Using ALL4’s EDR-E to Avoid Surprises with Continuous Monitoring System (CMS) Data in Pennsylvania

Surprises are Fun…Or Are They?

My Dad celebrated his 60^th birthday this past December.  Milestone events are a great reason for celebration, and this milestone birthday caused me to consider a surprise party.  On one hand, surprises are fun, exciting, and thrilling.  Yet, from another vantage point, surprises can be upsetting and unwelcome.  Using the latter, I imagined my dad coming home from walking the family’s Boston Terrier on a cold winter night, entering his house, only to be shocked to find some of his friends and our Pottsville, Pennsylvania family members all staring at him, as he reaches for a needed tissue and removes his winter cap that would expose his “hat hair.”  It’s a not-so-flattering image that I’m sure he would like to avoid.  After this image crossed my mind, I revised my idea of a surprise party to eliminate this potential embarrassment.

Don’t Get Caught Off-Guard

While life is full of surprises, the Pennsylvania Department of Environmental Protection’s (PADEP’s) Facility Summary Report for quarterly CMS reports shouldn’t be one of them.  When CMS data is uploaded into PADEP’s GreenPort website with incomplete or inadequate quality assurance (QA) / quality control (QC), the unknown can be worrisome.  Does submitting data that does not result in penalties (e.g., due to excess emissions or due to low data availability) mean it is accurate data?  Regardless, surprise report penalties can be embarrassing for the company and the personnel responsible for managing and reporting CMS data.  ALL4 has been called upon by facilities that got caught off-guard.  In response to these calls for support, ALL4 has developed an EDR-E to evaluate electronic data reports (EDR) for data collected by CMS.  Check out our website for the EDR-E details.

What is the Value of ALL4’s EDR-E to You?

The EDR-E is a customized tool built for each facility, addressing items such as facility-specific emissions limits and averaging periods, data availability requirements, and periods exempt from monitoring, such as startup and shutdown (as applicable).  Below are three main ways that the EDR-E service and support can be beneficial for a facility:

• Forecasting and Assessing Penalties

At it’s very core, in accordance with PADEP’s compliance assurance policies (CAPs), ALL4’s EDR-E provides the actual penalty amount that could be assessed on your data once it’s submitted to PADEP.  The EDR-E is custom-built for each facility, addressing items such as facility-specific emissions limits and averaging periods, data availability requirements, and periods exempt from monitoring (as applicable, such as periods of startup and shutdown).  It even considers source-specific penalty factors and truncation levels, which can dramatically impact penalties.  ALL4 has helped numerous facilities forecast their CMS penalties in the past so that funds for fee liabilities can be allocated.  Our clients value the “heads-up” this service provides well before PADEP assesses these penalties.

Imagine this: you are an Environmental Manager responsible for CMS data at your facility.  Your operations experienced some 1-hour parts per million (ppm) exceedances that occurred during startups.  While these exceedances seemed innocuous at the time, you also know that they could result in excess emissions penalties.  Management expects to be made fully aware of any penalties prior to submittal.  The uncertainty of both penalties and the fee amount can be distressing for those managing budgets.  ALL4’s EDR-E will evaluate a report, determine if there are report penalties, and provide the actual fee that can be expected.

• Data Review and QA

Prior to EDR submittal, ALL4’s EDR-E is used to review the CMS data, process codes, and monitoring codes to identify data anomalies and potentially problematic periods.  The EDR-E emulates PADEP’s report, which supplements facilities’ QA/QC programs.  ALL4’s CMS team has been providing this service to various industrial clients for years, which has been an effective tool to detect data that requires a closer look.  As an added service, ALL4 can take those next steps and work with the facility to dig into the CMS data in more detail, such as reviewing log books, calibration and testing reports, minute data, startup and shutdown data, and subsequently reconcile the CMS data to ensure that the submitted EDR is accurate and representative of facility operations and emissions during the reporting period.

• Mitigate and Eliminate Future Penalties

When used simultaneously with the data reconciliation effort, the EDR-E can be a useful tool to identify periods where action can be taken by the facility to avoid future penalties.  This includes providing guidance to source operators and technicians on how to flag data in the data acquisition and handling system (DAHS), when to run daily calibrations, and how to mitigate CMS downtime.  Using these tools, ALL4 has worked with facilities and even trained operators to reduce quarterly CMS penalties over time.  ALL4 has helped clients reduce or eliminate their yearly penalties from what began as several thousand dollars.

With ALL4’s help, there won’t be surprises that come your way regarding PADEP-assessed CMS penalties.  You won’t be like my dad walking into a room getting caught off guard on his 60^th birthday.  Eliminating surprises in your CMS data submittals is another way ALL4 can provide value to your ever-increasing laundry list of facility tasks.  To find out more about ALL4’s EDR-E service, visit our website, or contact JP Kleinle at 610.422.1120 and jkleinle@all4inc.com.