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Ah, February. The reporting window for the fourth quarter is closed, and you managed to get all the other permit-required reports off your desk and on their way. After you take some time to exhale and clear your brain, take a moment to reflect on the past year. Think about what went well, what you learned, and identify areas for improvement. Based on our customers’ feedback, we put together a list of lessons learned last year. 

Lesson 1: Lock Down Your Database
Take a few minutes and lock down the database for your monitoring systems each quarter (remember that StackVision has a wizard that guides you through this process: Tools – Data Locking Wizard). It typically takes only 5 minutes to lock down the entire quarter, including all data sets. This practice prevents the accidental re-processing of previously submitted or accepted data.

Lesson 2: Review and Process Data (including EDR files) Regularly
Don’t neglect to review and process your data regularly, including generating and evaluating EDR files. It is easier to immediately address errors than wait until the end of the quarter when other pressing obligations occur.
  • Look at your data reports weekly or with more frequency. 
  • Flag downtime, exceedance, and excess emission events with the proper reason and action codes. 
  • At least once a month, generate a QA and emission EDR file and run them through ECMPS. 

Lesson 3: Look Ahead to Your Next Rounds of Relative Accuracy Test Audits (RATAs) and Stack Testing 
These significant events require a lot of coordination and preparation.  
  • RATAs for Part 75 usually occur two or four calendar quarters after the last successful test. RATAs for Part 60 are due within the next four calendar quarters after the last successful test. The RATA Editor in StackVision is a useful tool for tracking your RATAs: it will tell you how many quarters can pass before the next RATA is required.
  • Stack testing requirements can be complicated and confusing. In general, the regulation, the permit, or the letter from the state agency accepting the last set of results will list the requirements for when the test can occur. Some regulations give you a window (i.e., you must wait X months before, or you must complete by Y months or days for the next round of tests). 
Lesson 4: Check Fuel Flow Meters Calibrations and Accuracy Test Deadlines
There are different ways to perform flow meter checks. Getting these checks completed is expensive and requires planning.
  • You can perform the test using a second meter in line with your existing meter and compare the amount of fuel flow recorded by each. Another type of test requires the meter’s removal to send to an approved vendor for an accuracy test (while a replacement meter takes its place).
  • Check your Quality Assurance Quality Control (QAQC) Plan. In some situations, you may be able to delay QA checks to the next quarter.
Conclusion 
While these recommendations require time on the front end, you will save yourself from future headaches by investing in reviewing past events and adjusting plans accordingly. As always, the ESC Spectrum team is standing by to put your lessons learned into practice. Our professional CEMS services performs RATA and stack testing, provides expert reporting services (including weekly and monthly data reviews and EDR & permit compliance reporting) as well as a host of solutions that help you meet your air emissions compliance challenges.

For questions, suggestions, or for a general chat, do not hesitate to contact me.

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Jon Konings

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