1. Electronic Reporting Tool
Software to Standardize
Source Test Planning, Reporting
and Assessment
Measurement Technology Workshop
12/8/2010
Ron Myers
OAQPS/SPPD/MPG

2. Test Report Uses Compliance certification Modeling
Permit applications or revisions
Permit fee determination
Emissions Inventory
Performance Information
Modeling
Risk Assessment
Environmental Justice Issues
TRI – CERCLA – SARA
AIRS AFS reporting
Complaint Evaluations
The traditional uses for stack test results are very limited. As a result, many of these additional uses do not use information gleaned from stack test data. In addition to the test report information not being used for a variety of programs that impact the facility tested, this information is not used for programs that impact a broader population and are covered by non compliance related programs.

3. The Electronic Reporting Tool
Version 3.1 Methods
Methods 1 through 4, 3A, 5, 6C, 7E, 10, 17, 23, 25A, 26A, 29, 101, 101A, 201A, 202, OTM-27, OTM-28 & CTM-039
Version 3.1 Pollutants
Filterable PM, Condensable PM, PM10, PM2.5, CO, Chlorine, Chloride, HCl, Total Chloride, NOx, SO2, Metals (Sb, As, B, Be, Cd, Cr, Co, Cu, Pb, Mn, Hg, Ni, P, Se, Ag, Th and Zn), TOC (as C, CH4, C2H6, C3H8), dioxin/furans, PCB’s, PAH (19)
The current version of the ERT has been expanded to include many of the more common test methods that are used in areas under the authority of State/local agencies.

4. New Unpopulated Project Data Set
When first opened, the only area where information can be entered is the Setup/ Test Plan area of the ERT.

5. Blank Test Plan Entry Screen
Here is the first tab of the ERT Setup/ Test Plan menu. You will also notice that there are nine other tabs that cover many other areas. Most of the information included in the Setup/Test Plan area were derived from requirements for Test Plans that are required by the States of North Carolina, New Jersey, Pennsylvania, Wisconsin, Ohio, Georgia, South Carolina which were polled for these requirements. A few items were added to satisfy several internal EPA programs including Enforcement and Emissions Inventory.

6. Here is the first tab of the Setup/Test Plan filled in to identify the facility to be tested and the company which will be performing the stack testing.

7. This is the detailed information which is on the second tab
This is the detailed information which is on the second tab. One detail that provides the source the ability to narrow the identification of the facility to be tested to those process characteristics that are available in the emissions inventory system and are listed in AP-42.

8. To support the use of the ERT in compliance testing, we have included a tab that identifies the specific reason for the emissions test, any additional purposes that the test may be used and a listing of the applicable State and Federal regulations that the test will be used to characterize compliance.

9. The Process/APCD tab includes information that is required to be collected during the emissions test that will either be used in the calculations as specified in the permit or will be used a part of subsequent assessments. For example, the process data to be documented may contain the process rate should the facility need that information to calculate their emissions on a production or process rate basis or used for identifying the ability to demonstrate compliance as part of a synthetic minor allowance. Other items included are for documenting specific parameters that influence the ability of the facility to operate within suitable ranges. These may be conditions that are required of the source to monitor as part of their Title V permit and used for determining compliance status when CEM’s are not used. There is a free form text field available to describe the specific details of the plants design, operation and controls installed. Lastly there is a list of control devices that is required to be completed. You will notice that there are some areas where there is a note that indicates that the field is required to be filled in before any test data entry is allowed. All the rest of the fields are optional at the discretion of the applicable authority. There are a few other field which are required.

10. This tab is the one of the more important tabs in that the emissions points to be tested, the relevant dimensions that are important for setting up the stack sampling are listed, the specific test method and pollutants to be measured are, the number of test runs and duration and the output concentrations are listed. If this tab is not set up correctly then the source tester will have great difficulty producing a viable result.

11. This provides information you would need to know prior to allowing the tester to perform the test or information that you should know before the test is submitted for your approval.

12. For test planning, you may wish to see some of this information so that you better understand the unique situations at the facility. For example, you may wish to se a diagram or picture of the sampling location, you may wish to see the approved alternative method request and may wish to see historical evidence on cyclonic flow.

13. Here is an example of a picture (jpg file) that was attached to this ERT.

14. Test Plan Review
Provides test contractor feed back on information needed prior to test
Allows State/local agency evaluation of proposed test program.
Notifies State/local agency of test date and special access requirements.
Allows for linked and improved documentation of acceptance or comments.
All of the material that you saw up to now was to be filled in by the source or the source test contractor. As a test plan reviewer, you see the same screens and tabs as were filled in but with additions to allow you to provide feedback to the source or source test contractor.

15. You will note that this page shows the same information that was in the tabs filled in by the source but with a salmon colored area to the right where you can approve or comment on the contents of the tab.

16. Here is a comment on one of the areas of the ERT which can be used to provide direction to the source or source test contractor.

17. Field data collection
Use Excel spreadsheet application used by many contractors
Modified to extract critical information into the ERT Access application
ERT application duplicates calculations in spreadsheet program using equations from FR methods
There are several options the field crew has in collecting field data. We have made a spreadsheet application available for the field crew meter box person to record the point by point data and meter box information. The spreadsheet is set up to allow the recorded data (not calculated information) to be imported into the ERT for recalculation.

18. Here is a screen shot of one of the runs entered into the spreadsheet application. If the tester wishes to use their own field data collection spreadsheet or form, then there are ways to import this data into the ERT without completely filling in all the data.

21. Test Report Data in ERT
Field test information is only stack gas information
Laboratory data added to report
Process data added to report
Control device data added to report

25. Test Report Data Quality Evaluation
Evaluates primarily the availability of documentation of critical instrument calibration and field data elements
Evaluates compliance with published FR test method requirements

27. Expanded QA Checklist? Completeness
Criteria Area
Review Questions
Completeness
Is a description of test location provided?
Review
Is a drawing of the test locations provided?
Has a description of test methods used, including deviations from standard procedures, been provided?
Has a detailed discussion of sampling conditions been provided?
Is a schematic of each sampling train attached?
Is a full description of the facility provided?
Were the operating parameters for the process being tested reported?
Are the parameters monitored by the facility to assess the performance of the control device described?
Have all emissions tests specified in the test plan been performed?
Calibration
Are the following reports attached?
Reports
Manual Test Methods
Dry gas meter pre-test calibration
Dry gas meter post-test calibration
Thermocouple and display calibration
Pitot inspection records
Nozzle inspection records
Flow meter calibrations
Instrumental Test Methods
Instrumental method analyzer interference tests
Response time tests
System bias tests
Converter efficiency tests
In a future version of the ERT, an expanded checklist will be provided. The ERT will partially evaluate some of these components but will not be able to verify that the material provided meets the requirements of the various regulatory and non regulatory program requirements. The ERT will not require that all items on the checklist be evaluated but will allow individual regulatory agencies to select those items that they wish to evaluate depending on the program goals.

28. Expanded QA Checklist (cont)
Raw Data
Are the following reports attached?
Reports
Manual Test Methods
Method 1 sample point evaluation
Cyclonic flow checks
Exhaust gas conditions
Raw sampling data
Field notes
Description of the recovery procedures
Complete laboratory report
Chain of custody forms
Flow diagram of sample analysis
Instrumental Test Methods
Stratification checks
Raw data
Sampling system flow and temperature logs
Calibration gas certifications
Calibration reports
Complete description of the sampling system
Process & Facility Operation
Process operating parameter data
Control device operating and monitoring parameter data
A detailed discussion of the process and control device operation
Here is a second page of the expanded checklist.

29. As a final assessment of the source test, we reproduce the applicable regulations that were identified during the Setup/Test Plan development and also the results of the test program. The regulatory authority can select the appropriate compliance assessment. These include Yes (lower than applicable compliance limit), No (exceeds applicable compliance limit) or Indeterminant (the regulatory authority can not determine if the source is within compliance).

30. ERT Availability & Future
On the CHIEF web site at
Test Methods Addition
Method 18, 320, 321, 0010, 0031, ?
Improved QA (automation and guidance)
Submission capabilities
Through EPA’s CDX by January 2012
Legal signature capabilities
CROMERR compliance

31. Open Discussion
QUESTIONS?
Ron Myers
(919)