Managing CEM compliance data to protect the company and its designated representative

Conference · Sun Dec 31 04:00:00 EST 1995

OSTI ID:271840

Means, C S; Helderlein, D ^[1]

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1. Associated Electric Cooperative, Springfield, MO (United States)

Titles IV and V of the 1990 Clean Air Act Amendments, and related regulations, set forth very stringent emissions monitoring and reporting requirements. Not only are there detailed quality assurance provisions, but the accuracy of reports must be certified by the company`s designated representative (Title IV) or responsible corporate official (Title V). This paper briefly reviews the DAHS change-out experience, then describes the company`s efforts to minimize both corporate and personal liability related to CEM data reporting. It reviews the quality assurance program to minimize corporate liability, including required elements (i.e., calibration error, linearity and RATA requirements), the internal operations oversight, auditing and data checking procedures, and EPA`s ETS audit software. The paper then describes the program to document the overall operation of the CEM system for the designated representative. It identifies the pertinent information the authors believe must be provided, and the actions the DR must take to demonstrate prudent inquiry for both the DR and the company. This includes the documentation, procedures used by the DR to personally inquire about data quality and caveats in the certification transmittal letter regarding errors and anomalies in reported data.

• OSTI ID: 271840
• Report Number(s): CONF-950196--
• Country of Publication: United States
• Language: English

Related Subjects

20 FOSSIL-FUELED POWER PLANTS
29 ENERGY PLANNING, POLICY, AND ECONOMY
AIR POLLUTION ABATEMENT
AIR POLLUTION MONITORING
AIR POLLUTION MONITORS
CERTIFICATION
CLEAN AIR ACTS
COMPLIANCE
FOSSIL-FUEL POWER PLANTS
LIABILITIES
REPORTING REQUIREMENTS
WASTE MANAGEMENT