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Monitoring Data Verification at CAMD

Monitoring Data Verification at CAMD. Matthew Boze U.S. EPA CAMD boze.matthew@epa.gov. ECMPS. Goals of ECMPS Client Tool: Improve the efficiency of EPA’s data collection process Provide greater certainty of data quality through more complete checking of the data

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Monitoring Data Verification at CAMD

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  1. Monitoring Data Verification at CAMD Matthew Boze U.S. EPA CAMD boze.matthew@epa.gov

  2. ECMPS • Goals of ECMPS Client Tool: • Improve the efficiency of EPA’s data collection process • Provide greater certainty of data quality through more complete checking of the data • Reduce the burden of reporting especially by making it easier to trouble shoot and resolve errors

  3. ECMPS • 2009 was the first full implementation year for the ECMPS data validation process • As of July 8, we had just 54 files with critical errors on the list • In November we had 33 files with new 3rd quarter errors and 16 remaining from previous quarters. • By January we were down to 19 files at 9 facilities • Currently there is one issue outstanding pending resubmission in line with a recently finalized petition response.

  4. ECMPS • 100% of the Errors are resolved despite • Approximately 4 times the checks • Tighter tolerances • Stricter enforcement of basic procedures to ensure consistency • Who’s to thank? • Industry • DAHS Vendors • By working together we got the job done right!

  5. ECMPS – Changes • Any new checks and minor functionality upgrades will be aimed for a 1st quarter 2011 release • Changes to address expected revisions to EPA reference methods 2H are also to be included in this release • Also, changes to support revisions to the PGVP, and AETB programs to be added as well. • Plan is to have details on expected changes out by the fall so that any preparations needed can be made before April 2011 when the 1st quarter reports are due

  6. Additional QA Checks • Additional QA checks and data analysis are developed to assess the reasonableness of the data collected, or to identify things that the ECMPS system is unable to check efficiently • CO2 control chart • Operating status during linearity checks • EPA plans to begin identifying suspect data on a quarterly basis with respect to these two issues starting with 1Q2010 • More checks may be added to the routine checks as warranted

  7. CO2 Control Charts

  8. CO2 Control Chart Feedback • Whenever EPA identifies suspected erroneous data, EPA will send a letter to the DR and monitoring contact to disclose our finding. The letter will provide the following options: • If you concur that air in-leakage into the CEMS (or another malfunction of the monitoring systems) has occurred during the time period(s) in question and that the reported emissions are not accurate, then you should either: • Resubmit the electronic data reports (EDRs) using the standard missing data procedures for SO2, NOx, and CO2; or you may • Submit a petition to EPA under 40 CFR 75.66, requesting an alternative to the standard missing data procedures. • If you believe that the emissions have not been under-reported because, e.g., there is a technical explanation for the unexpected, low CO2 concentrations identified by the EPA audit or that the bias in CO2 was caused by a known malfunction that would not have affected the quality of the SO2 or NOx measurements you may provide that explanation to EPA with supporting documentation.

  9. Passing the Audit andAvoiding the Letter • EPA encourages all facilities with CO2 CEMS data to follow the procedures described in this presentation to identify early any questionable data as an added QA step. • If you see the CO2 drop for more than a few days, investigate to find the cause and take appropriate action. • EPA recommends investigation at the 2 level • In such cases, consider the data validity for other parameters that might also need to be invalidated. • Document all findings.

  10. Field Auditing • EPA has begun to provide updated field audit training to EPA Regional, State, and Local officials • This training includes instruction on how to obtain data from ECMPS to prepare for an inspection; and • Focus’ on issues we know we cannot verify using our current software checks • EPA believes that Field Auditing is an important aspect of a well rounded QA/QC program for ensuring the quality of the monitoring data.

  11. Conclusion • 2009 was a very successful transition year and much of the credit goes to all of you. • EPA is committed to the mission of ensuring that the emissions data used for trading programs are of high quality and that there is consistency in the manner at which measurements are made. • We look forward to your continued cooperation.

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