PC MACT and Electronic Reporting: What You Need to Know
Posted: June 20th, 2016Authors: Kayla T.
I introduced the basics of electronic reporting (E-Reporting) to you in the blog “ERT and CEDRI: What the Heck Is It and How Does It Impact You?” which included some additions to the never-ending list of environmental acronyms like Electronic Reporting Tool (ERT), Compliance and Emissions Data Reporting Interface (CEDRI), and Central Data Exchange (CDX), as well as a general overview of E-Reporting, who is subject to it, and what it actually entails. But with an approaching reporting deadline for 40 CFR Part 63, Subpart LLL, or “PC MACT,” I think it’s time to get a little specific.
Okay – so you’re a cement facility subject to PC MACT, what do you need to do? There are a few E-Reporting requirements that apply.
1. Semiannual Summary Reports [40 CFR §63.1354(b)(9)]
Semiannual reports must be prepared and submitted via CEDRI. The summary report must contain the information specified in 40 CFR §§63.10(e)(3)(vi) and 63.1354(b)(9). Examples of this information includes, but is not limited to:
- Brief description of the process unit
- Monitoring equipment manufacturer(s) and model number(s)
- Date of the latest continuous monitoring system (CMS) certification or audit
- Operating time of the affected source
- Exceedances of maximum control device inlet gas temperature limits
- 30-day and/or 3-hour rolling average values for applicable continuous parameter monitoring systems (CPMS), continuous emissions monitoring systems (CEMS), and/or CMS.
The data entry is relatively straight-forward. Some data (e.g., 30-day rolling average data) may even be uploaded using CEDRI Excel templates. However, templates are not yet available for all data (e.g., 3-hour rolling average data) which can make submission a little trickier. Semiannual reports are due 30 days following the compliance period (i.e., January 30th and July 30th of each year).
2. Results of Performance Tests [40 CFR §63.1349(d)(2)]
Results of performance tests conducted to demonstrate compliance with any PC MACT standard must be submitted electronically. The reports must first be created using ERT and then uploaded and submitted via CEDRI. My one word of caution for these reports – the data entry side of things can be extensive, so plan for the time needed. Data entry includes more than just “the basics.” You don’t just enter in the test results. Examples of information includes:
- Sampling location information (e.g., stack characteristics, upstream/downstream distance from disturbances)
- Control device parameters monitored
- Calibration gas concentrations
- Fuel sampling lab data
- Pitot coefficients
- Deviations from/descriptions of sampling methods
Again, plan ahead because this can become a larger task than anticipated. Results must be submitted within 60 days after the date of completing each performance tests.
3. Results of Relative Accuracy Test Audit (RATA) Data
[40 CFR §63.1349(d)(2)]
Results of RATAs conducted to demonstrate compliance with any PC MACT standard must be submitted electronically. The reports must first be created using ERT and then uploaded and submitted via CEDRI. Just like for the performance tests, I will caution you to plan for more data entry than probably expected. Results must be submitted within 60 days after the date of completing each RATA.
If you have any questions about the specific requirements or how to complete these reports using ERT or CEDRI, please contact me at email@example.com or (610) 933-5246 x143. I’d be happy to help. Or check out our ERT/CEDRI Focus Area page for additional information.