ALL4 proudly announces the EDR Evaluator (EDR-E) for the evaluation of electronic data reports (EDR) for data collected by continuous monitoring systems (CMS) in accordance with Revision 8 of Pennsylvania Department of Environmental Protection’s (PADEP) Continuous Source Monitoring Manual (CSMM). Our EDR-E allows ALL4 to quickly evaluate quarterly EDRs for penalties associated with excess emissions and data availability by automating PADEP’s Compliance Assurance Policies (CAPs) within the tool. ALL4’s EDR-E also provides a valuable quality assurance (QA) review prior to the CEMDPS*Online submittal via PADEP’s GreenPort website.
ALL4 has been providing CEMS penalty estimation and QA support to our existing Pennsylvania clients for years; however, our new EDR-E provides a cost-effective solution that allows ALL4 to provide this same service to ALL Pennsylvania facilities before the reporting deadline each quarter.
What is the EDR-E used for?
The intended use of the EDR-E is to ensure that the CEMS data in the EDR is correct (See certification items No. 1 and 2 on page 51 of PADEP CSMM). The tool supplements a facility’s existing QA program while providing documentation of any excess emissions and data availability issues that are included within the EDR.
A common example of EDR-E QA catch includes excess emission penalties associated with data reported during a quality assurance activity (e.g., linearity check) or continuous opacity monitor (COM) maintenance. These “false” excess emissions may sometimes only result in a few hundred dollars in fines. However, the actual cost can be thousands of dollars when one considers the time and effort associated with revising and resubmitting reports, corresponding with PADEP, and even delinquency penalties. The goal of the EDR-E is to get the CEMS data in the EDR correct the first time while satisfying the CSMM certification requirements referenced above.
Let’s be crystal clear here that the EDR-E is a QA tool and NOT intended to identify data penalties so they can be resolved prior to EDR submittal. The Tool helps ensure that the penalties found in an EDR are based on accurate and complete data.
How does it work?
Prior to a facility submitting an EDR to the CEMDPS*Online via PADEP’s GreenPort website, ALL4 will utilize our EDR-E to quickly evaluate the actual EDR submission files and identify and calculate any penalties associated with the data contained in the EDR. The report generated by our EDR-E is formatted to emulate PADEP’s quarterly Continuous Source Monitoring Facility Summary Report. Facilities can provide their draft EDR submission files to ALL4 via email or upload them to our designated website.
An initial onetime setup and verification is required for ALL4 to program our EDR-E with site-specific information contained in CEMDPS*Online (e.g., applicable emissions standards). The site-specific information needed is easily obtained from the quick links section of a facility’s CEMDPS*Online account.
What are some benefits?
Improving the lines of communication between the report preparer, the certifying official, and upper management. I haven’t met an Environmental Manager yet that wouldn’t want to know the exact dollar amount, if any, of penalties prior to submitting the EDR.
Timely and efficient verification that PADEP’s summary reports align with what you submitted. Because our EDR-E is formatted to emulate PADEP’s quarterly Continuous Source Monitoring Facility Summary Report, it is used to quickly and accurately review correspondence provided to the facility by PADEP.
Predicting potential data availability penalties during the reporting quarter. Partial EDRs can be processed by the EDR-E to evaluate penalties associated with the data availability status at any time. This information is often used while making compliance and operational decisions associated with atypical CEMS malfunctions and significant downtime events.
Can I add custom data review aspects to the EDR-E?
Absolutely. The EDR-E can be used to review data as defined by you, with some limitations.
One example of report customization is a comparison of Process Codes and Monitoring Codes across all reported parameters (e.g., NOX, CO, Opacity, etc.). This customized report identifies any hour that the Process Codes and/or Monitoring Codes indicate conflicting process status for a similar emissions unit (e.g., NOX MC13 “process down” while CO MC00 “process up”)
How can I get more information, how much does it cost, how do I enroll?
If you have additional questions or you would like to have ALL4 get started on development of your site-specific EDR-E, complete the form to request a call or ask a question. For more information, please contact JP Kleinle, ALL4’s CMS Focus Area leader, at 610-422-1120 or firstname.lastname@example.org.
This information is also available as a podcast episode on ALL4’s Air Quality Insider.