies previously sent to Federal agencies without confidentiality claims/Within 60 days
after chemical is listed
• Information regarding a suspected or known substantial risk (Notification of Substantial
Risk)/In emergency situations, verbal notification within 24 hours; non-emergency
situations, written notification within 15 working days
• All allegations of previously adverse reactions to any substance or mixture/No later than
45 days after letter from EPA or Federal Register notice
November 1995
-------
TOXIC SUBSTANCES PROGRAM
STATUTE: Toxic SUBSTANCES AND CONTROL ACT
Recordkeeping Requirements:
• All CAIRs submitted, materials that verify the CAIR, and notices sent to customers/3 years
• IIJRs/At least 4 years
• Site-specific production records
• Allegations of previously unknown significant adverse reactions to any substance or
mixture, including:
- Date and substance of the allegation
- Name of the implicated substance
- Alleged effect(s)
- Results of any self-initiated investigation/30 years for allegations made by employees
and 5 years for all others
Data Quality Assurance:
Regulated Entity under Section 4 Quality Assurance Activities:
- Any person subject to a Section 4 order or rule must certify that the study meets
prescribed GLP protocols
Enforcement Authority Data Verification Activities:
• Audit/Inspections of regulated community
• Joint inspections of chemicals/pharmaceutical producers (with FDA) and importers (with
U.S. Customs Service)
November 1995
-------
TOXIC SUBSTANCES PROGRAM
STATUTE: Toxic SUBSTANCES AND CONTROL ACT
Data/Information Management:
Data Use:
Data collected by EPA regarding toxic substances is used primarily to:
• Determine the effect of chemical substances on human health and the environment; and
• Regulate chemical substances and mixtures which present and unreasonable risk of injury to
health or the environment, and to take action with respect to chemical substances and
mixtures which are imminent hazards.
Types of Enforcement Actions:
• Penalties for violations of TSCA can either be civil, criminal, or both.
November 1995
-------
APPENDIX B-l
MASS-FLOW CHECK VALUES
FOR NETHERLANDS EMISSIONS REGULATIONS
-------
-------
APPENDIX 6.
Mass-flow check levels for selecting the appropiate
control method
substances
category class
• m,Csrc
Ext extremely hazardous substances
see: par. 4.2.3
sA
carcmogerucs
class C.I 0,5
class C.2 5,0
class C.3 25
particulates 1000
inorganic particulates
class sA.l 1,0
class sA.2 5,0
class sA.3 25
gA inorganic vapours and gases
class gA.l 10
class gA.2 50
class gA.3 300
class gA.4 5000
sO organic particulates
class O.I 100
class O.2,3 250
gO organic vapours and gases
class gO.l 100
class gO.2 2000
class gO.3 3000
odour
see: par 4.2.4
-------
-------
APPENDIX C-l
SELF MONITORING FREQUENCIES
FOR U.K. DRINKING WATER PROGRAM
-------
-------
TABLE 3: Sampling frequencies at consumers' taps
Parameters
Trihalomethanes
Tetrachloromethane
Trichloroethene
Tetrachloroelhene
Copper
Lead
Zinc
Pesticides(i)
Polycyclic aromatic
hydrocarbons(ii)
Water Supply Zone
Volume Population
distributed Supplied
(m* Id) for
domestic purposes
^7000 =S 3 5000
7001-10000 35001-50000
Sampling Frequency (number per annum)
Reduced
I
1
Standard
4
4
Increased
12
24
Notes (i) ie any fungicide, herbicide or insecticide; increased or reduced sampling, where required or permitted,
may be confined to the substance in question.
(ii) The sum of the detected concentrations of fluoranthene, benzo 3.4 fluoranthene, benzo 11.12 fluoranthene,
benzo 3.4 pyrene, benzo 1.12 perylene and indeno (1,2,3-cd) pyrene.
TABLE 4: Sampling frequencies at consumers' taps
Parameters
Sampling Frequency
(number per annum)
Standard Increased
Chloride
Sulphate
Calcium
Magnesium
Sodium
Potassium
Dry residues
Oxidizability
(permanganate value)
Total organic carbon
Boron
Surfactants
Phosphorus
Fluoride
Barium
Silver
Arsenic
Cadmium
Cyanide
Chromium
Mercury
Nickel
Antimony
Selenium
Total hardness
Alkalinity
12
23
-------
a.
CL
Q.
3
1/3
W
01
en
«SJ
'o
u
3
er
bo
.S
"3.
UJ
J
CQ
S
?
g
Q
S.
i.
-S
S
t:
t-
1
"t:
^
1
ll
N' -^
„ o
li
\O ^O
Tf TJ- u-i OO »O O O
£;rioooooo
— ro VO ON OO OO OO
Tj-rrvo^io^ooc
8 OOOOOOOOO
OOOOOOOOO
— n 0 0 0
\ '. \ i ' 1 •. \ •.
OOOOC^CJOOO
V1OOOOOOOO
unooooooo
— rN ^o o *^i o o
oooooooooo
oooooooooo
— OOOOOOOOO
w. — r-iTTOC3OOOO
' — ol r^. vO O O
1 1 ' 1 1 , 1 i • i
OOOOOOOOO
— oooooooo
— C'l rO ^O ^3
O vi
II II
O ^
24
-------
TABLE 6: Sampling frequencies at consumers' taps
Parameters
Tola! coliforms ~1
Faecal coliforms 1
Residual disinfcciani |
Colony counts J
Water Suppl\
1 'iituine
distributed
: in d / /or
domestic purposes
silOO
101-1000
1001-2000
2001-4000
Zone
Population
Supplied
s£500
501- 5000
500 1-- 10000
10001-20000
20001-50000
Sampling Frequency
(number per annum i
Standard
12
12
24
48
at the rate of 1 2 per 5000
population except in the case of
colony counts where the
standard number is 52.
TABLE 7: Sampling,frequencies for treatment works
Parumeiers
\, Total and faecal coliforms, 1
residual disinfectant and >
colony counts J
2. Total and faecal coliforms \
and residual disinfectant J
3. Colony counts
Volume, of water
supplied (m*ldj for
domestic purposes
<2000
2001-6000
6001-12000
> 1 2000
>6000
Sampliing frequency
(number per annum}
Reduced
12
52
104
104
52
Standard
52
104
208
365
104
25
-------
-------
APPENDIX D-l
INDIA'S ANNUAL STATEMENTS
-------
-------
MINISTRY OF ENVIRONMENT & FORESTS
Annexure - III
NOTIFICATION
New Delhi, the 22nd April, 1993
G.S.R. 386(e)-In exercise of the powers conferred by sections 6 and 25 of the Environment (Protection) Act,
1986 (29 of 1986), the Central Government hereby makes the following rules further to amend the Environment
(Protection) Rules, 1986, namely -
1- (1) These rules may be called the Environment (Protection) Amendment Rules, 1993.
(2) They shall come into force on the date of their publication hi the Official Gazette.
2. In the Environment (Protection) Rules, 1986 -
(a) In Rule 14 -
(i) for the words "audit report" wherever they occur, the word "statement" shall be
substituted.
(ii) for the figures, letters and words "15th day of May" the words "thirtieth day of
September," shall be substituted.
(b) In Appendix 'A' for FORM-V, the following shall be substituted, namely:-
"FORM-V"
(See rule 14)
Environmental Statement for the financial year ending the 31st March.,
PART - A
(i) Name and address of the owner/occupier of the industry operation or process.
(ii) Industry category Primary - (STC Code) Secondary - (SIC Code)
(iii) Production capacity - Units -
(iv) Year of establishment
(v) Date of the last environmental statement submitted.
B-6
-------
A\DIV834\339P\NTFCTION.DOC
Waste and Raw Material Consumption
(1) Water consumption mVd
Process
Cooling
Domestic
PART - B
Nature of Products
1)
2)
3)
Process Water Consumption per unit of product output
During the previous financial year
During the current financial year
(2) Raw material consumption
*Nature of Raw material
Process Water Consumption per unit of product output
During the previous financial year
During the current financial year
* Industry may use codes if disclosing details of raw material would violate contractual obligations, otherwise
all industries have to name the raw materials used.
PART-C
Pollution discharged to environment/unit of output
(Parameter as specified in the consent issued)
Pollutants
(a) Water
(b) Air
Quantity of pollutants
discharged (mass/day)
Concentration of
pollutants in discharges
(mass/volume)
Percentage of variation
from prescribed
standards with reasons
B-7
-------
ANDIV834\339P\NTFCTION.DOC
PART -D
HAZARDOUS WASTES
(as specified under Hazardous Wastes/Management and Handling Rules, 1989)
Hazardous Wastes
(a)
(b)
From process
From pollution control
facilities
Total Quantity (kg)
During the previous financial year
During the current financial year
PART - E
SOLID WASTE
Solid Waste
(a)
(b)
(CXD
(2)
(3)
From process
From pollution control
facility
Quantity recycled or
reutilized within the unit
Sold
Disposed
Total Quantity
During the previous financial year
During the current financial year
PART -F
Please specify the characterizations (in terms of composition and quantum) of hazardous as well as solid
wastes and indicate disposal practice adopted for both these categories of wastes.
PART -G
Impact of the pollution abatement measures taken on conservation of natural resources and on the cost of
production.
B-8
-------
A\DIV834\339P\NTFCTION.DOC
PART -H
Additional measures/investment proposed for environmental protection including abatement of pollution,
prevention of pollution.
PART - I
Any other particulars for improving the quality of the environment.
(F. No. Q-15015/1/90/CPA)
Mukul Sanwal, Joint Secretary
B-9
-------
APPENDIX E-l
ELECTRONIC REPORTING REQUIREMENTS
FOR U.S. UTILITIES UNDER AIR PROGRAM
-------
-------
Electronic Reporting Mayi995
CFR 75.62, 75.63, 75.64) version 1.3
Introduction
The Acid Rain Program regulations require submission of Continuous Emission Monitoring Systems (GEMS)
certification applications and quarterly reports (including monitoring plan updates) in electronic format
(40 CFR 75.63 and 75.64). The required data elements are listed and described at 40 CFR 75.50-75.52. This
booklet. Version 1.3, replaces Version 1.1. These electronic file record structures will be used by software
developers and utilities to develop computer-generated reports which meet the requirements of 40 CFR Part 75.
The Electronic File Formats and Record Structures Tables provide the necessary information for constructing
electronic files to submit electronic reports to the U.S. Environmental Protection Agency. Electronic Report Record
Types (Table 1) provides an index which lists all the possible record types which may be submitted in an electronic
report. Tables 2, 3, and 4 define the specific computerized layout or "record structures" of the electronic reports,
containing the following types of data: Quarterly Emission Data (Table 2), Monitoring Plan Data (Table 3), and
Certification-OA/QC Test Data (Table 4).
Tables 2, 3, and 4 provide the record structures which define the order, length, and placement of information
within the electronic report or "file." Specifically, the Tables provide the Record Type, Type Code, Start Column,
Data Element Description, Units, Range, Length, and Fortran (FTN) Format for each data element in the electronic
report.
For detailed information on the use of these reporting formats, see the CEM Certification Handbook. May, 1995.
-------
Electronic Data Reporting - Version 1.3
Page 1
TABLE 1: ELECTRONIC REPORT RECORD TYPES
V '
ijjj*. J,
Off* *
Facility Data
(100)
Monitoring Data
(200)
Unit Data
(300)
f
**»«**# * J
Facility
Configuration
Pollutant Gas Concentrations
Diluent Gas Concentrations
Moisture Data
Volumetric Row
Daily Calibration and
Interference Check Data and
Results
Reference Method Backup
Quality Assurance Data
Unit Operating Data
SOj Mass Emissions
NO, Emissions Rate
•wortHK— -^r-*-^-
Facility ID Data
Record Types Submitted
SOj Concentration Data
NO, Concentration Data
CO, Concentration Data
CO i Concentration Data
Oj Concentration Data
Moisture Data
Volumetric Flow Data
Daily Calibration Test Data
Daily Interference Check Results
Hourly Pollutant and Diluent Concentration from RM Backup
Analyzers
Quality Assurance Run Data for Reference Method Analyzers or
Systems Used as Backup CEMS
Reference Method 2 ~ Use of Backup Flow Rate Monitor
Unit Operating Data
Quarterly Cumulative Emissions Data
Oil Fuel Row Rate
Gas Fuel Flow Rate
SO2 Mass Emissions Data
SO2 Mass Emissions Alternative Estimation Parameters for Oil
SOj Mass Emissions Alternative Estimation Parameters for
Natural Gas
S02 Mass Emissions Alternative Estimation Parameters for Oil
(Revised RT311)
SO2 Mass Emissions Alternative Estimation Parameters for
Natural Gas (Revised RT 31 2)
NO, Emissions Rate Data
NO, Emissions Hate Alternative Estimation Parameters for Oil
NO, Emissions Rate Alternative Estimation Parameters for
Natural Gas
NO, Emissions Rate Alternative Estimation Parameters for
Natural Gas (Revised RT 322)
•" f f SA*. '
m*mm*m
100
101
200
201
202
210
211
212
220
230
231
260
261
262
300
301
302
303
310
311
312
313
314
320
321
322
323
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Page 2
Electronic Data Reporting - Version 1.3
TABLE 1: ELECTRONIC REPORT RECORD TYPES
"""v" •"' %
' '""
«aoar
Unit Data
(300)
(continued)
Control Equipment Data
(400)
Monitoring Plan Information
(500)
Certification Test Data and
Results
(600)
- !
" "
S9&4BQ9?
CO, Mass Emissions
SO, Control Equipment
Operating Parameters
NO, Control Equipment
Operating Parameters
Qualifying Phase 1 SO,
Removal Equipment
Parameters
Units and Unit Pools
Systems/Components
Emissions Formulas
Span and Calibration Gas
Fuel Flowmetar Information
Reasons for Missing Data
Periods
riecertrfication Events
Calibration Error Tests
RATA/Blas Tests
Cycle/Response Time
RECORD TYPfS
ugssfiDnrre
CO, Mass Emissions
CO, Estimated Mass Emissions
SO, Control Equipment Operating Data
SO, Control Equipment Scrubber Module Operating Data
NO, Control Equipment Operating Data
SO, Post-Combustion Treatment and Control - Inlet Data
SO, Post-Combustion Treatment and Control - Outlet Data
SO, Pre-combustion Treatment and Control Data
Combustion Emission Controls
Unit Definition Table
Stack Definition Table
Unit Definition Table (Revised RT 500)
Stack Definition Table (Revised RT 501)
Monitoring Systems/Analytical Component Definition Table
Emission Formula Table
Span and Calibration Gas Table
Fuel Flowmetar Table
Missing Data Period Reasons
Monitoring System Recertification Event
7-Day Calibration Error Test Data and Results
Quarterly Linearity Test Data
Quarterly Linearity Test Results
Quarterly Leak Check Results
RATA/Bias Test Data
RATA/Bias Test Results
Reference Method Supporting Data for Gas RATAs
Reference Method 2 Supporting Data for Row RATAs
Cycle Time/Response Time Test Data and Results
Cycle Time/Response Time Test Data and Results (Revised
RT 620I
' ' ^
',
RgCOBBKtBMBEB
330
331
400
401
410
420
421
422
423
500
501
502
503
510
520
530
540
550
555
300
601
602
603
610
611
612
613
620
621
-------
Electronic Data Reporting - Version 1.3
Page 3
TABLE 1: ELECTRONIC REPORT RECORD TYPES
1 ^;- fclSOftDTYfeS
GROW?
Certification Test Data and
Results
(600)
(continued)
% s*aw»«H*? - I
Fuel Rowmeter Calibration
Alternative Monitoring
System Petition Test Data
and Rasults
Appendix E Test Records
newwi! TW •• ' \
Fuel Rowmeter Calibration Data
Fuel Flowmeter Calibration Results
Alternative Monitoring System Petition Data
Alternative Monitoring System Petition Results
NOx/Heat Input Con-elation Test Data
NOx/Haat Input Correlation Test Results
Oil Fuel Row During Test
Gas Fuel Row During Test
WgCOflO N18MBER
625
626
630
631
650
651
652
653
-------
Page 4-
Electronic Data Reporting - Version 1.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
'
Facility Identification
TYPE
eowr
100
'-
START
«0t
1
4
10
11
FACtUTTINfOSMAnoN
' •,
Record Type Code
ORISPL Number
Calendar quarter data contained in report (5=-more than 1
quarter)
Calendar year data contained in report
Records Types Submitted
101
1
4
10
16
23
26
Record Type Code
Unit ID
Stack/Pipe ID
Parameter reported
Record type used
# of records
YYYY
• .,
i
1-5
a 1993
Total Record Length
1
1-9999
t&i&ttt
3
6
1
4
FQflMEttT
(fTOJ
13
16
11
14
14
3
6
6
7
3
4
13
A6
A6
A7
13
14
Total Record Length 29
Available codes are:
S02CONC, S02MASS, FLOWRTi, NOXCONC, DILUENT, NOXRATE, CO2CONC, CO2MASS, OPERATN, OILRATE,
GASRATE, SO2RTIN, SO2RTOT
-------
Electronic Data Reporting - Version 1.3
Page 5
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
• . .. -3fc
~*§F
nwttwrm
SO. Concentration Data
J75.54(c)(1)
"i "•> >
COOK
200
MONITORING DATA
*Wk
1
4
10
13
16
22
24
29
35
41
-v ^**m*a**m** ,
POLLUTANT GAS CONCENTRATIONS
Record Type Code
Unit ID/ Stack ID
Component ID
Monitoring System ID
Date
Hour
Percent monitor data availability for SOa data
Average SO2 concentration for the hour
Average SO2 concentration for the hour adjusted for
bias
Method of determination code
* *" >
MM*
YYMMDD
HH
%
ppm
ppm
KANG*
00-23
0.0-100.0
01-12
Total Record Length
NO. Concentration Data
S?§.54(d)(1)-<3),(8)
201
1
4
10
13
16
22
24
30
Record Type Code
Unit ID/ Stack ID
Component ID
Monitoring System ID
Date
Hour
Average NO, concentration for the hour
Method of determination code
YYMMDD
HH
ppm
00-23
01-04
Total Record Length
CO, Concentration Data
S75.54(e)«MvH)
202
1
4
10
13
16
22
24
30
Record Type Code
Unit ID/ Stack ID
Component ID
Monitoring System ID
Date
Hour
Average C02 concentration for the hour
Method of determination code
YYMMDD
HH
%
00-23
01-06, 14
X-*
UMtKKj
3
6
3
3
6
2
5
6
6
2
42
3
6
3
3
6
2
6
2
31
3
6
3
6
2
6
2
13
A6
A3
A3
16
12
F5.1
F6.1
F6.1
12
• 13
A6
A3
A3
16
12
F6.1
12
13
A6
A3
16
12
F6.1
12
Total Record Length 31
DILUENT GAS CONCENTRATIONS
CO, Concentration Data
S75.54(e)(1)(i) - (iii)
S75.54CdU4»
0, Concentration Data
S75.54WH4)
210
211
1
4
10
13
16
22
24
1
4
10
13
16
22
24
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Data
Hour
Average C02 concentration for the hour
YYMMDD
HH
%
00-23
0.0-100.0
Total Record Langth
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Date
Hour
Average O2 concentration for the hour
YYMMDD
HH
%
00-23
0.0-100.0
3
6
3
3
6
2
5
28
3
6
3
3
6
2
5
13
A6
A3
A3
16
12
F5.1
13
A6
A3
A3
16
12
F5.1
Total Record Langth 28
-------
Page 6
Electronic Data Reporting - Version t.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
''
RECORD TYPE
Moisture Data
575.54(e)(1)(i) - (iii)
575.54 >, -' - „ ;'
BATAS4MENT OEseJUPTHHJS
MOISTURE DATA
Record Typa Code
Unit ID/Stack 10
Component ID
Monitoring System ID
Date
Hour
Average moisture content of flue gases for the hour
Formula ID
HWTS.
YYMMDO
HH
%
SANSS
00-23
0.0-100.0
vm$m
3
6
3
3
6
2
5
3
«m«*T
mm
I3
A6
A3
A3
16
12
F5.1
A3
Total Record Length 31
Volumetric How Data
575.54(c)(2)
S75.54(a)(1)(ivl
220
VOLUMETRIC FLOW
1
4
10
13
16
22
24
29
39
49
54
56
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Data
Hour
Percent monitor data availability for volumetric flow
Average volumetric flow rate for the hour
Average volumetric flow rate for the hour adjusted foi
bias
Average moisture content of flue gases for the hour
Operating load range corresponding to gross load
Method of determination code
YYMMDD
HH
%
scfh
scfh
%
00-23
0.0-100.0
O.O- 100.0
01-20
01-12
3
6
3
3
6
2
5
10
10
5
2
2
13
. A6
A3
A3
16
12
F5.1
110
110
F5.1
12
12
Total Record Length 57
DAILY CALIBRATION AND INTERFERENCE CHECK DATA AND RESULTS
Daily Calibration Test Data and
Results
§75.56(a)(1)
230
1
4
10
13
16
22
24
37
50
63
68
69
71
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Date
Hour
Instrument span
Reference value
Measured value
Results (CEor |R-A|)
Alternative Performance Specification Flag'
Reserved
Calibration Gas Level (Z=zero, H = high)
YYMMDD
HH
%,ppm
0,1
Z,H
00-23
0.0-100.0
Total Record Length
Flow Daily Interference Check
Results
!75.56(a)(2)
231
1
4
10
13
16
22
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Date
Hour
YYMMDD
HH
00-23
3
6
3
3
6
2
13
13
13
5
1
2
1
13
A6
A3
A3
16
12
F13.3
F13.3
F13.3
F5.1
11
A1
71
3
6
3
3
6
2
13
A6
A3
A3
16
12
If the alternative performance specification for low emitters (|R-A|) is used, a 1 is recorded; a zero is entered otherwise.
-------
Electronic Data Reporting - Version 1.3
Page 7
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
waxawmfct
TW*
coot
START
24
25
SUtus (P-Pssj, F-Fail)
Reserved
P,F
*OWK*T
A1
Total Racord langth 26
-------
Page 8
Electronic Data Reporting - Version 1.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
MONITORING DATA
RECORD TYPE
Hourly Pollutant and Diluent
Concentration Data from RM
Backup Analyzers
55 75.24(c)(2) and 75.20(d)
TYP6 ;
CODS
260
START
cot
1
4
10
13
16
20
22
28
30
37
DATAEISMSNTO^^
REFERENCE METHOD BACKUP QA DATA
Record Type
Unit/Stack ID
Reference Method Component ID
Reference Method Monitoring System ID
Parameter monitored (SO,, NO,, CO2, 02)
Run number
Date
Hour
Unadjusted (raw) average pollutant or diluent
concentration for the hour
Adjustad average pollutant or diluent concentration
for the hour
% <•••••.'•• _, , ,
Wf»
YYMMDD
HH
»M,
00-23
um;
3
6
3
3
4
2
6
2
7
7
THE*
I3
A6
A3
A3
A4
12
16
12
F7.2
F7.2
Total Record Length 43
Quality Assurance Run Data
for Reference Method
Analyzers or Systems Used as
Backup CEMS
55 75.24(c)(2) and 75.20{d)
261
1
4
10
13
16
18
24
26
32
34
37
40
45
50
57
64
69
76
83
88
95
102
107
108
115
120
127
132
139
144
151
156
161
166
Record Type Code
Unit ID/Stack ID
toference Method Component ID
Reference Method Monitoring System ID
Run number
RM run start date
RM run start hour
RM run end data
Rm run end hour
Type of analyzer/system
Moisture basis of RM analysis
Instrument span (as defined in App A, Part 60)
Dilution factor
Reference zero gas concentration
Initial (pre-test) calibration response—zero gas
're-test calibration error— zero gas (% of span)
Reference mid-level gas concentration
nitiil (pre-test) calibration response— mid gas
Pre-test calibration error-mid gas (% of span)
Reference high-level gas concentration
Initial (pre-test) calibration response— high gas
Pre-test calibration error-high gas (% of span)
Upscale gas used during run (mid, high)
Pre-run system response— zero gas
Pre-run system bias (non-dilution) or calibration error
(dilution)-zero gas (% of span)
Post-run system response— zero gas
Post-run system bias (non-dilution) or calibration error
(dilution)— zero gas (% of span)
Pre-run system response— upscale gas
Pre-run system bias (non-dilution) or calibration error
(dilution)-upscale gas (% of span)
Post-run system response— upscale gas
Post-run system bias (non-dilution) or calibration error
(dilution)-upscale gas (% of span)
Zero drift (% of span)
Calibration drift (% of span)
Stack gas density adjustment factor
YYMMDD
HH
YYMMDD
HH
EXT, OIL
WET, DRY
%
%
%
M,H
%
%
%
%
%
00-23
00-23
3
6
3
3
2
6
2
6
2
3
3
5
5
7
7
5
7
7
5
7
7
5
1
7
5
7
5
7
5
7
5
5
5
5
- 13-
A6
A3
A3
12
16
12
16
12
A3
A3
15
15
F7.2
F7.2
F5.1
F7.2
F7.2
F5.1
F7.2
F7.2
F5.1
A1
F7.2
F5.1
F7.2
F5.1
F7.2
F5.1
F7.2
F5.1
F5.1
F5.1
F5.3
Total Record Length 1 70
-------
Electronic Data Reporting - Version 1.3
Page 9
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
,*'"> ', ; ' ; MONITORING DATAl ,
'V ' ' "'" " f '"
RECORD T*PC
Reference Method 2 - Use of
as Backup Flow Rate Monitor
fRun Summary)
H 75.24{cH2) and 75.20(dl
TYPS
cot*
262
START
cot-
1
4
10
13
16
22
24
26
31
35
40
45
50
SB
60
65
70
75
81
87
V1 ^ " 9A-£A. £it$?M£flf* pjpp»5'UP»jQ*F
Record Type
Unit ID/Stack ID
Reference Method Component ID
Reference Method Monitoring System ID
Run date
Run hour
Number of traverse points
(Square root of aP),^
T., stack temperature
P,,., barometric pressure, in. Hg
fv stack static pressure, in. H2O
% CO, in stack gas, dry basis
% Oj in stack gas, dry basis
% moisture in stack gas
M« stack gas molecular weight, dry basis
M., stack gas molecular weight, wet basis
CB, pitot tube coefficient
Data of latest pitot tuba calibration
A,, stack or duct cross-sectional area at test port
Total volumetric flowrate
> •• •. -.
YYMMDD
HH
in. H,O
°R
in. Hg
in. H2O
%
%
%H,0
Ibs/lbs-
mole
Ibs/lbs-
mola
YYMMDD
ft1
scfh
**
00-23
j
3
6
3
3
6
2
2
5
4
5
5
5
5
5
5
5
5
6
6
10
;^ST
I3
A6
A3
A3
16
12
12
F5.2
14
F5.2
F5.2
F5.2
F5.2
F5.2
F5.2
F5.2
F5.3
16
F6.1
no
Total Record Length 96
-------
Page 1O
Electronic Data Reporting - Version 7.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
•*•*••;.. ;• , «NITP«TA , . •;•
-
RECOUP TYM?
fti*
CBOE
Unit Operating Parameters
575.50(bT(1)-(6!
300
$T*RT
"«0t
DATA aayia«Toesc«»TMM
'
1
!
Rwwe
UNIT OPERATING DATA
1
4
10
16
18
22
28
34
36
Record Type Coda
Unit ID/ Stack ID
Data
Hour
Unit operating time
Gross unit load for the hour
Steam load1
Operating load range corresponding to gross load for the
hour
Total hourly heat input rate
YYMMDD
HH
MWe-hr
1000 Ib/hr
mmBtu/hr
00-23
0.00-1.00
01-20
***«*«
IKWMft?:
mm
3
6
6
2
4
6
6
2
7
I3
A6
16
12
F4.2
16
16
12
F7.1
Total Record Length 42
Quarterly Cumulative
Emissions Data
575.64(a)
Oil Fuel Flow for Appendix D,
E & Q
I75.55(c)
(Required January 1, 1996)
301
302
1
4
10
16
26
36
49
62
72
82
92
102
108
1
4
10
13
19
21
31
32
34
44
45
52
56
59
69
74
75
83
Record Type Coda
Unit ID/ Stack ID
Data of report generation
Quarterly SO, tops emitted
Cumulative annual SO, tons emitted
Quarterly average NO, emission rate
Cumulative annual average NO, emission rate
Quarterly CO, tons emitted
Cumulative annual CO, tons emitted
Quarterly total heat input
Cumulative annual total heat input
Reserved
Reserved
YYMMDD
ton
ton
Ib/mmBtu
Ib/mmBtu
ton
ton
mmBtu
mmBtu
6
6
1Q
10
13
13
10
10
10
10
6
6
13
A6
16
F10.1
F10.1
F13.3
F13.3
F10.1
F10.1
110
110
Total Record Length 1 1 3
Record Typo Code
Unit ID/Pipe ID
Monitoring System ID
Date
Hour
Mass flow rate of oil for the hour
Missing data/source of data code for mass oil flow rate*
Operating load range corresponding to gross load
Gross calorific value (GCV) of oil
Missing data flag for GCV of oil*
Heat input rate from oil for the hour
Fuel usage time
Type of oil (OIL - residual oil, DSL - diesel)
Volumetric flow rate of oil for the hour
Units of measure for oil flow rate
Missing data/source of data code for oil flow rate9
Density of oil
Units of measure for density of oil
YYMMDO
HH
Ib/hr
0-9
Btu/lb
0,1
mmBtu/hr
OIL.DSL
5
0-9
s
00-23
01-20
O.OQ-1.00
3
6
3
6
2
10
1
2
10
1
7 .
4
3
10
5
1
8
5
13
A6
A3
16
12
F10.1
11
12
F10.1
11
F7.1
F4.2
A3
F10.1
A5
11
F8.5
A5
3 Steam load may be reported in lieu of total integrated unit load if appropriate.
* If this record represents substitute data, a 1 is recorded; a zero is entered otherwise. Other codes for "source of data code" are reserved for future
designation.
Limited to a Table of Codes: SCFH (scf/hr); GALHR (gal/hr); BBLHR (barrels/hr), M3HR (M3/hr) for volumetric flow of oil
LBSCF (Ib/scf); LBGAL (Ib/gal); LBBBL (Ib/barrel), LBM3 (lb/m3) for density of oil
-------
Electronic Data Reporting - Version 1.3
Page 11
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
• • ' v£ ' ' '-,'-' UNIT DATA s '
RECQBDiTVPg
TWI
coot
START
fiOl
88
89
P*T« a»i!$NTQKe»pHQK '
Missing data flag for density of oil5
Rag to indicate multiple or single fuel types combusted
(M » multiple fuels combusted, S = this fuel only
combusted)
i
., f 'v .&
\ $m*"
0,1
M,S
/'
RAfKJE
UBilSTH
1
1
?08Wftt
(WNt
11
A1
Total Record Length 39
-------
Page \ 2L
Electronic Data Reporting - Version 1.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
"
KECOflDTYEE
Gas Fuel Flow for Appendix
D E & G
575.55(c)
(Required January 1, 1996)
TWI
303
-">•;/'•
cot
1
4
10
13
19
21
31
32
34
44
45
52
56
59
UNIT DATA
m«umttOT9Ht>
Record Type Code
Unit ID/Pipe ID
Monitoring System ID
Date
Hour
Flow rate of gas for the hour
Missing data flag for gas flow rate*
Operating load range corresponding to gross load
Gross calorific value (GCV) of gas
Missing data flag for GCV4
Heat input rate from gas for the hour
Fuel usage time
Type of gas (PNG - Pipeline Natural Gas, OTH - Other)
Flag to indicate multiple or single fuel types combusted
(M = multiple fuels combusted, S = this fuel only
combusted)
, ,,, - - '"'-; -,- >-
i^w
YYMMDD
HH
100 scfh
0,1
Btu/IOOscf
0,1
mmBtu/hr
PNG.OTH
M,S
sowe
00-23
01-20
0.00-1.00
uwm
3
6
3
6
2
10
1
2
10
1
7
4
3
1
FORMAT
tit*;
13
A6
A3
16
12
F10.1
11
12
F10.1
11
F7.1
F4.2
A3
A1
Total Record Length 59
SO2 MASS EMISSIONS
SO, Mass Emissions Data
575.50(c)(3)
310
1
4
10
16
18
25
32
Record Type Coda
Unit ID/Stack ID
Data
Hour
SO, mass emissions rate for the hour
SO, mass emissions rate for the hour adjusted for bias
Formula ID from monitoring plan for hourly SO, emissions
YYMMDD
HH
Ib/hr
Ib/hr
00-23
3
6
6
2
7
7
3
13
A6
16
12
F7.1
F7.1
A3
Total Record Length 34
SO, Mass Emissions
Alternative Estimation
Parameters for Oil
§75.51(c)(1) and (21
(Effective Through December
31, 1995)
311
1
4
10
16
18
28
33
36
46
53
58
Record Type Code
Unit ID/Pipe Header ID
Data
Hour
Average flow rate of oil for the hour
Sulfur content of oil sample
Coda for method of oil sampling from monitoring plan
(ADC, ADD, ADR)
Mess rate of oil combusted for the hour
Average SO, mass emissions for the hour
Highest sulfur content recorded from last 30 daily oil
samples
Missing data flag9
YYMMDD
HH
%
ADC.ADD,
ADR
Ib/hr
Ib/hr
%
0,1
00-23
0.0- 7.0
0.0- 7.0
Total Record Length
SO, Mass Emissions
Alternative Estimation
Parameters for Natural Gas
575.51(0(3) (Effective
Through December 31,
1995)
312
1
4
10
16
26
34
42
55
Record Type Code
Unit ID/Pipe Header ID
Data
Heat input from natural gas
Sulfur content of daily gas sample
Volume of gas combusted per day
SO, emission rate from NADS or NADB default for pipeline
natural gas
Missing data flag9
YYMMDD
mmStu
grains/scf
kscf
Ib/mmBtu
0,1
3
6
6
2
10
5
3
10
7
5
1
58
3
6
6
10
8
8
13
1
13
A6
16
12
F10.1
F5.1
A3
F10.1
F7.1
F5.1
11
13
A6
16
F10.1
F8.1
F8.1
F13.5
11
Total Record Length 55
If this record represents substitute data, a 1 is recorded; a zero is entered otherwise.
-------
Electronic Data Reporting - Version 1.3
Page 13
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
*8?r''V ••» '• WITOATA • • •"
RECOUP tVHT
SO] Mass Emissions
Alternative Estimation
Parameters for Oil {Hourly)
i 75.51(0(1) and (2)
(Revised Record Type 311)
Required January 1, 1996
coot.
313
cot
1
4
10
13
19
21
26
29
30
Record Type Code
Unit ID/Pipe Header ID
Monitoring System ID
Date
Hour
Sulfur content of oil sample
Code for method of oil sampling (ADC, ADD, ADR)
Missing data flag for sulfur content7
SO, mass emission rite from oil for the hour
YYMMDD
HH
%
ADC, ADD,
ADR
0,1
Ib/hr
wwt
00-23
.01-5.0
Total Record Length
SO2 Mass Emissions
Alternative Estimation
Parameters for Natural Gas
(Hourly) i 75.51(c)(3)
(Revised Racord Type 312)
Required January 1, 1996
314
1
4
10
13
19
21
29
30
37
Record Type Code
Unit ID/Pipe Header ID
Monitoring System ID
Date
Hour
Sulfur content of ges semple
Missing data flag for sulfur content7
SO, emission rate from NAOB or default SO, emission rate
of 6.0006
SO, mess emission rste from gas for the hour
YYMMDD
HH
grains/ 100 scf
0,1
Ib/mmBtu
Ib/hr
00-23
^
WWHH
3
6
3
6
2
5
3
1
7
36
3
6
3
6
2
8
1
7
8
-
13
A6
A3
16
12
F5.2
A3
11
F7.1
13
A6
A3
16
12
F8.1
13
F7.5
F8.5
Total Record Length 44
If this record represents substitute data, a 1 is recorded; a zero is entered otherwise.
-------
Page 14
Electronic Data Reporting - Version 1.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
o/o,; Y ' ' -«WTO*TA
RECQflDTYPE
NO, Emission Rate Data
S75.54(d)(2),(5) - (9)
twe
cooc
320
NO, Emission Rate
Alternative Estimation
Parameters for Oil
$75.55(4X1)
(Effective through
December 31, 1995)
321
*j
-------
Electronic Data Reporting - Version 1.3
Page 15
-------
Page 16
Electronic Data Reporting - Version 1.3
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
»>'*' .' -*- ' . ' '* y»rroATA,
- Raw**™* :;
•ease'
*3T
CO, Mass Emissions Data
I75.54(e)(1)(ii),(v),
(vii) & (viii)
330
1
4
10
16
18
28
31
' BATA ctcm»^r'^ig^pftiy IK1>M
CO2 MASS EMISSIONS
Record Type Code
Unit ID/Stack Pipe ID
Date .
Hour
C02 mass emissions rate for the hour
Formula ID from monitoring plan for hourly C02 mass
emissions
Method of Determination Code - 1 3 - App. G
Missing Data
- -
YYMMDD
HH
ton/hr
,
SAMGE
00-23
13
Total Record Length
CO, Mass Emissions
Estimation Parameters
575.54(0)12)
331
1
4
10
16
26
36
Record Type Code
Unit ID/Stack ID
Data
Daily combustion related CO, mass emission rate
adjusted for C02 retained in flyash
Daily sorbent-reiated CO2 mass emission rate
Total daily CO2 mass emission rate
YYMMDD
ton/day
ton/day
ton/day
'
3
6
6
2
10
3
2
32
3
6
6
10
10
10
FORMAT
13
A6
16
12
F10.1
A3
12
13
A6
16
F10.1
F-10.1
F10.1
Total Record Length 45
-------
Electronic Data Reporting - Version 1.3
Page 17
TABLE 2: QUARTERLY EMISSION DATA FILE RECORD STRUCTURES
&> COHTROt EQUIPMENT DATA *'
"\ .. - ' .'...
wEcoaatVPS
SO, Control Equipment
Operation Parameters
i7S.51(b)t1)
SO, Control Equipment
Scrubber Module Parameters
§75.S1(b)(1)
TH»i
CG3J6
400
START
<»t
S02
1
4
10
16
18
DATA8J£M^TO**e*tt*W«*
- -- , ",
«*«?«
CONTROL EQUIPMENT OPERATING PARAMETERS
Record Type Code
Unit ID/Stack 10
Data
Hour
Number of scrubber modules operating
YYMMDD
HH
' BAtJfGI
tmsm
00-23
ai
3
6
6
2
2
«MU*At
-------
Page 18
Electronic Data Reporting - Version 1.3
TABLE 2: QUARTERLY EMISSiON DATA FILE RECORD STRUCTURES
; " CONTROL EQUIPMENT DATA
R«fc0a» T¥f*
SO3 Phase I Technology Post-
Combustion Control
Parameters
Outlet Monitors
S75.55(a)(1)
HfMI
eooe
421
$TA8T
COfe,
1
4
10
13
19
21
34
47
50
vxtA&XMm o«ss»aNO«
Record Type Code
Unit iD/Stack 10
Monitoring System ID
Date
Hour
Outlet SO, emission rate for the hour
Reserved
Formula ID from monitoring plan identifying formula
deriving average hourly outlet S02 emission rates from
monitor data
Method of determination code
'
wm
YYMMDD
HH
Ib/mmBtu
8ASOK
00-23
01-04
Total Record Length
SO2 Phase I Technology Pre-
Combustio'n Control
.Parameters
S75.55(a)(2)(v)
422
1
4
10
16
18
28
33
43
53
58
Record Type Code
Unit ID/Stack ID
Date
Hour
Pre-treatment fuel weight
Pre-treatment fuel sulfur content
Pre-treatmant fuel gross calorific value
Post-treatment fuel weight
Post-treatment fuel sulfur content
Post-treatment fuel gross calorific value
YYMMDO
HH
tori
%
Btu/lb
ton
%
Btu/lb
00-23
0.0-100.0
0.0-100.0
tSNUTtt
3
6
3
6
2
13
3
2
51
3
6
6
2
10
5
io
10
5
.io
«J«MAt
%1F1»t
13
A6
A3
16
12
F13.3
A3
12
13
A6
16
12
F10.1
F5.1
F10.1
F10.1
F5.1
F10.1
Total Record Length 67
SO2 Phase 1 Technology
Combustion Emission
Controls
§75.55
-------
Electronic Data Reporting - Version 1.3
Page 19
TABLE 3: MONITORING PLAN FILE RECORD STRUCTURES
: liOMmm FUN a****™*,
WSCORDTYSK
Unit Definition Table
$75.53(0(2)
Effective through
December 31, 1995
TW*
COOK
500
cot
1
4
24
44
50
52
55
58
61
69
75
78
86
92
^AKWWWKWW* ,/:
Record Type Code
Plant Name
Unit Short Name
Unit ID (i.e.. NADB Boiler ID)
Unit classification
Boiler type
Primary fuel
SO, controls
NO, controls
Paniculate controls
SOj monitoring method
NO, monitoring method
C02 monitoring method
Opacity monitoring method
'f '" '
wm
' ••
SAftttK
Total Record Length
Stack/Pipe Headar Definition
Table
Effective Through
December 31, 1995
501
1
4
10
30
36
Record Type Code
Stack/Pipe Header ID
Stack/Pipe Headar Description or Nam*
Unit ID
Submission status - Add (A), Delete (D), Correct (C),
Unchanged (U)
A,C,D,U
Total Record Length
Unit Definition Tabla
i75.53tc)<2)
(Revised RT 500)
Required January 1, 1996
502
1
4
24
44
50
52
55
58
61
69
75
78
86
92
95
108
114
120
Record Type Code
Rant Nam*
Unit Short Nam*
Unit ID (i.e., NADB Boiler ID)
Unit classification
Boiler type
Primary fuel
SO; controls
NO, controls
Particulate controls
SO] monitoring method
NO, monitoring method
CO, monitoring method
Opacity monitoring method
Secondary fuels
Maximum hourly gross load in megawatts (used for load
rang* calculations)
Maximum hourly gross steam load (used for load rang*
calculations)
Unit definition change date
MWe-hr
1000lbs/hr
YYMMDD
Total Record Length
Stick/Pip* Header Definition
Table
(Revised RT 501)
Required January 1, 1996
503
1
4
10
30
36
37
43
49
Record Type Code
Stack/Pip* Headar ID
Stack/Pipe Header description or name
Unit ID (i.e., NADB Boiler ID)
Submission status - Add (A), Delete (D), Correct (C),
Unchanged (U)
Maximum hourly gross load in megawatts (used for load
range calculations)
Maximum hourly gross steam load (used for load range
calculations)
Activation date
A,C,D,U
MWe-hr
1000 Ibs/hr
YYMMDD
','"••„ -
«**»
3
20
20
6
2
3
3
3
a
8
3
8
6
3
94
3
6
20
6
1
36
3
20
20
6
2
3
3
3
8
6
3
8
6
3
13
6
6
6
125
3
6
20
6
1
6
6
6
'/'
T5P
I3
A20
A20
A6
A2
A3
A3
A3
AS
A6
A3
AS
A6
A3
13
A6
A20
A6
A1
13
A20
A20
A6
A2
A3
A3
A3
AS
A6
A3
AS
A6
A3
A13
16
16
16
13
A6
A 20
A6
A1
16
16
.16
-------
Page 2O
Electronic Data Reporting - Version 1.3
TABLE 3: MONITORING PLAN FILE RECORD STRUCTURES
,.
ueeoaotwe
r'
COOK
••
cot
55
R* ONffORIKS RAN I$?0f«yi&tf0» ?
OAtA«t«*»e^eese«8»wai _
Retirement data
mm*
YYMMDD
^
SAfeKJt
X
UBMm
6
iHJBWAT
16
Total Record Length 60
-------
Electronic Data Reporting - Version 1.3
Page 21
TABLE 3: MONITORING PLAN FILE RECORD STRUCTURES
.
Monitoring
Systems/Analytical
Components Table
$75,53tc)(4)
T
-------
Page 22
Electronic Data Reporting - Version 1.3
TABLE 3: MONITORING PLAN FILE RECORD STRUCTURES
*"
meomtYM
Fuel Flowmeter Data
Required January T, 1996
coor
540
~ ,- /
COL
1
4
10
13
17
20
30
35
38
49
60
(SONrTORIKSPMWWPOWtKW ^
o««iuiHwnmin<»
Record Type Code
Unit/Pipe Header ID
Monitoring System ID
Parameter monitored
Type of oil or gas (OIL - Residual Oil, DSL - Diesel, PNG -
Pipeline Natural Gas, OTH - Other)
Maximum fuel flow rate
Units of measure for maximum fuel flow rate
Source of maximum rate (URV = Upper Range Value, UMX
= Unit Max)
Initial calibration method
Ongoing calibration method
Submission status - Add (A), Delete (D), Correct (C) or
Unchanged (U)
wm
OILDSL,
PNG.OTH
13
URV.UMX
A,D,C,U
'r
HAWGS.
Total Record Length
Reasons for Missing Data
Periods
Required January 1, 1996
550
1
4
10
14
17
23
25
31
33
35
110
Record Type Code
Unit/Stack ID
ParameterJSO2, CO2, NOX, FLOW, OILM, OILV, GAS,
GCVG, GCVO, fcSG, %SO, DENS)
Monitoring System ID
Begin date
Begin hour
End date
End hour
Missing data reason code
Missing data description
Corrective action description
YYMMDD
HH
YYMMDD
HH
00-23
00-23
13
14
Total Record Length
Monitoring System
Recertification Events
Required January 1, 1996
555
1
4
10
13
19
21
23
73
123
126
129
132
135
138
141
144
147
150
156
Record Type Code
Unit/Stack ID
Monitoring System ID
Begin date of recertification event
Begin hour of recertification event
Recertification event code
Recertification event description
Recertification event response/action taken
System permanently inactivated/retired
7-day calibration test required
Linearity check required
Cycle time test required
RATA/bias test required
DAHS verification required
Daily calibration
Interference) Check
Leak Check
Completion date of required recertification tests
Completion hour of required recertification tests hour
YYMMDD
HH
RET
7CE
LIN
CTT
RAT
VER
DLC
INT
LCK
YYMMOD
HH
00-23
15
14
00-23
«*<«**
3
6
3
4
3
10
5
3
11
11
1
60
3
6
4
3
6
2
6
2
2
75
75
TS?
13
16
A3
A4
A3
F10.1
AS
A3
A11
A11
A1
13
•A6
-A4
A3
16
12
16
12
12
A75
A75
184
3
6
3
6
2
2
50
50
3
3
3
3
3
3
3
3
3
6
2
13
A6
A3
16
12
12
A50
A50
A3
A3
A3
A3
A3
A3
A3
A3
A3
,16
12
Total Record Length 157
12 For volumetric flow meters for oil use SCFH (scf/hr); GALHR (gal/hr); BBLHR (barre!s/hr); M3HH (M3/hr). For mass of oil flow meters use LBHR. For
gas flow meters use HSCF (for 100 scfh).
13 For missing data reason codes see instructions.
14 Optional field. Provide information if code does not adequately explain reason or event.
15 For recertification event codes see instructions.
-------
Electronic Data Reporting - Version 1.3
Pag6 23
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
.: ;; CERTIFICATION TEST DATA AND RESULTS "
MCOMFtV*. '
cast
*Sf
7-Oay Calibration Error Test
Data and Results
S75.56(a)(1)
600
1
4
10
13
16
22
24
37
50
63
68
69
CALIBRATION/ERROR TESTS
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Data
Hour
Instrument span
Reference value
Measured value
Results (CE or |R-A|)
Alternative performance specification flag"
Calibration gas level (Z-zero, H-high)
YYMMDD
HH
%, ppm
0,1
Z,H
00-23
0.0-
100.0
3
6
3
3
6
2
13
13
13
5
1
1
'
jfORMAT
13
A6
A3
A3
16
12
F13.3
F13.3
F13.3
F5.1
11
A1
Total Record Length 69
LINEARITY CHECKS
Quarterly Linearity Test Data
S75.58{a)(3)
601
1
4
10
13
16
22
26
39
52
65
Record Type Coda
Unit ID/Stack ID
Component ID
Monitoring System ID
Data
Time
Instrument span
Reference value
Measured value
Calibration gas level (L = low, M-mid, H-high)
YYMMDO
HHMM
L,M,H
0000-
2359
Total Record Length
Quarterly Linearity Check
Results
!75.56(a)(3)
602
1
4
10
13
16
22
36
48
61
66
67
71
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Data
Instrument Span
Mean of reference values
Mean of measured values
Results (LE or |R-A|)
Alternative performance specification flag10
Reserved
Calibration gas level (L = low, M = mid, H-high)
YYMMDD
%, ppm
0,1
L,M,H
0.0-
100.0
6
3
3
6
4
13
13
13
1 ,
65
3
6
3
3
6
13
13
13
5
1
1
A6
A3
A3
16
14
F13.3
F13.3
F13.3
A1
13
A6
A3
A3
16
F13.3
F13.3
F13.3
F5.1
11
A1
Total Record Length 71
LEAK CHECKS
Flow Quarterly Leak Check
Results
J75.56(»)(4)(i)
603
1
4
10
13
16
22
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Data
Hour
YYMMDD
HH
00-23
3
6
3
3
6
2
13
A6
A3
A3
16
12
'• If the alternative performance specification for low emitters (|R-A|) is used, a 1 is recorded; a zero is entered otherwise.
-------
Page 24
Electronic Data Reporting - Version 1.3
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
, -.-
RECQflCMrYPE
"f
1f*f
fcft&t
CERTIFJCAT1QN TEST DATA AND RESULTS
*?ABt
«3ft.:
24
25
9ATA£tl3«lfrB£8<2lS«nq»
Status (P-Paas, F-Fail)
Reserved
VN&9""
P,F
'RAW55'
juptsm
i
4
fOWKAT
-------
Electronic Data Reporting - Version 1.3
Page 25
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
"jjgjgxr ^ \£%Kfj&GjaiQM TEST|3hftTAANB"ftE6iilLTS
, •'' ' 'Vf|i§l'j' ' \> '' v* ,,'£' s ' ' , " /••"'''
.
wcouDTm
RATA and Bias Test Data
S75,20(c)(1l(iii) and (Iv)
S75,20(c)(2)(li) and (iii)
575.20(c)(5)(iii)
TWC.
coot
610
STAST
cot
1
4
10
13
19
23
29
33
34
47
60
62
63
64
nATfti?tEi»i*rB£aej»tmoa ' ' ""'
RATA/BIAS TESTS
Record Type Code
Unit ID/Stack ID
Monitoring System ID
Run start date
Run start time
Run end date
Run end time
Units of measure (1 -ppm, 2-lb/mmBtu, 3-scfh, 4-%)
Value from CEM system being tested
Value from reference method, adjusted as necessary for
moisture and/or calibration bias
Run number
RATA run status flag
0 - RATA used, run not used
1 - Run data used in calculating relative accuracy and biaa
9 - RATA not used, run not used
Operating level - low, mid, high or normal (L,M,H,N)
Gross unit load
' "" '"
ttlBIfe
YYMMDD
HHMM
YYMMDD
HHMM
1,2,3,4
0,1,9
L,M,H,N
MWe
/ ._
HAMtie
0000-
2359
0000-
2359
Total Record Length
RATA and Bias Test Results
S75,20(c)(1)(iii) and (iv)
J75,20(cj(2)(ii) and (iii)
J75.20(c)(5Hilf)
611
1
4
10
13
19
23
34
35
48
61
74
87
100
105
111
116
117
123
Record Type Code
Unit ID/Stack ID
Monitoring System ID
Data
Time
Reference method used
Units of measure (1 =ppm, 2-lb/mmBtu, 3>scfh, 4<-%)
Arithmetic mean of CEMS values
Arithmetic mean of reference method values
Arithmetic mean of the difference data
Standard deviation of difference data
Confidence coefficient
Relative accuracy
Tabulated t- value (bias test)
Bias adjustment factor
Operating level - low, mid, high or normal (L,M,H,N)
Gross unit load
Reserved
YYMMDO
HHMM
1,2,3,4
L,M,H,N
MWe
0000-
2359
""A
kEwmi
'
3
6
3
6
4
6
4
1
13
13
2
1
1
6
69
3
6
3
6
4
11
1
13
13
13
13
13
5
6
5
1
6
4
fCWKAT
13
A6
A3
16
14
16
14
11
F13.3
F13.3
12
11
A1
16
13
A6
A3
16
14
A11
11
F13.3
F13.3
F13.3
F13.3
F13.3
F5.2
F6.3
F5.3
A1
16
Total Record Length 1 26
-------
Page 26
Electronic Data Reporting - Version 1.3
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
f f v" •>•"•.". *• ""
MomtTWV
Reference Method
Supporting Data for Gas
RATAs i 75.52(a)(5Miii)(F)
S 75.52(a)(7)
5 75.64(a)(1)
(Required January 1 , 1 998)
cane
612
cot
1
4
10
13
16
18
24
28
34
38
41
44
49
54
61
68
73
80
87
92
99
106
111
112
119
124
131
138
143
148
155
160
165
170
177
182
187
194
200
DATAaEMWDSS,*™* |
Record Type Code
Unit ID/Stack ID
Component ID
Monitoring System ID
Run number
RM run start data
RM run start time
RM run end date
\M run end time
Type of RM analyzer/system
Moisture basis of RM analysis
RM instrument span (as defined in App A, Part 60)
RM dilution factor
Reference zero gas concentration
nitial (pre-test) calibration response— zero gas
Pre-test calibration error-zero gas (% of span)
Reference mid-levet gas concentration
nitial (pre-test) calibration response-mid gas
Pre-test calibration error-mid gas (% of span)
Reference high-level gas concentration
Initial (pre-test) calibration response— high gas
Pre-test calibration error-high gas (% of span)
Upscale gas used during run (mid, high)
Pre-run system response— zero gas
Pre-run system bias, (non-dilution) or calibration error
(dilution)-zero gas (% of span)
Post-run system response— zero gas
Post-run system bias (non-dilution) or calibration error
(dilution)-zero gas (% of span)
Pre-run system response— upscale gas
Pre-run system bias (non-dilution) or calibration error
(dilutlon)-upscale gas (% of span)
Post-run system response-upscale gas
Post-run system bias (non-dilution) or calibration error
(dilutionl-upscals gas (% of span)
Zero drift (% of span)
Calibration drift (% of span)
Unadjusted (raw) average concentration for run
% Moisture in stack gas
Stack gas density adjustment factor
Adjusted average concentration for run (corrected for
calibration bias/error and, if applicable, moisture and stack.
gas density)
F-factor used for conversion to Ib/mmBtu
Formula coda for formula used to convert to Ib/mmBtu
S--
aw*
YYMMDD
HHMM
YYMMDD
HHMM
EXT, OIL
WET, DRY
%
%
%
M,H
%
%
%
%
%
%
% H2O
WWS.
0000-
2359
0000-
2359
warn
3
6
3
3
2
6
4
6
4
3
3
5
5
7
7
5
7
7
5
7
7
5
1
7
5
7
5
7
5
7
5
5
5
7
5
5
7
6
5
JSB*
I3
A6
A3
A3
12
16
14
16
14
A3
A3
IS
IS
F7.2
F7.2
F5.1
F7.2
F7.2
F5.1
F7.2
F7.2
F5.1
A1
F7.2
F5.1
F7.2
F5.1
F7.2
F5.1 .
F7.2
F5.1
F5.1
F5.1
F7.1
F6.2
F5.1
F7.1
16
AS
Total Record Length 204
-------
Electronic Data Reporting - Version 1.3
Page 27
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
CERTIFICATION TEST BATA AMD RESULTS , i
WOOBDTYPS
Reference Method 2
Supporting Data for Row
RATA Tests
5 75,52(a)l5)((ii](F)
{ 75,52(a!(7)
S 75.64(a)l1)
(Required January 1, 1998)
TWPt
CBtHt
613
*TART
1
4
10
13
19
23
29
33
35
36
38
43
47
52
57
62
67
72
77
82
87
93
•"*
Record Type
Unit ID/Stack ID
Monitoring System ID
Run start data
Run start time
Run end date
Run end time
Run number
Operating level
Number of traverse points
(Square root of iP)^.
T., stack temperature
PS., barometric pressure, in. Hg
Py stack static pressure, in. H2O
% CO] in stack gas, dry basis
% O, in stack gas, dry basis
% moisture in stack gas
Ma, stack gas molecular weight, dry basis
M,, stack gas molecular weight, wet basis
C,, pitot tuba coefficient
Date of latest pitot tuba calibration
A,, stack or duct cross-sectional area at test port
vw*
YYMMDD
HHMM
YYMMDD
HHMM
L,M,H,N
in. H2O
°R
in. Hg
in. HjO
%
%
%H,0
Ibs/lbs-mole
Ibs/lbs-mole
YYMMDD
ft1
HMM*
oooo-
2359
0000-
2359
nwnnj
3
6
3
6
4
6
4
2
1
2
5
4
5
5
5
5
5
5
5
5
6
6
*?tttr
13
A6
A3
16
14
16
14
12
A1
12
F5.2
14
F5.2
F5.2
F5.2
F5.2
F5.2
F5.2
F5.2
F5.3
16
F6.1
Total Record Length 98
CYCLE/RESPONSE TIME
Cycle TimejResponse Time
Test Data and Results
!75.2CHc)(1Itv)
i7S.20
-------
Page 23
Electronic Data Reporting - Version 1.3
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
J f
.. «eim&T(m ,- ,
Cycle Time/Response Time
Test Data and Results
575.20(c)(1)(v)
575.20(o){2)(iv)
S75.20(c)(5)(iv)
(Required January 1 , 1 996)
HP6
coot
621
--
$tAi*f
cot
1
4
10
13
16
22
26
30
32
45
58
71
72
TEST INFORM/iTfQPi * '" „• ,,
OATAStw^rqeatspriw
Record Type Code
Unit ID/Stack 10
Component ID
Monitoring System ID
Date
Start time
End time
Component cycle time
Stable starting monitor value
Stable ending monitor value
Calibration gas value
Calibration gas level (Z—zero, H«high)
Total or system cycle time17
'WWJS
YYMMDD
HHMM
HHMM
Min
Z,H
Min
mum
0000-
2359
0000-
2359
LEW3TH
3
6
3
3
6
4
4
2
13
13
13
1
2
fORMAT
trm
13
A6
A3
A3
16
14
14
12
F13.3
F13.3
F13.3
A1
12
Total Record Length 73
FUEL FLOW CALIBRATION
Fuel Flowmeter Calibration
Data S75.5S(b)(1)
Fuel Flowmeter Calibration
Results 575.56
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Electronic Data Reporting - Version 1.3
Page 29
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
^ ALTERNATIVE MONITORING PETtTiON DAT). %* ' '"'"
MOO*™*
Alternative Monitoring
System Approval Petition
Data
575.41 (a)
TWB
630
START
cot.
1
4
10
13
16
22
28
30
43
56
69
71
72
, B^iumMMMMmcM; '" "; |
Record Type Code
Unit ID/ Stack ID
Component ID
Monitoring System ID
AMS ID
Date
Hour
Hourly test data for alternative monitoring system
Hourly lognormalized test data for alternative monitoring
system
Hourly test data for reference CEMS
Fuel type code
Operating Level - Low, Normal, High (L,N,H)
Gross unit load
VWTS
YYMMDD
HH
L,N,H
MWge
8ASGI
00-23
Total Record Length
Alternative Monitoring
System Approval Petition
Results and Statistics
175.41(1) - (c)
631
1
4
10
13
16
17
30
43
56
69
82
95
108
121
134
147
160
161
174
187
200
201
214
227
240
253
266
279
292
305
318
331
Record Type Code
Unit ID/ Stack ID
Component ID
Monitoring System ID
Unit of Measure d -ppm, 2 = lb/mmBtu, 3-scfh, 4-%)
Arithmetic mean of AMS values
Arithmetic mean of CEM values
Arithmetic mean of differences of paired AMS and CEM
values
Variance of differences
Variance of measured values of AMS
Variance of measured values for CEM
F-statistic
Critical value of F at 95% confidence level for sample size
Coefficient of correlation (Pearson's r) of CEM and AMS
data
Shapiro-Wilk test statistic (W) for AMS data
Shapiro-Wilk test statistic (W) for CEMS data
Lognormally adjusted data used in final analysis (1 =» yes, 0
- no)
Autocorrelation coefficient (/>) for AMS data
Autocorrelation coefficient (p) for CEM data
Autocorrelation coefficient (p) for differences of paired AMS
and CEM data
Adjustment for autocorrelation used in final analysis d -
yes, 0 » no)
Covarianca of alternative monitoring data and associated
lagd) values
Covarianca of continuous emission monitoring data and
associated lagd) values
Covarianca of differences of paired AMS and CEM data
Standard deviation of AMS data
Standard deviation of CEM data
Standard deviation of differences of paired AMS and CEM
data
Standard deviation of lagd) AMS data
Standard deviation of lagd) CEM data
Standard deviation of lagd) differences of paired AMS and
CEM data
Variance inflation factor for AMS data
Variance inflation factor for CEM data
1,2,3,4
0,1
0,1
Ummk
3
6
3
3
6
6
2
13
13
13
2
1
6
77
3
6
3
3
1
13
13
13
13
13
13
13
13
13
13
13
1
13
13
13
1
13
13
13
13
13
13
13
13
13
13
13
fOMWAT
13
A6
A3
A3
A6
16
12
F13.3
F13.3
F13.3
12
A1
16
13
A6
A3
A3
A1
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
11
F13.3
F13.3
F13.3
11
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
F13.3
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Page 3O
Electronic Data Reporting - Version 1.3
344 (Variance inflation factor for difference of paired AMS and
|CEM data ' '
13 F13.3
Total Racord Length 356
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Electronic Data Reporting - Version 1.3
Page 31
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
••"••• "', - 'V* &,, )•••• ' '" '* v , .
^ < < '-> APPENDIX E TEST RECORDS
•£**"'<.'. v .* . 'w
MCOIIOTVM;
NO, Heat Input Correlation
Test Data
Appandix E to Part 75
TW6
COOE
650
cot
1
4
10
13
19
23
29
33
36
44
46
48
49
56
59
* i, , w**i^*&*&m ' , \
Record Type Code
Unit ID
Monitoring System ID for Appendix E System
Reference method run start data
Reference method run start time
Reference method run end date
Reference method run end time
Reference method response time
Value from reference method during run
Run number
Operating level - 1 - lowest
Type of fuel combusted (O = residual oil, D<*diesel fuel.
G- gaseous fuel, M» mixture)
Total heat input or load during the run
Elapsed time
Hourly heat input for run
f '
warn
YYMMDD
HHMM
YYMMOD
HHMM
sec
1-99
0,D,G,M
mmBtu
hrs
mmBtu/hr
HUNK
0000-
2359
0000-
2359
0-800
0.1-8.0
Total Record Length
NO^'Hoit Input Correlation
Results
Appendix E to Part 75
651
1
4
10
13
19
23
31
41
48
SO
Record Type Code
Unit ID
Monitoring System ID for Appendix E System
Completion data of last test
Completion time of last test
Arithmetic mean of reference method values at this level
F Factor converting NO, concentrations to emission rates
Average heat input rate or load at this level
Operating level - 1 = lowest
Type of fuel combusted (O = residual oil, D=»diesel fuel,
G» gaseous fuel, M~ mixture)
YYMMDD
HHMM
Ib/mmBtu
mmBtu/hr
1-99
O,D,G,M
0000-
2359
Total Record Length
Oil Fuo) Flow During Test
Appendix E to Part 75
652
1
4
10
13
19
23
29
33
35
45
55
62
72
77
85
Record Type Code
Unit ID
Monitoring System ID for Oil Fuel Flow System
Run start date
Run start time
Run end date
Run and time
Run number
Mass flow of oil during run
Gross calorific value (GCV) of oil
Heat input during run
Volumetric flow of oil during run
Units of meesure for oil flow
Density of oil
Units of measure for density of oil
YYMMDD
HHMM
YYMMOD
HHMM
Ib
Btu/lb
mmBtu
'•
it
0000-
2359
L5K5K*
3
6
3
6
4
6
4
3
8
2
2
1
7
3
7
65
3
6
3
6
4
8
10
7
2
1
50
3
6
3
6
4
6
4
2
10
10
7
10
5
8
5
'
*tsr
13
A6
A3
16
14
16
14
13
F8.3
12
12
A1
F7.1
F3.1
F7.1
13
A6
A3
16
14
F8.3
F10.1
F7.1
12
A1
13
A6
A3
16
14
16
14
12
F10.1
F10.1
F7.1
F10.1
A5
F8.6
A5
Total Record Length 89
" Limited to a Table of Codes:
SCFH (scf/hr); GALHR (gal/hr); BBLHR (barrels/hr), M3HR (rtWhr) for volumetric flow of oil
LBSCF (Ib/scf); LBGAL (Ib/gal); UBBBL (Ib/barrel), LBM3 (Ib/m3) for density of oil
-------
Page 32
Electronic Data Reporting - Version 1.3
TABLE 4: CERTIFICATION - QA/QC TEST FILE RECORD STRUCTURES
< ' * ?" *rV, ' , * A??El«DIX£T€&Tf^aitB$
mWferor
Gas Fuel Flow During Tast
Appendix E to Part 75
coot
653
cot
1
4
10
13
19
23
29
33
43
53
:
9Am£tEMt»rt*e«M»TW«
Record Type Code
Unit ID
Monitoring System ID for gas fuel flow system
Run start data
Run start time
Run end date
Run end time
Row of gas for the run
Gross calorific value (GCV) of gas
Heat input from gas during the run
•. s
wra
YYMMDD
HHMM
YYMMDO
HHMM
100 scf
Btu/100 scf
mmBtu
',„•.' •. "„ * -
IMWH;
0000-
2359
0000-
2359
m?#\
3
6
3
6
4
6
4
10
10
7
FORMAT
13
A6
A3
16
14
16
14
F10.1
F10.1
F7.1
Total Record Length 59
-------
-------
APPENDIX F-l
INFORMATION ON OTHER U.S. DATA MANAGEMENT SYSTEMS
-------
-------
Description of Several Data Management Systems in the United States
Biennial Reporting System
Under the U.S. hazardous waste program, large quantity generators of hazardous waste must
submit a biennial report to EPA. The purpose of the report is to compile data on the type
and quantity of wastes generated; transporters; treatment, storage, and disposal facilities; and
methods of treatment, storage, and disposal. Since the hazardous waste program is delegated
by the Federal government to the States, regulated entities submit their biennial reports to the
States (or EPA Regional Offices if a particular State does not have delegation). The State or
Regional Office then uploads the information from the reports into the Biennial-Reporting
System (BRS). The BRS is a national database that 1) provides an overview of the progress
of the hazardous waste program by tracking generation, management, and minimization, 2)
assesses the impact of regulatory decisions, and 3) provides data to develop waste capacity
analyses. The system is updated every 2 years (biennially), as reports are submitted every 2
years. The States and EPA share the responsibility for data quality and QA/QC of the
system. Automated data validation routines and manual assessment analyses are completed
on the data prior to public release.
Aerometric Information Retrieval System
In the United States air program, the Aerometric Information Retrieval System (AIRS) is a
national database that contains information on airborne pollutants. As discussed in Section 2,
under the U.S. air program, regulated entities are required to monitor for seven criteria
pollutants—PM 10, CO, SO2, NO2, lead, reactive VOCs, and ozone. The regulated entities
are then required to report the monitoring data to the States, who have responsibility for
implementing the air program. The States then submit the ambient air quality data
(quarterly) and point-source emission data (annually) to EPA. It is this data that are
contained in AIRS. AIRS is comprised of four subsystems:
• Air Quality Subsystem: This system contains measurements of ambient
concentrations of air pollutants and associated meteorological data. It is used
to assess the overall status of U.S. air quality.
» AIRS Facility Subsystem: This subsystem contains emissions and compliance
data on air pollution point sources. Its purpose is to track emissions and
compliance data from industrial plants. The data contained in AFS is used by
States when preparing State Implementation Plans.
o AIRS Area/Mobile Source Subsystem: This subsystem contains estimates of
area-wide emissions from mobile sources, forest fires, fugitives transport, and
other area-wide emission sources. It provides methods for computing
emissions and serves as an inventory of emissions from area and mobile
sources.
-------
• Geo-commom Subsystem: This system contains reference information, such as
codes and code descriptions to identify places, pollutants, processes,
geopolitical entities, and numerical values. This reference information is used
with all the AIRS subsystems.
The system is updated daily and has built-in edit and logic checks to help ensure data quality.
Resource Conservation and Recovery Information System
Li the United States, the hazardous waste program requires an owner or operator of a
hazardous waste treatment, storage, or disposal facility to obtain a permit to operate. The
permit application requires information on design features, operation, and maintenance of the
facility. Also under the hazardous waste program, any facility generating, transporting, or
owning or operating a treatment, storage, or disposal facility must notify EPA of the
regulated activity. The information that is submitted in these permit applications and
notifications is tracked in the Resource Conservation and Recovery Information System
(RCRIS). RCRIS is a national system that tracks events and activities related to facilities
that generate, transport, and treat, store, or dispose hazardous waste. For example, the
system tracks facility identification, permit application status, compliance monitoring, and
sensitive enforcement information, such as compliance data obtained during inspections. The
regulated is required to submit the data to the State (if it has delegated authority) or to the
EPA Region. The information is then uploaded into the national system by the State or
Region. RCRIS has several built-in QA/QC checks, including screen edits and data
assessment reports, and is updated at least monthly.
Permit Compliance System
Under the United States water program, facilities discharging wastewater directly to the
environment are required to apply for and receive permits for such discharges. The Permit
Compliance System (PCS) is a national database that contains relevant information on those
permitted facilities. The purpose of the system is to track permit, compliance, and
enforcement status of the facilities. PCS contains 13 types of data: permit facility, permit
event, compliance schedule, compliance schedule violation, outfall schedule, permit limit,
discharge monitoring report, single event violation, enforcement action, inspections,
pretreatment compliance inspection/audit, pretreatment performance summary, and
evidentiary hearing. Each permit record contains information that:
• Identifies and describes the facility
• Specifies the pollutant discharge limits
• Records the actual amounts of pollutants measured in the wastewater
discharges
-------
« Tracks the compliance schedule and violations.
The source of data is primarily permit applications and the actual permits. Discharge
monitoring reports also provide information for the system. Since most States have delegated
authority under the water program, they are responsible for receiving the data from the
regulated community and then uploading it into PCS. There are two levels of QA/QC on the
system. The first level verifies the completeness and validity of data (e.g., required fields
are checked for values, numeric fields are checked to ensure the value entered was numeric,
and code fields are checked against valid PCS values). The second level verifies the
transactions relationship to existing data for that facility.
-------
-------
APPENDIX G-l
STANDARD METHODS FOR AIR MONITORING - THE NETHERLANDS
-------
-------
Appendix 5
APPENDIX 5. Methods of measurement
substances
(class or category)
methods for
separate measurements continuous measurement
Sampling
Waste gas reference
values
O,
CO
C02
air flow
temperature
humidity
ISO/DIS 10396
CAN/CSA-Z223.2-M86" CAN/CSA-Z223.2-M86'
VDI 2459 Bl. (l-)6, NDIRa
see NPR 2788 /
NPR 2786 (draft)
general practicec
d, e
ISO/DIS 10780
general practicec
EPA method 4 d
S Particulates
sA, gA Inorganic
substances
asbestos
heavy metals
vapour and gases
NOX (as N02)
SO2 (SOy as SO2)
(SO3/H,SO4)
NH3
or, HCI
F,HF
NPR 2788
ISO/DIS 9096 b
ISO/DIS 10397
NPR 2817 (draft) 8
ISO/CD 11564,
NEN 2044, NEN 2046
ISO/DP 7934
(EPA method 8)
p.m.
VDI 3480 B1.1'
NVN 2819 (draft)
VDI 2470 Bl. 1' •
ISO/DIS 10155'
NEN 2039a
ISO/CD 10849.2
ISO/DIS 7935 h
general practice'
B-10
Staff office NeR '92
-------
Appendix 5
substances
(class or category)
Methods for
individual measurement continuous measurement
sO, gO Organic
substances
CvHy-total
PAHs
PCBs
PCDDs/PCDFs
Odour
(VDI 3481 Bl. 2)
NVN 2816
sampling: dusth'lter
analysis:
instructions by
RIVM/TNO
NVN 2820 (draft)
VDI 3481 Bl. (l,)3k-a
FID-monitor
notes to the table:
b
f
other methods can be applied if data obtained by these methods does not
differ significantly from data obtained by the standardized norms and if the
repeatability is at least equal to these norms
VDE/VDI 3511 and VDE/VDI3512 Bl. 2 give general recommendations for
temperature measurement, i.e. in respect to the appearance and assembling of
equipment
if wet scrubbers are applied in the waste gas purification unit, the humidity of the
waste gases after purification is to be assumed saturated at the waste gas
temperature. Continuous measurements should involve measurement and
registration of the waste gas temperature
if no wet waste gas purification system is applied, corrections towards "dry [m3]"
have to be made by means of a ratio, determined four times a year using
measurement data from a series of three independent measurements
ISO/DIS 9096 equals NPR 2788
for the time being, measurement data obtained by these monitors may be
considered as an indication of emission concentrations; vindication of permit
regulations can only take place by means of individual measurements
this NPR applies to all heavy metals discussed within the Incineration
Guideline 1989 (RV'89)
Staff office NeR '92
B-ll
-------
Appendix 5
only SO2 concentrations are monitored contiuously; continuous measured
SO2 concentrations are to be adjusted for total sulfur oxides concentrations
(SOy) using a correction factor;
this factor is to be determined four times a year using measurement data
from a series of three independent measurements according to ISO 7934
in respect to the analysis ion chromatography according to NEN 6588 can
also be applied
if monitors are applied for measurent of just the HCl-concentration
continuously, the obtained concentration is to adjusted by a factor for other
gaseous inorganic chlorides (determined as HC1);
this factor is to be determined four times a year using independent data
from individual measurements of gaseous inorganic chloride and HC1
following the German regulation (Richtlinien fur die Eignungspriifung, den
Einbau und die Wartung kontinuierlich arbeitender Emissionsmefigerate, nr.
3, RDschr.d.BMI vom 21.7.1980 (GMBI.S.343)) only those FID's are to be
applied which have been proven to have a relative standard deviation of the
response factors for butane, heptane, cyclohexane, isopropanole, toluene,
acetone, butylacetate and ethylacetate of less than 15%;
the standard deviation is to be related to the averaged response factors;
FID's have to comply with the other quality standards of yhe VDI 3481 Bl. 3
also, except that response factors of the compound to be quantified should
be between a value of 0,85 to 1,15, if the nature of those compounds is not
known
B-12
Staff office NeR '92
-------
-------
APPENDIX H-l
REPORTING FORMS UNDER CANADA'S VINYL CHLORIDE
AND LEAD SMELTER REGULATIONS
-------
-------
13/3/91
Canada Gazette Pan 11. Vol. 125. ,Vo. 6
Gazette du Canada Partie II, Vol. 125. N°
-------
28/2/90 Canada Gazette Part II. Vol. 124, No. 5
Gazette du Canada Partie II. Vol. 124. N" 5 SOR/DORS/90-130
SCHEDULE I
(Section 5)
RELEASE MEASUREMENT REPORT
Name of Owner or Operator _
Address of Plant _ —
Telephone Number.
Rated Capacity
Source Tested
Measurement Method .
Date of Measurement _
Results: (Detailed data and calculations to be appended)
Measurement Number 1
Average gas flow over the dura-
tion of measurement (norm.
m'/min) —
Average mercury concentration
over the duration of measurement
(uf/norm. m1) —
Calculated mercury release rate
(g/day/I.OOOkgofrated
capacity) —
5 6
Average of Measurements.
(Signature)
(Title)
(Date)
ANNEXE I
(paragraphe 5(1))
RAPPORT SUR LA MESURE DES REJETS
Nom du proprietaire ou de 1'exploitant
Adresse de la fabrique .
Numero de telephone (fabrique).
Production nominate
Source controlee
Methode de mesure.
Date de la mesure
Resultats: (Joindre les donnees et calculs detailles)
Mesure n9 12345
Debit moyen des gaz evacues
durant la mesure (mj norm./min)— — — — —
Concentration moyenne du mer-
cure durant la mesure
(ug/m3 norm.)
Evaluation de rejet de mercure
(g/jour par 1 000 kg de la produc-
tion nominate)
Moyenne des mesures.
(Signature of attending
Inspector) (if applicable)
(Date)
(Signature)
(Titre)
(Date)
(Signature de I'inspecteur
present, s'il y a lieu)
(Date)
794
[5]
B-4
-------
Canada Gazette Pan II, Vol. 126. No. 23 Gazette du Canada Panic II. Vol. 126, N" 25 SOR/DORS/92-63I
SCHEDULE II
(Paragraplis 5(1 )(a) and 6(l)(b) and
subsections 6(3) and (6))
QUARTERLY REPORT MONITORING RESULTS
OF RELEASES OF VINYL CHLORIDE
FROM POLYMERIZATION REACTORS
THAT ARE OPENED
ANNEXE II
(alineas 5(1 )a) el 6(1 )b) et paragraphed 6(3) el 16))
RAPPORT TRIMESTRIEL
R£SULTATS DE LA MESURE ons REJMTS
DE CHLORURE DE VINYLE PROVI-NANT DES
RfiACTEURS DE POLYMERISATION OUVERTS
Company.
City
Entreprise.
Ville
Month
% Openings
analysed
% Openings where releases do not
exceed 0.002 leg vinyl chloride/
100 kg polyvinyl chloride produced
Total vinyl
chloride
released/
month (kg)
Mois
% d'ouvertures
analysed
% d'ouvertures rejetant mpins de
0,002 kg de chlorure dc vmyle /
100 kg de chlorure de
polyvinyle produit
Total ile chlonire
de vmyle rejete par
mois ilcg)
Releases exceeding 0.002 kg vinyl chloride/100 kg polyvinyl
chloride produced between openings
Rejets depassant 0,002 kg de chlorure de vinyle par 100 kg
de chlorure de polyvinyle produit entre les ouvertures
Due
Reactor No.
kg Vinyl chloride/
100 kg polyvinyl
chloride produced
^
Vinyl chloride
released (kg)
^
Cause and
corrective measure*
Due
Reacteur n'
kg de chlonire de
vinyle/100 kg de
chlonire de polyvinyle
produit
chlorure de vinyle
rejet< (kg)
cause et mesures
correctives
4520
[9]
-------
-------
APPENDIX H-2
ENHANCED MONITORING REPORT FORM - U.S. AIR PROGRAM
-------
-------
Appendix F: Sample Summary Report Form
ENHANCED MONITORING REPORT
Part A - Source Information
1. COMPANY IDENTIFICATION
Company Name:
Company Mailing Address:
2. FACILITY IDENTIFICATION (if different from the Company!
Facility Name: ——_______
Facility Street Location: ___
AIRS AFS ID No.:
Permit ID No.:
3. RESPONSIBLE OFFICIAL IDENTIFICATION
Name/Title: .
Telephone/Facsimile Number(s):
4. FACILITY SITE MANAGER/CONTACT IDENTIFICATION (if different from the Responsible Official)
Name/Title: _____
Telephone/Facsimile Number(s): ^
5. REPORT INFORMATION
Reporting Period (mm/dd/yyl:
Number of Units Included:
/Vote Complete a separate Part B for each pollutant at each unit included in the report.
6. CERTIFICATION
/ certify under penalty of law that I have personally examined, and am familiar with, the statements and information
submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for
obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true,
accurate and complete. I am aware that there are significant penalties for submitting false statements and information or
omitting required statements and information, including the possibility of fine or imprisonment.
Signature of Responsible Official:
Date Signed:
OFFICIAL USE ONLY
Reporting Period End Date:
Postmark Date:
Date of Initial Review:
Review Conducted By:
Certification Is:
D
Complete
D
Incomplete
Explain:
EM Reference Document - 9/30/93 Draft
F-3
-------
Appendix F: Sample Summary Report Form
ENHANCED MONITORING REPORT
Part B - Unit Information
1. BASIC DATA
Unit Identification:
Process Description:
Control Device (if applicable}:
Pollutant/Parameter Identification:
S02
NOX
D
CO
D
PM
D
VOC
D
Other Ispecify):
EmtMiOM St»ndard(»)/Umhation(«>
On unit* oftfioftfitdfrdt
Averaging Time
Regulatory
Reference
Permit Reference •
2. ENHANCED MONITORING PROTOCOL INFORMATION
Monitoring Type (for each element of the EMP check the appropriate box, and then provide a brief description in the space
provided):
I I Continuous Emissions Monitoring System
' I Fuel Sampling and Analysis
I I Mass Balance and/or Emission Factors
I I Control Device Parameter Monitoring;
I I Other Instrumental Process Monitoring
I I Mass Balance and/or Emission Factors
Brief Description of EMP:
3. COMPLIANCE SUMMARY
Th« emissions unit on the last day of the reporting period was/was not in compliance with all emission standards/limitations
subject to enhanced monitoring, (circle one)
The emissions unit was in continuous/intermittent compliance during the reporting period with all emission
standards/limitations subject to enhanced monitoring, (circle one)
Giv» th« Permit ID, Unit ID, and PoiiutantlDi;i:;1 .
F-4
EM Reference Document - 9/30/93 Draft
-------
Appendix F: Sample Summary Report Form
ENHANCED MONITORING REPORT
Part B - Unit Information (cont.)
Provide the following EMP performance information:
CauMS of EMP Downtime* (Excluding Any Applicable
Zero and Span Checks}
Monitor Equipment Malfunctions
Man-Monitor Equipment Malfunctions (e.g..
computer, data recorder, etc.)
Quality Assurance
Other Known Causes
Unknown Causes
Total
Downtime
Incident*
(Number)'
Total
Downtime
{Hours)
Percent
Unavail-
ability*
Comment!
"Percent Unavailability" is calculated by the following formula:
EMP Downtime
Source Unit Operating Time (Hours)
X 10O = Percent Unavailability
3. MONITORING DATA INFORMATION
Emission Limitation/Standard:
limitation/standard monitored by the EMP.
. (complete a separate form for each emission
Causes of Deviations
Process Start-up/Shutdown
Control Equipment Problems
Process Problems
Fuel Problems
Other Known Problem*
Unknown Causes
Total
Number of
Deviations
Totaf Duration
of Deviations
(Hours)
Percent of:
Monitored
Operating
Time*
Comments
" "Percent of Monitored Operating Time* is calculated as follows: divide Total Duration of Deviations by (Unit Operating
Time (Hours) - EMP Downtime During Unit Operating Time (Hours)), then multiply the result by 10O.
4. REQUIRED ATTACHMENTS
The total enhanced monitoring plan downtime for the reporting period is greater then the percentage specified in
the permit for this emissions unit, and a copy of the records that are required to be maintained pursuant to
5 64.6(a)(3)(iii) and (iv) is attached.
D
Non-exempt deviations occurred during the reporting period and/or the total duration of deviations for the reporting
period is greater than the percentage specified in the permit for this emissions unit, and a copy of the records that
are required to be maintained pursuant to § 64.6(a)(3)(i) and (v) is attached.
This emissions unit undertook additional measures during the reporting period to demonstrate compliance with an
applicable emission limitation or standard or with an enhanced monitoring requirement, and a summary of each
compliance test or other requirement is attached.
Give the Permit iD, Unit ID, and Pollutant ID:
EM Reference Document — 9/30/93 Draft
F-5
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APPENDIX 1-1
FACTSHEET ON NORWEGIAN INKOSYS DATABASE
-------
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N'r. 5 E - September 1995
INDUSTRY
SFT's Department
of Industry hand-
les discharge per-
mit applications
from industrial
and offshore acti-
vities and follows
up given permits.
The department
administers 'the
Cleaner Technolo-
gy Programme and
the njonitoring of
areas' polluted by
industral an'd offs-
hore activities. It
also participates
in international
cooperation
within the fields
where it is
responsible.
INKOSYS
To gain better access to environmental data gathered from Norwe-
gian industry, the Norwegian Pollution Control Authority establis-
hed the INKOSYS database in 1978. This database provides easy
access to information about discharge permits granted by the Nor-
wegian Pollution Control Authority as well as information from
enterprise reports. Intended originally for internal use only, this
database now serves a number of external users as well.
The database is organised in three
main parts:
• A register of all permits that have
been granted and a list of the requi-
rements each enterprise has to fulfil
• A register of inspections carried out
by the Norwegian Pollution Control
Authority
• A register of annual quantities of
industrial emissions and waste
INKOSYS provides a basis for the
Norwegian Pollution Control Authority
to compile statistics and summaries of
emissions, as well as ready access to
current requirements applicable to spe-
cific enterprises and industries.
Discharge permits
The Pollution Control Act requires
industrial enterprises engaging in pol-
luting activities to obtain permits for
their emissions. Around 1600 enter-
prises currently hold permits, which
may place restrictions on such factors
as production volumes, emissions to air
and water, waste and noise. All of this
is recorded in INKOSYS.
Inspections
The Norwegian Pollution Control Aut-
hority carries out inspections to find
out whether applicable requirements
are complied with. Approximately 400
inspections are conducted each year.
Enterprises that are found to be in vio-
lation of applicable requirements are
followed up according to established
procedures. The results of inspections
are recorded in INKOSYS. This infor-
mation is used to set up goals for the
coming year's inspection activities and
to compile annual reports on the total
inspection activity.
Pollution reports
In 1992 new procedures for reporting
by enterprises holding discharge per-
mits were introduced. The Norwegian
Pollution Control Authority uses a '
standard form to inform each enter-
prise of the permit conditions and the
substances for which the permit appli-
es, and the enterprise is required to
report its actual pollution figures. This
report form is sent to around 400 enter-
prises at the beginning of each year.
To ensure registration of the most
important sources of pollution, repor-
ting has been made mandatory. It is
also important to standardize these
annual reports so as to make them pre-
dictable and thus a lesser a burden on
the industry. Before the reporting sys-
tem was implemented, the Norwegian
Pollution Control Authority asked the
enterprises involved for comments in
order to make these reports an effective
tool for the authorities as well as for
the enterprises themselves.
SET
Norwegian Pollution Control Authority (SFT)
P.O.Box 8100 Dep.. 0032 O-,li>. Ti-l.-|ili.>iu--i-*7 " ~~ ' " ------
.l-t no - l-';i\ +47 ±2 nT i>7 0<>
-------
The reports consist of the following
three main sections:
Part 1: Statements dealing with speci-
fic requirements in the dischar-
ge permit.
Part 2: Statements of deviations, i.e.
descriptions of circumstances
that deviate from the specifica-
tions of the discharge permit.
Part 3: Statements of total annual pollu-
tion and waste quantities for the
entire enterprise, i.e. figures for
specified components of pollution
and waste per calendar year.
After receiving these reports, the Nor-
wegian Pollution Control Authority
classifies any excesses. Enterprises
reporting major excesses will be contac-
ted promptly, and inspections may be
conducted to ensure that problems are
rectified as quickly as possible.
Public information
Certain kinds of information registered
in INKOSYS may be provided to anyone
who asks. Information is provided if the
request is restricted to a specific topic,
and compilation of the requested report
is not unreasonably difficult. This appli-
es chiefly to emissions of polluting sub-
stances such as toxic substances to
water or air. The most common users of
this information, aside from the environ-
mental authorities, are research institu-
tes, industrial enterprises, universities
and technical schools, trade organisati-
ons and environmental groups.
Information on which enterprises have
been granted discharge permits by the
Norwegian Pollution Control Authority
is available to the public. Those who
require further information on the
details of individual permits may con-
tact the Industrial Department of the
Norwegian Pollution Control Authority,
which is responsible for handling appli-
cations and granting permits.
All information on inspections is desig-
ned for internal use only, so inspection
reports are not distributed. A summary
of this information is published once each
year, however. Information pertaining to
specific enterprises may be obtained by
contacting the Industrial Department.
Information on annual industrial pollu-
tion is compiled and published in the
reports Pollution in Norway and Indus-
tri og Milj0 (Industry and Environ-
ment). Other reports, such as pollution
figures for specific industries, may also
be prepared. Enquiries regarding pollu-
tion from specific sources, i.e. quantiti-
es of specific toxic substances emitted
by specific enterprises, must be direc-
ted to the Industrial Department.
The terms of the concession granted by
the Data Inspectorate place restrictions
on the disclosure of information. One
restriction prohibits disclosure if the
information is intended for such com-
mercial activities as marketing or
advertising. This means that the Nor-
wegian Pollution Control Authority
does not compile lists of enterprises or
industries for consultancies etc. unless
they have a specific use for such infor-
mation in connection with work com-
missioned by the Norwegian Pollution
Control Authority.
Data from INKOSYS -
• Contribution by the industrial sector towards the fulfilment of national and. - '
international programmes and conventions targeting the reduction of emissions.r"
• Annual reports to the Norwegian Pollution Control Authority^ on which L-:
basis priorities for following up specific enterprises is set. •• v--:;
• Changes in the amounts of selected toxic substances emitted to the environ-
ment over time. :
ISSN 0806-4008 TA-1246/1995
9/95.500. Lobo Grafisk as. Printed on recycled paper
-------
APPENDIX J-l
NORWAY'S INTERNAL CONTROL REGULATIONS
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-------
i
Internal control
Regulations, with guidelines
Ministry of Local Government
Oslo 1991
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PREFACE
The Regulations concerning internal control were laid down by Royal Decree
of 22 March 1991. The regulations enter into force on 1 January 1992.
The regulations concerning internal control contain provisions which stipulate
that the person responsible for an enterprise1 has an obligation to arrange for
systematic follow-up of current requirements, as laid down in the Working
Environment Act, the Pollution Control Act, the legislation relating to fire
and explosion hazard and fire prevention, the Product Control Act, the Civil
Defence Act and the Act relating to Inspection of Electrical Installations and
Electrical Equipment. The purpose is to promote health and a good working
environment, and improve safety.
The regulations underline the management's special responsibility, but pre-
suppose active participation from all persons involved.
Guidelines have been prepared to supplement and explain the content of the
regulations. The guidelines are not legally binding. The provisions of the
regulations will be best understood by studying the regulations and the
guidelines together. Solutions other than those indicated in the guidelines may
be chosen provided that they meet the requirements of the regulations.
Oslo, februar 1992
1 See Guidelines to the regulations, comments to § 2.
-------
Regulations concerning internal control
Laid down by Royal Decree of 22 March pursuant to § 16a of Act No. 4 of 4
February 1977 relating to worker protection and working environment etc.,
§ 14 Act No. 47 of 21 May 1071 relating to flammable goods, § 14 Act No. 39
of 14 June 1974 relating to explosives, § 4 of Act No. 26 of 5 June 1987 relating
to fire prevention etc., § 52b of Act No. 6 of 13 March 1981 concerning
protection against pollution and concerning waste, § 8 of Act No. 79 of 11
June 1976 relating to product control, § 41, cf. § 48, of Act No. 9 of 17 July
1953 relating to Civil Defence, and § 9, cf. § 3, of Act No. 4 of 24 May 1929
concerning inspection of electrical installations and equipment.
Chapter I. Introductory provisions
§ 1. Purpose
These regulations shall enhance
- the working environment and safety
- protection against damage to health and the environment from products
- protection of the external environment against pollution and better treat-
ment of waste, through the person who is responsible for the enterprise
organizing systematic measures to ensure that the requirements stipulated in
or in pursuance of Acts or regulations are complied with.
§ 2. Scope
These regulations apply to
a) enterprises subject to
- Act No. 4 of 4 February 1977 relating to worker protection and working
environment etc.
- Act No. 79 of 11 June 1976 relating to product control
- Act No. 9 of 17 July 1953 relating to Civil Defence, § 48, cf, § 41 (enter-
prises that are required to have an industrial civil defence organization)
b) enterprises that engage employees and are subject to Act No. 6 of 13 March
1981 concerning protection against pollution and concerning waste (The
Pollution Control Act)
c) public and private enterprises subject to
- Act No. 47 of 21 May 1971 relating to flammable goods
- Act No. 39 of 14 June 1974 relating to explosives
- Act No. 26 of 5 June 1987 relating to fire prevention
- Act No. 4 of 24 May 1929 relating to inspection of electrical installations
and electrical equipment, § 9, cf. § 3.
These regulations are not applicable in Svalbard nor to enterprises as mentio-
ned in § 2, sub-section 3, of the Working Environment Act, cf. Royal Decree
-------
of 1 June 1979, concerning worker protection and working environment etc.
in connection with exploration for and exploration of submarine petroleum
resources.
§ 3. Definitions
In these regulations the following definitions apply:
Internal control
To ensure that requirements stipulated in or pursuant to Acts or regulations
are complied with.
Internal control system
Systematic actions to ensure and document that the activities are performed
in accordance with requirements stipulated in or pursuant to Acts or regula-
tions. The systematic actions shall be described in administrative procedures.
System audit
Systematic examination of the enterprise in order to establish that the internal
control activities and the results of the same conform with the internal control
system and that the internal control activities are appropriate to achieve the
objectives of the enterprise with regard to environment and safety.
Sertificate
Documentation issued by an accredited certifying body, other authorized
company or public authority which that a product, a service or an activity
conforms with specified requirements stipulated in or in pursuance of Acts or
which are in other respects valid for the issuer.
§ 4. Penal provisions and coercive fine
The provisions concerning punishment and coercive fines in the Acts mentio-
ned in § 2 apply in cases of violation of these regulations.
§ 5. Entry into force
These regulations enter into force on 1 January 1992. The Ministry of Local
Government, after consultations with the Ministry of Environment, the
Ministry of Children and Family Affairs and the Ministry of Justice, may
decide that the obligation stipulated in § 7 to establish an internal control
system shall be made to apply at a later date for certain types of enterprises.
Chapter ii. General provisions
§ 6. Obligation for internal control - obligated subject
Any person who carries out or participates in an activity that is subject to these
regulations has an obligation to ensure that they are complied with.
The person who is responsible for an enterprise that is subject to these
regulations has a special responsibility to ensure that the activities of the
-------
enterprise are carried out in accordance with the requirements that are
stipulated in or pursuant to the regulations.
This responsibility implies inter alia:
- clarifying objectives, responsibilities and tasks for the environmental and
safety activities of the enterprise.
- responsibility for identifying and assessing risks and problems, and for pre-
paring plans of action, with measures.
- systematically monitoring that the activities of the enterprise comply with
the objectives defined by the enterprise.
§ 7. Obligation to establish an internal control system -
obligated subject
The person who is resposible for an enterprise that is subject to these
regulations shall establish an internal control system for the activities of the
enterprise in accordance with the requirements stipulated in or in pursuance
of the Acts mentioned in § 2.
Development of, practise of, and changes to the enterprises's internal control
system shall place in cooperation with the employees at the enterprise.
If several enterprises at the same workplace employ a total of more than 10
employees simultaneously to carry out an activity, and no one of the enterpri-
ses can be regarded as th principal enterprise, it shall be decided by written
agreement which enterprise shall be responsible for the everyday management
of the joint activities, with obligation to establish a coordinated internal
control system for these.
§ 8. Supervisory authority
The supervisory authority according to the Acts mentioned in § 2 also
supervises implementation of and compliance with these regulations.
§ 9. Exemption
The Ministry of Local Government, after consultation with the Ministry of
Environment, the Ministry of Children and Family Affairs and the Ministry
of Justice, may grant exemption from these regulations when special condi-
tions exist for so doing.
§ 10. Appeal
Individual decisions made by authority of these regulations may be appealed
to the administrative body immediately superior to the administrative body
that has made the decision, cf. the Public Administration Act.
-------
Chapter in. Special provisions concerning
internal control
§ 11. Development of the internal control system
The internal control system shall be developed by the person who is respon-
sible for the enterprise within the framework of the Acts mentioned in § 2.
The internal control system shall establish coordinated administrative proce-
dures for internal control and shall cover all aspects of the activities of the
enterprise in order to ensure that these are planned, performed, maintained
and controlled in accordance with the requirements in force.
The internal control system shall contain inter alia:
a) the management's objectives for the environmental and safety activities of
the enterprise.
b) a description of how the enterprise is organized, including the area of
authority and responsibility of the environmental and safety activity of the
enterprise, with reference to possible job instructions.
c) written routines and procedures for ensuring that the enterprise complies
with Acts and regulations, also showing who is responsible for examina-
tions, implementation of measures, and how these are performed and
followed up.
d) a description of how the internal control system is systematically and regu-
larly updated and how employees and other affected parties are informed
of the changes.
§ 12. Internal monitoring
The person responsible for the enterprise shall monitor the internal control
system. The monitoring shall take place in cooperation with representatives
of the employees.
§ 13. Coordination
The person who is responsible for the enterprise is also responsible for
coordinating the internal control of all the activities at the enterprise and shall:
- as far as possible build on the internal control system established by the con-
tractors and supplies that are used
- assess whether adjustments should be made to his/her own internal control
systems established by the contractors and suppliers that are used
§ 14. Documentation
The person responsible for the enterprise shall document the internal control
system and its implementation in writing. Certificates may be included as part
of the documentation. The person who is responsible for the enterprise shall
at all times keep the documentation available for the authorities.
-------
Guidelines to the Regulations concerning
Internal Control
PREFACE
The regulations lay down provisions stipulating that the person responsible
for the enterprise is under obligation to organize systematic measures to
ensure that the requirements of the authorities are complied with. The
purpose is to enhance:
- the working environment and safety
- protection against damage to health and the environment from products
- protection of the external environment against pollution, and better treat-
ment of waste.
The guidlines contain supplementary comments to the Regulations concerning
Internal Control.
The guidelines are not legally binding, and thus do not prevent a person from
choosing solutions other than those described in the guidelines, provided that
these conform with the requirements of the regulations.
The best possible understanding of the provisions of the regulations willl be
obtained by studying the regulations together with the guidelines.
Chapter I - Introductory provisions
To § 1. Purpose
The intention of the regulations con-
cerning internal control is that the
person responsible for the enterprise
shall systematize his/her efforts to
achieve a better working environ-
ment, better protection of the exter-
nal environment against pollution,
better treatment of waste and better
protection against damage to health
and the environment from products,
and his/her efforts to prevent acci-
dents or mishaps due to fire or explo-
sion. The actual wording expresses a
recognition that, through manage-
ment, control and participation, a
person responsible for an enterprise,
an emloyee and an authority can do
more to prevent damage.
The person responsible for the enter-
prise means the following in the diffe-
rent Acts: ^
- The forking Environment Act;
the employer
- The Pullution Control Act; the per-
son responsible for the pollution
- The Product Control Act; a ma-
nufacturer, importer or person in-
volved with a product by reason of
occupation
- § 48 of the Civil Defence Act;
owner, supervisor
- The Act relating to explosives; a
person who manufactures, stores,
transports, procures, uses, im-
ports, exports or trades in explo-
sives
- The Act relating to flammable
goods; a person who stores, hand-
-------
les, transports or trades in flam-
mable goods
- The Fire Prevention Act; owner
and user of buildings for commer-
cial purposes
- The Act relating to inspection of
electrical installations and equio-
ment; owner and user of such in-
stallations and equipment.
Therefore, one of the purposes of the
regulations on internal control is to
get the person responsible for the
enterprise to:
- define his/her objectives for health,
environmental and safety work at
the enterprice
- achieve a clear and appropriate di-
stribution of tasks in the work to
promote health, safety and a good
working environment, and in fol-
lowing up measures
- ensure that the employees possess
the necessary knowledge and other
qualifications to carry out their
tasks
- systematically identify and assess
risks in connection with the work
and risks connected to the products
used, manufactured, imported or
sold
— systematically implement measu-
res to improve health, environment
and safety, for example through
actively adjusting the objectives of
the enterprise as a whole, and by
planning and follow-up in the form
of written plans of action to be im-
plemented by a specified deadline
- document the organization to the
extent that this is important for
dealing with matters related to
health, environment and safety,
and document routines for mana-
gement and control of activities at
the enterprise
- continually follow up, assess and if
nesessary change his/her internal
control system.
At many enterprises, routines have
already been established to safeguard
health, environment and safety. The
requirement for a system implies that
the enterprise must further develop
and achieve coherence in the routines
and procedures that have been esta-
blished. It is very important that mat-
ters concerning health, safety and the
environment are dealt with «in the
line». It is thus not always appro-
priate to develop a completely new
system or a new organization in addi-
tion to the one that is needed to ope-
rate the enterprise.
Employee partcipation is both a pre-
requisite and a democratic right in
the development and follow up of the
internal control system at the enter-
prise, and when preparing working
routines and plans of action. The
employees constitute an important
resource because they possess expe-
rience of the everyday running of the
enterprise. Participatory influence is
also important in itself as a factor
promoting work, motivation and
learning. Such influence will make it
more certain that the established rou-
tines are also complied with in prac-
tice.
To §2 Scope
The term «enterprice» has slightly
different meanings in the Acts men-
tioned under sub-sectin a). For a
more detailed definition of what is
meant by the term «enterprise», the
reader is referred to the different
8
-------
Acts. Cases of doubt about the scope
of the regulations should be referred
to the supervisory authority for clari-
fication.
As far as the Product Control Act is
consented, the regulations currently
apply to any person manufacturing,
processing, importing, selling, or
using a product by reason of occupa-
tion. As regards sub-section c), the
regulations will apply to each and
every public and private commercial
enterprise and service enterprise.
This means that the regulations do
not apply only to traditional commer-
cial enterprises. They also apply to
hospitals, schools, etc. The term «ser-
vice enterprise* will therefore be
subject to wide interpretation.
It is stated in another section of the
regulations that they do not apply in
Svalbard or to petroleum activities
on the Norwegian continental shelf.
Regulations concerning internal
control in petroleum activities were
passed several years ago. The mate-
rial requirements in the internal cont-
rol regulations for petroleum activity
deviate on certain points from the
requirements described in the present
regulations. In order to avoid confu-
sion before the principle has been
incorporated in onshore enterprises,
it is considered expedient to allow the
established supervisory activity on
the continental shelf to continue until
the present regulations are generally
in force. The intention is to integrate
the two regulations when the present
regulations have been applied for a
time. Until this is done, internal cont-
rol offshore is governed by the regula-
tions laid down by the Norwegian
Petroleum Directorate, i.e. the regu-
lations concerning licensee's internal
control in petroleum activities on the
Norwegian continental shelf.
This implies that the requirements of
the present regulations must be coor-
dinated with those of the regulations
concerning the licensee's internal
control. The obligation to coordinate
the two sets of regulations is evident
from § 5 of the regulations concerning
the licensee's internal control and
from § 13 of the present regulations.
To the extent that the Norwegian
Petroleum Directorate, during audits
etc. at the licensee's, imposes requi-
rements which lead to changes in the
contractor's internal control system,
the Labour Inspection must be infor-
med if such changes affect the way in
which the obligations pursuant to the
Working Environment Act are fulfil-
led, see § 6.
To § 5 Entry into force
The regulations concerning internal
control enter into force on 1 January
1992. However, the regulations pro-
vide access to postpone the entry into
force of the obligation to establish an
internal control system in the case of
specific types of enterprises.
-------
Chapter ii General provisions
Til § 6 Obligation for Internal
control - obligated subject
The person responsible for the enter-
prise is the obligated subject pursuant
to these regulations. It is important
to emphasize, however, that eve-
ryone should take part in the internal
control. This is why the regulations
impose a requirement for responsibi-
lity on the place of work. This will
mean, for example that:
Managers
- define objectives for health, the
working environment and safety at
the enterprise in the same way as
they define the expected results for
the different areas of operation
- define safety requirements for the
products that are manufactured,
imported or sold
- ensure continual assessment of the
enterprise's routines and products
in the light of new knowledge
- work out strategies and concrete
progress schedules for attaining the
objectives of the enterprise
- ensure that all employees receive
good information about objectives,
strategies and plans
- require all their subordinate mana-
gers to accept responsibility for
health, environment and safety, in
the same way as for all other areas
of operation
«middle management^
work supervisors
— accept a clear management respon-
sibility for health, environment and
safety, in the same way as for the
rest of the operations
- make an active effort to learn about
the experiences of the employees
from the employes themselves, and
seek assistance from safety delega-
tes and health personnel
- systematically obtain key figures
on health, environment and sa-
fety at regular intervals, and follow
up these figures by plans of action
and measures
- take the initiative and become a
driving force for internal control
efforts in their own area of respon-
sibility
safety delegates
- receive training in the work of
internal control and in the work of
actively solving problems, and the
necessary time to become involved
in such matters
- participate in the regular health,
environmental and safety inspec-
tions together with the manager/
supervisor responsible for the ope-
ration concerned.
safety and health personnel
- systematize their findings from vi-
sits to the workplace and from
health examinations and provide
* regular and intelligible data on
health and accident statistics to the
operating organization
- ensure that this information and
these key figures are considered in
relation to data on sick leave,
«turnover», and branch statistics,
and point out what measures are
necessary to promote health
- work to ensure that health, envi-
ronment and safety become a natu-
ral, important and integrated as-
pect of the activities of the enter-
prise.
10
-------
employees
- show responsibility for their own
safety and that of others, and make
an active effort to reduce the risk
of unfortunate environmental in-
fluences, and any adverse effects
- make an effort to ensure that their
working experience is exploited -
also in connection with health, en-
rironment and safety
- follow the established instructions
for the work operations concerned.
To §7 Obligation to establish an
internal control system
The obligation to establish an internal
control system implies that the acti-
vity shall be planned, organized,
arranged and maintained so as to
ensure compliance with the require-
ments of the legislation. The internal
control system shall apply to all activi-
ties at the enterprise. This implies
that the internal control shall both
cover all levels of the enterprise and
all phases of operations.
According to § 12, sub-section 3, of
the Working Environment Act, em-
ployees shall be kept informed about,
and receive the training required to
enable them to understand the sy-
stems employed for planning and
directing the work. They shall also
help to develop these systems. It is
assumed that the employees will be
kept similarly informed about the
implementation of internal control
systems.
When a particular activity is carried
out by several persons, it is important
to ensure that also this activity, in
Itself, is performed in compliance
with the relevant Act and regulations.
The provision is analogous with § 15,
sub-section 2, of the Working Envi-
ronment Act, which determines
which enterprise is to be regarded as
the principal enterprise.
The obligation of each enterprise to
establish an internal control system
pursuant to sub-section 1 is not affec-
ted by the detailed stipulation in sub-
section 2 concerning what is applica-
ble when several enterprises are
involved.
To § 8 Supervisory authority
This provision establishes which
agency shall supervise observance of
the regulations. The following admi-
nistrative agencies shall carry out this
supervision:
- The Labour Inspection (Working
Environment Act)
- Directorate for Fire and Explosion
Prevention/Municipal Fire Board
(Act relating to flammable goods,
Act relating to explosives, Act re-
lating to fire prevention)
- The Norwegian Electricity Inspec-
torate (Act relating to inspection of
electrical installations and equip*
ment)
- The State Pollution Control
Authority (Pollution Control Act
and parts of the Product Control
Act)
- Ministry of Children and Family
Affairs (part of the Product Con-
trol Act)
- The industrial civil defence organi-
zation (Civil Defence Act).
The internal control regulations
assume that the supervisory authori-
11
-------
ties will gradually place the emphasis
on system audit. System audit means
that the supervisory authority under-
takes a detailed examination of the
documentation that the enterprise
has prepared for the purpose of docu-
menting its plans of action, organiza-
tion and routines for monitoring
health, environment and safety.
In addition to examining the docu-
mentation prepared by the enterpri-
se, the system audit shall also find out
whether the most; important factors
have received proper priority. Fac-
tors of fundamental importance for
the supervision include:
- accident statistics
- sick leave statistics and health re-
ports
- risk assessments
- list/description of events with pos-
sible impacts on the environment
- emission records and statistics
- product documentation
as well as experience from earlier
inspections and supervision.
In addition to examining the docu-
mentation prepared by the enterpri-
se, the supervisory authority will also
undertake investigations to ensure
conformity between the employer's
documented internal control and
implementation of the control in
practice.
The regulations say nothing about
how the internal control system is to
be organized; they only lay down
requirements concerning the ele-
ments of the system. During their
supervision, the authorities will be
prepared to accept the different ways__
chosen by the various enterprises to
organize the internal control, and will
use these as the basis for the super-
vision.
If the authorities discover inadequa-
cies in the internal control of the
enterprise, they may instruct the
enterprise to make changes. For
example, the internal control system
may be inadequate because it does
not cover the legislation that applies
to the enterprise, because the system
established in practice does not agree
with the prepared description, or
because the system, as described, is
not followed in practice. Because
several agencies are responsible for
supervising the internal control of
enterprises in accordance with the
same regulations but by authority of
different Acts, these agencies will
cooperate and coordinate their activi-
ties.
To § 9 Exemption
Exemption may be granted only
when special conditions so dictate.
Whether such special conditions
actually exist must be decided in the
specific case. The evaluation must
give due consideration to the conse-
quences of the exemption for the
exercise of internal control, and thus
for health, the environment and safe-
ty at the enterprise.
To § 10 Appeal
According to the Public Administra-
tion Act, in the case of all individual
decisions it must be stated which
agency constitutes the appeal instan-
ce in the specific case.
Decisions made by the local Labour
Inspection may be appealed to the
Directorate of Labour Inspection.
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Decisions made by the Directorate of
Labour Inspection in the first
instance may be appealed to the Mini-
stry of Local Government.
Decisions made by the Chief Munici-
pal Fire Officer may be appealed to
the Municipal Fire Board. Decisions
made by the Municipal Fire Board
may be appealed to the Directorate
for Fire and Explosion Prevention.
Decisions made by the Directorate
for Fire and Explosion Prevention in
the first instance may be appealed to
the Ministry of Local Government.
Decisions made by the local electri-
city inspection may be appealed to
the Norwegian Electricity Inspecto-
rate. Decisions made by the Norwe-
gian Electricity Inspectorate in the
first instance may be appealed to the
Ministry of Local Government. Dici-
sions made by the Ministry of Child-
ren and Family Affairs may be appea-
led to the King in Council.
Decision made by the municipality
may be appealed to the County
Governor. Decisions made by the
County Governor in the first instance
may be appealed to the State Pollu-
tion Control Authority. Decisions
made by the State Pollution Control
Authority may be appealed to the
Ministry of Environment.
Decisions made by the industrial civil
defence organization may be appea-
led to the Directorate of Civil
Defence and Emergency Planning.
Chapter III - Special provisions concerning internal control
To §11 Development of the
internal control system
The regulations state that the person
responsible for the enterprise shall
develop the internal control system.
This obligation involves documenting
and effecting systematic measures to
ensure compliance with require-
ments. The measures shall be adap-
ted to each enterprise, depending on
its size and the scope of its activities.
Thus the individual enterprise may
itself decide how the internal control
system will be designed and what
measures will be implemented.
The internal control system shall
cover all aspects of the activities of
the enterprise within the framework
of the Acts mentioned in § 2. Thus it
is necessary to prepare procedures to
ensure that, at all times, the activities
are planned, organized, performed,
maintained and controlled.
It is assumed that the employees will
participate in the development and
follow-up of the internal control
system, cf. § 12, sub-section 3, of the
Working Environment Act.
In the case of certain enterprises it
will be natural to prepare a joint
system for quality assurance and
internal control. Standards have not
been prepared, however, for all the
areas dealt with in the regulations
concerning internal control. Therefo-
re, for some enterprises, two totally
different systems will be necessary,
which must be established separately.
Moreover, the supervisory authori-
ties are not affected by what an enter-
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prise may wish to include in the way
of self-imposed requirements, custo-
mer requirements, etc.
The internal control system may des-
cribe, inter alia:
- the objectives of the enterprise in
regard to the working environment
and safety, product safety, and pro-
tection against pollution
- the organization of the enterprise,
with a clear indication of distribu-
tion of authority and responsibility
- routines and procedures for regu-
lar, systematic investigation of the
status of the working environment
and safety, product safety, and of
protection against pollution
- relevant information indicating
whether the working environment
and safety, product safety and pro-
tection against pollution conform
with the respective Acts
- how these routines and procedures
form the basis for preventing pro-
blems connected to health, envi-
ronment and safety
- implementation of the nesessary
monitoring (measurements) and
risk assessments
— routines and procedures for what
is to be done, who is responsible for
doing it, how it is to be done and
who is to be informed of the result
— necessary written instructions
- how the enterprise clarifies the em-
ployees' need for training and in-
formation, and what measures
should be introduced to cover these
needs, to enable the employees to
meet their obligations and safe-
guard their rights in accordance
with the legislation
- what documents must be filed, and
how these are revised
- how deviations are dealt with and
corrective actions initiated
- how the internal control system is
updated and corrected, and how
affected parties are informed of
such changes.
To § 12 Internal monitoring
Internal monitoring is an examina-
tion of the internal control system,
carried out by the person responsible
for the enterprise, cf. § 7. The moni-
toring may take the form of a system
audit. Verification may be included
as part of the system audit.
System audit may also be used by the
supervisory authorities in their work
of control, cf. § 8.
The purpose of internal monitoring
in the form of system audit is to con-
firm that the internal control system
has been established and is being fol-
lowed in a way that ensures comp-
liance with the requirements of the
authorities. The audit is furthermore
intented to bring to light weaknesses
in the system. For example, the orga-
nization chart, procedures, instruc-
tions and job instructions must be
reviewed in detail in order to ensure
that they are good enough. Based on
the information obtained from such
an investigation, a description must
be prepared of any measures that are
considered necessary in order to cor-
rect or put right any deficiencies or
obscurities.
Verification is an investigation, exa-
mination, random check etc. to find
out if the internal control system is
functioning in practice, as indicated,
for example, by the fact that:
- the prescribed action has been
taken
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- monitoring records are up-to-date
- samples have been analyzed in ac-
cordance with prescribed proce-
dures
- routines are being followed for di-
ferent work operations
- the right qualified equipment and
personnel are used for the different
activities
- production documentation is avai-
lable and has been evaluated
and that, in other respects, the activi-
ties conform with the requirements
of the authorities.
It is emphasized that a verification
should not only take the form of a
final quality control, but should be
included as part of all aspects of the
activities of the enterprise. If the veri-
fication brings to light non-conformi-
ties in relation to specified require-
ments, these non-conformities shall
be put right, and corrective action
shall be taken in order to avoid repe-
tition.
The system audit shall take place in
cooperation with representatives of
the employees, cf. the Working Envi-
ronment Act, § 24, new sub-section 2
(e), and § 26, Sub-section 4, second
paragraph, last item.
To § 13 Coordination
In practice, this provision will apply
to larger enterprises and to enterpri-
ses which make use of contractors
and suppliers. In enterprises consis-
ting of several departements or divi-
sions, the internal control system
must cover all activities at the enter-
prise.
The rules also imply that the person
responsible for the enterprise also has
an obligation to ensure that the cont-
ractors or suppliers used by the enter-
prise have established an internal
control system which satisfactorily
covers the activities performed at the
enterprise. It is emphasized that this
obligation for coordination will nor-
mally be met if the management has
assured that such internal control
systems do, in fact, cover the activi-
ties concerned.
In other words, it is not the intention
of this provision to imply that con-
tractors etc. must have an internal
control system that is the same as, or
completely adapted to, the system
established at the enterprise that
engages the contractor. The intention
is to ensure that the systems are coor-
dinated to the necessary degree, to
make sure that the final product con-
forms with the legislation.
This main principle is emphasized by
the statement that the enterprise shall
as far as possible build on the internal
control systems established by cont-
ractors etc. The obligation of the per-
son with primary responsibility for an
internal control system does not,
however, relieve contractors or supp-
liers of the responsibility to establish
an internal control system at their
own enterprise.
To §14 Documentation
The person responsible for develo-
ping the internal control system must
ensure that it can be documented in
writing that the internal control
system has been established, how it is
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built up and how it is intended to
function. The documentation is of
major importance for the system
audits conducted by the supervisory
authorities. The person responsible
for the enterprise shall keep the docu-
mentation on the internal control
system available for inspection by the
supervisory authorities at all times.
Thus the regulations do not the enter-
prise to send such documentation to
the supervisory authorities in order
to demonstrate that the obligation to
establish an internal control system
has been complied with. It is enough
that the documentation is available
upon request. The provision gives no
instructions as to how this documen-
tation shall be designed, apart from
stating that certificates may be inclu-
ded as part of the documentation.
The purpose is to signal that it is not
necessary to produce new documen-
tation in cases where documentation
exists already. Thus the enterprise
itself must assess how simple or how
complex the documentation of the
internal control system needs to be,
taking into account, inter alia, the
size and complexity of the enterprise.
Delegating approval of the system to
external consultants does not relieve
the person under obligation to esta-
blish the system of his/her responsibi-
lity to ensure that the internal control
system, at all times, satisfies all the
requirements of the legislation in
regard to the activities of the enterpri-
se, and to ensure that the system func-
tion as expected.
Use of certificates does not in any
way affect the responsibility to esta-
blish an internal control system as
such. The way that the regulations
are formulated implies that this
responsibility is never reduced. The
person responsible for the enterprise
may use certificates as documenta-
tion that a verification has been
undertaken, and thus assume that the
conditions or activities to which the
certficates refer are achieved or are
performed in accordance with current
Acts and regulations. The obligation
for internal control that rests on the
person responsible for the enterprise
dictates that, in such cases, the person
concerned must also control which
areas of the legislation the certificate
refers to. On the other hand, the per-
son concerned will be relieved of the
responsibility of undertaking the
actual verification and of controlling
how it is carried out.
In this connection it must be emphasi-
zed that only those certficates that
are defined as a certificate in § 3 may
be used as documentation that a veri-
fication has been carried out. Other
types of certificates will not meet this
purpose.
Furthermore, a certificate may be
used as documentation only when
there is no reason to doubt the cor-
rectness of the certificate. If such
doubt does exist, the certificate can
affect the obligation to document the
internal control as prescribed in the
first paragraph only when the person
responsible for the enterprise has
assured him/herself that the certifi-
cate is genuine and reflects the actual
condidions concerned.
Febr. -92/10.000
Trykk: Senter Grafisk A.S, Larvik
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