Testing is Over: Reporting Your EGU MACT ICR Data May be More Challenging
Natalie Vaught, Weston Solutions, Inc.
Past participants in EPA’s information collection request (ICR) programs at oil- and coal-fired power plants are used to difficult and expensive emission test programs. But the recent ICR for which the reporting deadline is approaching is particularly challenging. Not only are the test programs complex, the data reporting requirements are challenging. Many plants will find that data reporting activities require as much time as coordinating and overseeing the field work.
Data reporting challenges originate from EPA’s desire to eliminate the re-entry of emission testing data from hard copy reports. To achieve this objective, EPA has developed an Electronic Reporting Tool (ERT) and spreadsheet reporting templates (SRTs) for reporting ICR data. In summary, data from emission testing reports and operating logs must be transferred into the reporting tools by the source operator. While these tools have improved since they emerged as the required method for reporting Boiler MACT/CISWI ICR program data, they remain difficult for the one-time or infrequent user.
To overcome data reporting difficulties, power plants will find it helpful to begin the data entry work at least two weeks before the reporting deadline. Preparations should involve a review of the 114 letter to confirm the scope and required identification information, collection of operations and air pollution control device data, and a review of the emission testing report to make sure it is complete and reflects the proper test methods and reporting units. Once this information has been assembled, the plant can download the ERT and SRTs, check for updates, and begin the process of transferring data following the required sequence of operations. The ERT and SRTs do not possess robust quality control features – plants must devise appropriate tools for verifying the accuracy and completeness of entered data.
Power plants are well familiar with electronic data reporting to support Part 75 test programs. An advance notice of proposed rulemaking on October 14, 2009 (FR 74, 52723-52734) makes it clear that the ERT will be central to emissions factor development. Further, there are indications that the ERT may be required for reporting Part 60 data. Given both the near- and long-term implications of the ERT, power plants and emission testing firms will benefit by using the ICR reporting experience to help guide future versions and applications of the ERT.
Learn about ERT reporting tools:
Keep up-to-date with ICR reporting requirements:
Learn about the history of regulatory development for power generation sources: