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Enhancing NOx SIP Call Compliance through Electronic Audits: Workshop Overview and Insights

This workshop provided an update on the Electronic Audit Program for the NOx SIP Call, detailing how the Clean Air Markets Division conducts electronic audits of over 1000 reporting units. The focus was on improving data accuracy and credibility in cap-and-trade programs, addressing common issues, and supporting compliance. Key processes discussed included self-assessment tools, error correction via Electronic Data Reports, and targeted field audits. The session highlighted the importance of maintaining high-quality emissions data through rigorous Quality Assurance/Quality Control measures.

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Enhancing NOx SIP Call Compliance through Electronic Audits: Workshop Overview and Insights

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  1. Clean Air Markets Division Electronic Audit Update NOx SIP Call Workshop June 10, 2004 Theresa Alexander, USEPA

  2. Background • Recap of E-Audit Program • CAMD received hourly data from over 1000 NOx SIP Call reporters • Perform electronic audits on all CEMS, LME and peaking units

  3. Why an Audit Program? • To enhance our cap-and-trade programs through data accuracy and credibility • Designed to identify problems early in the process so they can be corrected • Assists sources in complying with our programs • Identify areas that require improvement and training needs

  4. Basic Elements • Check electronic submissions to assure the accuracy of the data • Perform targeted field audits • Provide tools to sources for self assessment & problem prevention • Develop tools to identify benchmarks and to more effectively focus field audit resources

  5. QA/QC Begins with the Source • Conducts QA/QC requirements • Generates the Electronic Data Report (EDR) • Performs self-checks by running the EDR through the Monitoring Data Checking (MDC) software and correcting the errors • Submits the EDR to the Emissions Tracking System (ETS)

  6. CAMD Process • ETS performs a series of formatting & calculation checks • ETS sends automatic feedback • The E-Audit Process begins once ETS accepts the EDR • E-Audits are performed and feedback is sent

  7. E-Audit Overview • EDRs are audited using the MDC software • MDC Quarterly Review System(MDC-QR) • MDC Hourly • Ad-hoc Evaluations • Targeted Field Audits

  8. MDC-QR • Equivalent to MDC (Review menu function) • Performs import evaluation, identifies data inconsistencies, looks for basic file structure errors

  9. MDC-QR • Evaluates the monitoring plan in that quarter’s EDR (e.g., monitoring methodologies, emissions formulas, systems used) • Evaluates the reported QA test in that quarter’s EDR (e.g., check calculations, determine past/failure status, reference methods, calibration gases)

  10. MDC-CAMD • Data from MDC-QR is loaded into MDC-CAMD • MDC-CAMD is a separate database that contains a historical record of all the monitoring plans and QA tests • MDC-CAMD also includes monitoring plans and certification/recertification test data submitted to the EPA regional mail boxes

  11. MDC-CAMD • From this database it is possible to perform hourly data checks across quarterly boundaries • Bias Adjustment Factor applications • Out-of-control systems • Equivalent to running MDC-Hourly, provided the unit’s historical MDC database is populated

  12. BAF Checks • MDC-CAMD allows for EPA to audit for the proper application of the BAFs • Each hours unadjusted reported value is multiplied by the accepted BAF from a qualified RATA and compared to the reported adjusted value

  13. Out-of-Control System Checks • The OOC checks are used to identify hours that are reported as quality assured, but do not have the QA records to match • The OOC system checks for: • Missing or Expired QA Tests • Incomplete QA tests • Failed QA tests

  14. MDC Feedback • Feedback from the MDC audits are combined and sent to the sources • Critical errors must be corrected and the EDR resubmitted by the deadline • CAMD Engineers work with the sources to resolve the errors (e.g., substitute data)

  15. Resubmission Deadlines • Sources have until: • 1Q04 - July 1, 2004 • 2Q04 - October 1, 2004 • 3Q04 - December 30, 2004 • 4Q04 - March 15, 2005

  16. Ad-hoc Audits • EPA also performs Ad-hoc audits of the data to evaluate • MPC, Span, and Range • Flow-to-Load Ratio • Missing Data Substitution • Other QA parameters, as applicable

  17. Ad-hoc Audits • These audits are not currently automated by any of the MDC products and are selected on an as needed basis • Ad-hoc feedback may lead to an email or phone call to the plant contact or Authorized Account Representative • Ad-hoc audits can also result in the use of substitute data

  18. Field Audits • Provides for another independent means to QA emissions data • These audits are targeted based on statistical analyses of emissions data • Engineers review all the data from the targeted plant and conduct comprehensive audits • These audits also involve regional and state personnel

  19. Typical Errors • Failure to correctly apply BAFs • RATAs conducted at wrong loads • RATAs performed after due date • Missed linearity checks

  20. Typical Errors • Failure to respond to flow-to-load variations • Failure to make annual span and range adjustments • Incorrect calibration gases

  21. Highlights • Issues with different databases &/or use of different MDC versions • Mail box submittals for monitoring plans and certifications and recertifications • Different historical databases

  22. 2003 Audit Results • NOx Sip Call files audited: ~ 450 • Critical errors: ~ 200 • Excess Emissions: 7 units

  23. Recent Changes • Combined MDC-QR & Hourly feedback • MDC updated to calculate test exemptions and extensions • More effective internal tracking tool of audit results • Feedback during the submission period • More effective way to target sources for field audits

  24. Future Focus • Address issues with new reporters • Further scrutiny of annual adjustments • Development of benchmark analyses • Statistical analysis to identify outliers • Gearing up for re-engineering

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