If you have elected to comply with the Boiler MACT regulation through performance testing, the deadline for the broad majority of existing boilers to complete the performance testing was July 29th, 2016. For the sake of this blog entry, we’ll assume you have done this. (If not, you should contact us immediately and we can get you up to speed!)
Now that you have completed the testing, you await the results from the testing company. From the Boiler MACT regulation, as detailed in 40 CFR §63.7550, it seems like all of the steps you need to complete the performance test report are laid out for you. From our experience, it is not so simple. To make the process as efficient as possible and to ensure you submit all necessary information within the 60 day deadline, we recommend you do some research prior to assembling the performance test report.
In most cases, the EPA delegates the authority of this rule to the applicable state agency. Check with that delegated authority to ensure that electronic submission, via the Electronic Reporting Tool (ERT) to the Compliance and Emissions Data Reporting Interface (CEDRI) as outlined in 40 CFR §63.7550, of all necessary information is acceptable to them. We have found that not all state agencies use the submission systems setup by the EPA, specifically the CEDRI database. In those cases you will have to submit data via the ERT to satisfy the EPA regulation and also submit a hardcopy of reports to the state agency to satisfy their submittal requirements.
Assembling and submitting the hardcopy of the test report to the state agency, if they do not use the ERT, should take precedent over the submission to the EPA. This is because they are the ones actually reviewing the report and confirming compliance. In this report you will need to include all information as outlined in your site specific test plan and 40 CFR §63.7.
The ERT submission will take a substantial amount of time and can be very frustrating to complete. We have found the supplied instruction manual for ERT submission to be incomplete and often not go into the required detail needed to successfully assemble the report. At CTI, we are able to assemble and submit test reports via ERT efficiently and accurately. If you have any questions about the process or would like us to submit your ERT report, we are here to help!