MEMORANDUM

TO: Docket EPA-HQ-OAR-2009-0174

FROM: Gerri G. Garwood, P.E., EPA/OAR/OAQPS/SPPD

DATE: May 1, 2015

SUBJECT: Summary of Meeting with ACC Representatives on April 22, 2015

On April 22, 2015 at 12:30 p.m., the EPA held a meeting with members of the American 

Chemistry Council (ACC). A list of attendees is included at Attachment A to this memo. The 

proposed agenda is included as Attachment B to this memo. The first hour of the meeting 

covered topics related to electronic reporting and emissions factors. During this portion of the 

meeting, the proposed Electronic Reporting and Recordkeeping Requirements for NSPS 

rulemaking was discussed. Specifically:

• The EPA clarified the types of reports that are proposed to be collected 

electronically and stated that each subpart varies as to what is required.

• The EPA clarified that the Compliance and Emissions Data Reporting Interface 

(CEDRI) is our portal on the Central Data Exchange (CDX) for collecting reports 

electronically.

• The EPA clarified that in general, Notification of Compliance Status (NOCS) 

reports and Electronic Reporting Tool (ERT) files are uploads while other reports 

require filling out a form in CEDRI.

• The EPA clarified that the system will be designed with the ability to import data 

from spreadsheets, as well as extensible markup language (XML) data upload.

• ACC members questioned when the CEDRI forms would be available and if there 

would be an opportunity for beta testing. The EPA stated that it plans to have all 

forms available by the time the rule is promulgated. In development of past 

forms, beta testing was used, and the EPA envisions such opportunities going 

forward.
• The EPA clarified that whatever facilities are required to report now is still what 

will be required for reporting – no more, no less. Only the form of reporting has 

changed, not the data elements.

• The ACC members mentioned that when the Greenhouse Gas Program developed 

its electronic reporting, it developed sandboxes for users to test the program. The 

ACC members stressed that testing needs to be at least a couple of months long.

• The EPA mentioned the possibility of development of a web-based ERT, as 

proposed in the preamble of the rule.

• The EPA clarified that the ERT performs standard calculations for users.

• The EPA clarified that the stack test data goes to WebFIRE for emissions factor 

development. The EPA further clarified that while WebFIRE is being automated 

to perform the emissions factor calculations, there will still be a public review 

process for any new emissions factors.

• The EPA asked attendees to please submit comments formally.

At the end of the meeting, the newly finalized emissions factors for refineries, adding Method 18 

to the ERT, and the Next Gen Toolkit were discussed. Discussion on this topic ended, and the 

meeting then moved to the next agenda item.
Appendix A

List of Attendees
The following people were present for the meeting in Research Triangle Park:

EPA/OAR/OAQPS

Michael Ciolek 

Gerri Garwood

Barrett Parker

Ketan Patel

Bob Schell

ACC

Lorraine Gershman

Ashland

Patty Hemmelgarn

Bayer CropScience

Scott Munk

Chemours

Rick Vickery

Dupont

Bruce Davis

Dow

Jarod Davis

Russell Wozniak

Eastman

Steve Gossett

ExxonMobil 

Derek Reese

Gindi Vincent

LyondellBasell

Ro Sharma

Steve Smith

Shell

Shari Keller

The following people participated by phone:

EPA/OAR/OAQPS

Steffan Johnson

Oxychem

Fred Fedri

Merck

Anu Kunapuli

CPChem

Carrie Phillips

Evonik

Teresa Reksel
Section B

Proposed Agenda
ACC – EPA Meeting

April 22 and 23, 2015

Conference Room – C-300A

Conference Call #1-888-240-4148, PIN 980746 

Day 1

11:00 am Arrive at EPA security desk, eat lunch in EPA cafeteria

12:30 – 1:30 pm Topic: Monitoring, Reporting and Emissions Factors (SPPD schedule)

• E-Enterprise

• Emission factors 

• Consent decree for refineries

• Method 18 and E-Reporting

• OECA Monitoring efforts

EPA invitees: Barrett Parker, Bob Schell, Mike Ciolek, Colin Boswell, Steve Fruh and 

Foston Curtis

cc: Fred Thompson, Marguerite McLamb, Kevin Culligan

1:30 - 3 pm Topic: NAAQS Standards and Implementation (AQPD schedule)

• 2015 Ozone NAAQS

• 2008 Ozone implementation

• 2013 PM NAAQS implementation

• 2010 NOx, SOx standards – implementation issues, guidance, reconsideration 

petitions

• CSAPR 

EPA invited: AQPD: Anna Wood, Michael Ling, Scott Mathias

 AQAD: Chet Wayland, James Hemby

 HEID: Erika Sasser, Kimber Scavo

3 – 4 pm Topic: Title V/Permitting (AQPD schedule)

• Permitting status/backlog

• Improvements?

• Title V Task Force

EPA invited: AQPD: Anna Wood, Juan Santiago, Vera Kornylak, Raj Rao

 AQAD: Chet Wayland, Tyler Fox 

Cc: James Hemby

Day 2

8:30 am Arrive at security desk

9 am – 10:30 pm Topic: RTR/NSPS/NESHAP (SPPD schedule)

• 3Ps RTR final rule

• AMF/PC/APR final rule

• Ethylene 114 requests
• PVC MACT reconsideration

• Timeline for next rulemakings?

• SSM SIP call

EPA invitees: Penny Lassiter, Nick Parsons, Brenda Shine, Jodi Howard, Andrew 

Bouchard, Brian Shrager, Kelly Rimer

cc: Marguerite McLamb, Fred Thompson, Peter Tsirigotis, Kevin Culligan, Ravi 

Srivastava

10:30 –11:15 pm Topic: Boiler MACT, Boiler GACT, CISWI (SPPD schedule)

• Reconsideration

• Next steps

• NSPS KKKK

• MATS 

EPA invitees: Jim Eddinger, Mary Johnson, Toni Jones, Christian Fellner, Steve Fruh, 

Bob Wayland, David Cozzie

11:15- 12 pm Topic: Greenhouse Gas (SPPD schedule)

• 111(d) and 111(b) rules – timing, model FIP plan

• Other sectors? 

EPA invitees: Bob Wayland, Nick Hutson, Ravi Srivastava, Lisa Conner, Penny Lassiter, 

Douglas Solomon, David Cozzie, Dale Evarts, Steve Fruh, Marguerite McLamb, Kevin 

Culligan and Matthew Witosky

AQPD invitee: Juan Santiago

cc: Fred Thompson, Neil Frank, Bill Lamason

12 pm Adjourn