What does the Technical Management Section (TMS) look for in reporting?
The TMS looks for four basic elements in reporting: timeliness, completeness, accuracy, and compliance status.
Timeliness - Most periodic reports must be postmarked no later than 30 days after the end of the reporting period. TVACC’s must be postmarked no later than 45 days after the end of the reporting period.
Completeness – The facility must submit all of the data required by the permit condition, in the correct format.
Accuracy – Information must be correct and reasonable. Checks are made for proper units, rolling sum vs. rolling average, correct calculations, and that the information covers the proper time period.
Compliance Status – Reported information must be in compliance with the permitted emission limits, applicable regulations, and standards.
It is important for a facility to read their permit carefully and understand the reporting requirements. In addition to the listed reporting requirements in the permit, the TMS needs to know how all numbers are derived. For example, in VOC/HAP reports, facilities should include an algorithm with sample calculations in the first report. If the facility changes the method of calculating emissions, the algorithm should be resubmitted. In addition, most VOC/HAP reports require a 12-month rolling sum (pdf), not a rolling average.
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