Submitting Protocols and Reports Via the Electronic Reporting Tool (ERT)

Successful emissions compliance testing projects include the submittal of a test plan or test protocol for approval prior to testing and the submittal of the final test report, at the conclusion of testing, to the regulatory agency responsible for approving the test. The regulatory agency can be the local, state, or federal government environmental department.

Stack Testing for Air Quality ControlIn the past — and still current in many cases — this submittal has been the delivery of hard copies of the report to the state or federal agency. Now the increasing trendis the submittal of digital test data over the internet, utilizing the Electronic Reporting Tool, or ERT.

The ERT is used to electronically create and submit stationary source sampling test plans to regulatory agencies and, after approval, to calculate and submit the test results as an electronic report to the regulatory agency. It is intended to replace the manual preparation and transcription of test plans and reports currently performed by stack testing contractors for emissions sources, as well as the manual quality assurance evaluations and documentation performed by state agencies.

It is the EPA’s hope that the ERT will improve the content and quality of source emissions test reports, reduce the workload associated with manual transcription of information and data contained in the report, reduce the resources required to store and access the reports, and reduce redundant efforts in using the data for multiple purposes.

It needs to be noted that at this time no state agencies have formally adopted this method of accepting test protocols and test reports, so for state air permit requirements, test plans and test reports are still submitted in hard copy. However, for tests that are determined by Federal requirements, such as the many MACT regulations, it is a technical requirement that test data must be submitted via the ERT. As the federal agencies continue to push towards ERT submittal, there may be a period of time where both digital and hard copy submittal are required, but it is expected that the ERT will eventually be the required method of protocol and test report.  A full list of the various EPA regulations that require ERT submittal is provided below.

It is highly recommended that your facility designates a person or contracted testing company to familiarize themselves with the ERT format, structure, and requirements, particularly if your facility is or will be affected by the Federal regulations. ESS personnel are trained to prepare protocols and test plans in the format required for submittal via the  ERT, as well as any required hard copies, in order to meet all regulations for compliance demonstration.

Currently, the EPA requires ERT reporting for compliance tests falling under the following rules:

Promulgated Regulations with Electronic Data Reporting Requirements*

Source Category Code of Federal Regulations Reference
40 CFR Part 60 40 CFR Part 63
Chromium Electroplating (Hard and Decorative) and Chromium Anodizing Tanks   Subpart N
Coal Preparation and Processing Plants Subpart Y
Commercial Industrial Solid Waste Incinerators Subpart CCCC and DDDD
Electric Utility Steam Generating Units Subpart Da Subpart UUUUU
Flexible Polyurethane Foam Production Subpart III
Gold Mines Subpart EEEEEEE
Industrial, Commercial, and Institutional Boilers Area Source Subpart JJJJJJ
Industrial, Commercial, and Institutional Boilers Major Source Subpart DDDDD
Industrial-Commercial-Institutional Steam Generating Units Subpart Db Subpart UUUUU
Industrial-Commercial-Institutional Steam Generating Units, Small Subpart Dc Subpart UUUUU
Marine Tank Vessel Loading Operations Subpart Y
Nitric Acid Plants Subpart Ga
Oil and Natural Gas Production Subpart OOOO Subpart HH and HHH
Pesticide and Active Ingredient Production Subpart MMM
Pharmaceuticals Production Subpart GGG
Polyether Polyols Production Subpart PPP
Polymers and Resins Group I Subpart U
Polymers and Resins Group IV Subpart JJJ
Polyvinyl Chloride and Copolymers Production Subpart HHHHHHH
Portland Cement Subpart F Subpart LLL
Printing and Publishing Industry Subpart KK
Pulp and Paper Industry Subpart S
RICE Subpart IIII and JJJJ Subpart ZZZZ
Secondary Lead Smelting Subpart X
Sewage Sludge Incinerators Subpart LLLL and MMMM
Steel Pickling– HCl Process Facilities and Hydrochloric Acid Regeneration Plants Subpart CCC
*EPA requirements subject to change.  See http://www.epa.gov/ttnchie1/ert/ert_rules.html for the most up-to-date list

 

Mark Looney About Mark Looney

Speak Your Mind

*


+ 6 = 13