In accordance with §75.63(a)(1), sources that will be certifying mercury (Hg) CEMS equipment in 2008 must submit the certification data no more than 45 days after the tests are completed. Sources must also provide electronic monitoring plan information at least 21 days (proposed) prior to starting the certification tests. Since there is no way to report Hg data using the existing EDR format, which EPA has expressed that it will not revise for Hg, the predicament could potentially force many sources to use the new XML format prior to the anticipated date of 2009 when the Agency has stated that XML will be required for all sources. A similar situation also exists for newly affected SO2 sources under CAIR, which cannot be completely addressed by the existing EDR format. Complicating matters further, CAMD has stated that sources cannot report using both formats during the 2008 transition. If a source has to report an Hg monitoring plan and certification data it would, presumably, also have to report all its regular emissions data using the new format too. Furthermore, while 2008 has been slated as a transition year where sources could opt into XML reporting, EPA is somewhat behind its initial schedule so a production version of CAMD’s ECMPS client tool (which will be required to evaluate XML formatted data and facilitate submission of that data to EPA's host database) will not be available for some potential certifications in early 2008.
In recognition of this situation, EPA has indicated that it will accept (and grant) petitions to extend the deadline and give sources up to the 90 calendar days following the official release of the ECMPS client tool software to submit their monitoring plan and certification data. The extension would apply to both the electronic records submitted to CAMD as well as the hardcopy portions of the monitoring plan that are submitted to the applicable state and region. Although CAMD first indicated an email request would be sufficient, it has since reversed that decision. To ask for an extension, sources should send a written request in the form of a petition under §75.66. It is recommended that the request should be submitted before certification testing is completed. For more information, including a sample petition, click here.
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