Did You Know?
The Emission Collection and Monitoring Plan System (ECMPS) 2.0 web-based reporting platform is scheduled for mandatory reporting by Acid Rain Program, Cross-State Air Pollution Rule (CASPR), and Mercury Air Toxics Standards (MATS) Rule (Subpart UUUUU, 40 CFR Part 63) affected sources in 2024. More specifically, the Q1 2024 emissions and quality assurance (QA) files must be submitted via ECMPS 2.0 in JSON format by April 30, 2024, reporting deadline.
EPA has created a website dedicated to the ECMPS re-engineering effort at https://www.epa.gov/airmarkets/ecmps-re-engineering-effort. This new website has a wealth of information (instructions, beta testing, timelines, CDX access, etc.), and VIM Technologies, Inc. (VIM) encourages all ECMPS users to become familiar with the changes. There will be no dual reporting options available (XML and JSON). It’ll be a firm transition beginning in Q1 2024.
ECMPS 2.0 Free Webinar
VIM hosted a free ECMPS 2.0 webinar on April 12, 2023. Hear the latest on the re-engineering effort as we outline all the key milestones and share lessons learned about our experience thus far. You can request this previously recorded webinar HERE.
More about ECMPS 2.0
ECMPS 2.0 utilizes the Central Data Exchange (CDX) for login services. To access the ECMPS 2.0 beta environment, users are required to create a CDX test account. This account is separate from other existing (i.e., official) CDX accounts used for official electronic submittals to EPA. Once the web-based version of ECMPS 2.0 goes live, all logins will be managed via CDX in lieu of the current CAMD Business System (CBS).
In late December 2022, EPA published draft versions of the ECMPS 2.0 monitoring plan (MP), quality assurance (QA), and emissions (EM) reporting instructions that include MATS-related updates. EPA intends to finalize the reporting instructions by Spring 2024. VIM recommends reviewing these instructions and providing comments to EPA.
VIM cautions operators of low mass emissions (LME) units using the existing ECMPS Client Tool to generate quarterly electronic data reports (EDRs). In the Frequent Question section posted on the ECMPS re-engineering website, EPA states that “the current ECMPS 2.0 development timeline does not include plans for LME functionality within the application due to Central Data Exchange (CDX) and Cross-Media Electronic Reporting Rule (CROMERR) limitations. EPA is investigating the possibility of providing this functionality outside the application; however, EPA encourages affected sources to explore other options during this time.”
On the MATS front, affected sources will need to update the existing Monitoring Plan to include the new MATS data elements, especially for sources equipped with particulate matter (PM) monitors or PM continuous parameter monitoring systems (CPMS). It should also be noted that there are MATS-related reporting requirements that are outside of the new JSON format. Consistent with Section 1, Appendix E to Subpart UUUUU, all compliance tests, relative accuracy test audits (RATAs), PM monitor initial correlation tests, relative response audits (RRAs), and relative correlation audits (RCAs) that are completed on or after January 1, 2024, must include the applicable data elements in Sections 17 through 30. These data elements must be reported in an XML format specified by the Administrator. This requirement seems to suggest the use of EPA’s Electronic Reporting Tool (ERT) to generate these detailed XML files.
Additionally, the information specified in Section 31 of Appendix E must be reported in one or more PDF files to support each XML file. Examples of the required PDF information are laboratory reports, raw instrumental data, reference method field data sheets, and calibration gas certificates. VIM recommends that MATS-affected sources contact their stack testing companies to gauge if these companies intend to provide the required XML files as test program deliverables.
How VIM Supports Our Partners
VIM continues to stay abreast of the ECMPS 2.0 developments and releases to ensure that CEMLink 6 is ready to comply with the reporting requirements in 2024. VIM has reviewed the draft ECMPS reporting instructions and has submitted comments/recommendations to EPA for review. During the ECMPS 2.0 testing period, CEMLink 6 will be configured to generate QA and EM files in both XML and JSON format. It will allow the user to utilize the existing ECMPS Client Tool and the new web-based ECMPS 2.0 Tool to evaluate each file separately as a quality control measure.
VIM’s COMPAS Division also stands ready to assist with any required Monitoring Plan updates. In addition to the electronic Monitoring Plan revisions, updates may also be required to the hardcopy Monitoring Plan. Appendix C to the MATS Rule introduced hardcopy Monitoring Plan required for PM CEMS. Experience shows that the hardcopy Monitoring Plan requirements specified in 40 CFR Part 75 and the MATS Rule are often overlooked.
For more information concerning CEMLink 6 and/or VIM’s COMPAS environmental support services, please get in touch with our sales team at Sales@vimtechnologies.com.
