Managing CEM compliance data to protect the company and its designated representative
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.
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- Conference: Air & Waste Management Association (AWMA) conference on acid rain & electric utilits: permits, allowances, monitoring & meteorology, Tempe, AZ (United States), 23-25 Jan 1995; Other Information: PBD: 1995; Related Information: Is Part Of Acid rain and electric utilities: Permits, allowances, monitoring and meteorology; Dayal, P. [ed.] [Tucson Electric Power Co., AZ (United States)]; PB: 940 p.
- Air and Waste Management Association, Pittsburgh, PA (United States)
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- United States
- 20 FOSSIL-FUELED POWER PLANTS; 29 ENERGY PLANNING AND POLICY; FOSSIL-FUEL POWER PLANTS; AIR POLLUTION ABATEMENT; REPORTING REQUIREMENTS; CLEAN AIR ACTS; COMPLIANCE; AIR POLLUTION MONITORS; CERTIFICATION; AIR POLLUTION MONITORING; WASTE MANAGEMENT; LIABILITIES