2007 APR Table of Contents

ERMS Home ERMS Reports Allocation Reports Annual Performance Review News & Items of Interest ERMS Overview

FAQ ERMS Contacts Average ATU Prices Account Officer Training ERMS Forms Online Transaction Requests

Emissions Reduction Market System

Annual Performance Review Report - 2007

6  Performance Accountability

6.1  Seasonal Emission Reports

Illinois EPA identified 223 sources that were required to submit seasonal emission reports (SERs) for the ERMS program.  These reports are based on federally enforceable permit conditions for recordkeeping, reporting, monitoring and calculation methodology.  Of these, 160 SERs were expected from permitted participating sources.  Follow-up calls were made to 27 facilities that did not submit their SERs by the deadline.

Illinois EPA deemed 7.6 percent of the SERs received from participating sources as unacceptable for a variety of errors.  The reasons for determining reports to be unacceptable continue to include items from previous years:

• Mathematical or rounding errors
• Failure to include all significant emission units covered by the permit
• Failure to follow proper permit procedures for calculating emissions
• Failure to report HAPs

Sources are required to report VOM HAP emissions on their SERs if they are subject to MACT, report to TRI or are major for HAPs.  Some sources continued to report pollutants that were not HAPs, or, that were HAPs but were not VOM.  Information pertaining to these pollutants was not considered in this evaluation.

6.2  Alternative Compliance Market Account (ACMA)

The purpose of ACMA is to serve as a secondary source of ATUs for participants.  Unlike ATUs allocated to sources, those in ACMA have an indefinite life as long as they remain in ACMA.  Once they are bought, they must be used to account for either the preceding or subsequent seasonal allotment period.

ACMA may receive ATUs in several ways.  ACMA is given ATUs in an amount equal to one percent of each year’s allotment to the participating sources.  Sources that choose to become exempt from ERMS by taking an 18 percent reduction have six percent of that reduction allotted to ACMA.  ATUs are also deposited in ACMA as a result of participating source shutdowns and ERG shudowns.  Sources may donate ATUs to ACMA.

A total of 3854 ATUs were deposited into ACMA, as detailed in Table 6-1 below.  Of these, a total of 38 ATUs were donated to ACMA by a source as part of the settlement of a compliance issue.

Table 6-1:  ACMA Account Balance

Sources may buy ATUs from ACMA during the reconciliation period or, if necessary, in excursion compensation.  No sources bought ATUs from ACMA during the reconciliation period.  The 212 ATUs purchased from ACMA were for excursion compensation for the 2007 season.  Recent ACMA purchases by year can be seen in table 6-2.

Table 6-2:  ACMA Purchases

6.3  Excursion Compensation

Three sources went into excursion compensation for the 2007 season.  For this source, lack of action to purchase ATUs seemed to be the apparent cause of going into excursion rather than being unable to obtain ATUs on the market.  One of the sources in excursion was in excursion for their third year in a row and was thus required to provide 1.5 times the ATUs of their excursion.

Sources in excursion compensation have their ATUs withdrawn from ACMA unless they instruct Illinois EPA to take them from the next year’s allotment.  Two sources bought from ACMA while the third will be taking their excursion from their 2008 allotment

6.4  Source Inspections

In order to make sure appropriate ERMS reporting and compliance is maintained, Illinois EPA has its Field Operations Section focus on ERMS sources during the year.  ERMS Master File inspections where performed at 13 participating sources.  Master File inspections add a further level of review of the source’s ERMS Compliance Master File to make sure all recordkeeping, HAP information and other ERMS related items are being properly maintained.  No Violation Notices were issued to as a result of the ERMS inspections.

6.5  Findings

• The same errors continue to be made on the SERs each year.  These errors are satisfactorily resolved once the company is notified.
• No requests for regular access to ACMA were received during the reconciliation period.
• The reconciliation and compensation processes performed as designed and operated in a timely and effective manner.
• Inspections by the Illinois EPA found sources to be complying with the ERMS requirements.