MEMORANDUM 

TO: Docket EPA-HQ-OAR-2009-0 174 

FROM: Gerri G. Garwood, P.E., EPNOARIOAQPS/SPPD 

DATE: May 7, 2015 

SU BJECT: Summary of Webinar for State, Loca l, and Tribal Agencies on May 5, 201 5 

On May 5, 20 15 at 2:00 p.m. Eastern Standard Time, the EPA hosted a webinar for state, 

local, and tribal agencies to provide information on the recently proposed Electronic Reporting 

and Recordkeeping Requirements for NSPS rulemaking. A list of attendees is included as 

Attachment A to this memo. The slides from the presentation are included as Attachment B to 

this memo. 

After the presentation, there was a question and answer session. The EPA reminded the 

audience that only clarifying questions could be answered. The EPA responded to the following 

questions: 

• Will the presentation be available on-line? 

o The EPA clarified that a copy of the presentation and a recording of the webinar 

would be made available at the ATW website under "Rules and Implementation" 

(http://www.epa.gov/ttn/atw/eparules.html). 

• Can you explain the interaction of CEDRI with the £-Enterprise project? 

o The EPA clarified that CEDRI has been developed as part of £-Enterprise, a 

collaborate effort between the EPA and states through the Environmental Counci I 

of States (ECOS). The EPA also stated that there was an integrated project team 

organized through ECOS to discuss the CEDRI data flow at the time of 

development. 

• Any plans/timeline to expand electronic reporting to NESHAP/MACT rules? 

o The EPA clarified that the original intention of the electronic reporting rule was to 

cover all Part 60, 6 1, 63, and 65 subparts, but due to time and resource 

constraints, the rule cunently only includes Part 60 subparts. However, the EPA 

still intends to cover Part 63 in an additional rulemaking effort and continues to 
include electronic reporting on an individual subpart basis when the subparts are 

opened for other reasons. 

• Do you know how many States are accepting CEDRI submittals rather than hard copy 

reports (which are submitted to the State)? 

o The EPA clarified that it docs not have this information, although states have 

mentioned an intention to do so in the future. 

• Will there be any way for a state reviewer to "tag" facilities in CEDRI, so that when any 

report by that facility is submitted we will be notified automatically? 

o The EPA clari lied that reviewers cannot tag certain facilities in CEDRI, but that 

the reviewers can set notifications for particular counties and report types. 

• As a regulator, how do you know when a report has been uploaded for a facility in your 

jurisdiction? Are notifications sent? 

o The EPA clarified that if a reviewer registers with CEORI, the reviewer will be 

able to set type and frequency of notifications. 

• Can you clarify whether the reporting requirement take effect within 90 days of 

promulgation of the rule or whether it is 90 days once fonns become available? 

o The EPA clarified that if the CEDRI forms are complete by the time the rule is 

promulgated, as is the agency's intention, then the rule is effective 90 days from 

promulgation. However, if a particular form does not exist at the time that the 

rule is promulgated, facilities have 90 days from the time the form is available to 

start complying with the electronic reporting provisions for that form. 

• Will there be a standard to raise the emission results to I 00% of operating load. In other 

words if a stack test is run at 90% and thus the results is 90% are results extrapolated to 

100%? 

o The EPA clarified that it will not change any of the data submitted by the facility, 

and that reviewers must handle these situations in the same way that they handle 

them now. 

• When a stack test is performed for multiple purposes (e.g. NSPS, permit requirements, 

Acid Rain, etc.) will states have access to the additional information through CEDRI 

needed to determine compliance with those rules not NSPS? 
o The EPA clarified that multiple reasons can be checked when completing a stack 

test report. If additional information is required, there is a separate upload area 

that can be used by the facility. 

At the end of the presentation, the EPA encouraged the audience to provide comments on 

the proposed rule. 
Appendix A 

List of Attendees 
The following are the log-in IDs recorded for the webinar: 

EP A/OAR!OAQPS 

Mike Ciolek 

Rick Copland 

Deborah Elmore 

Gerri Garwood 

Angela Hackel 

Brad .J oh11S 

Theresa Lowe 

Lori Tussey 

State and Local Agencies 

Guest 

Guest 

Guest 

Guest 

Guest 

Agata Mcintyre 

Alaska Air Quality 

Aliya Khan 

Alirez Khalilzadeh 

Amanda Horstmann 

Amanda Rodriguez Martinez 

Ana Perez - Maryland 

Anthony Manson (Delaware) 

Anu Jain 

AQP 

Barbara Harwell 

Barry Halcrow 

Bradley Miller 

Brenda Eggleston 

Brenda Pomales 

Brian Hutchins 

Carmen Pedraza 

Casey Huck 

Catherine Beahm 

Chris 

Chris Kjellmark 

Chris Wood 

Christine Paulson 

Dan May 

Danny Luong 

DAQ 

Dave 

Dave Morgan 

David Harris 

DNREC 

Eleonora Kats 

Elmer Casiano 

George Eckert 

Howard Beeson 

Isabel Navoa 

James M. Jones 

Janice Easley 

Janine 

Jason, MCAQ 

Jb 

John McKie 

Jonathan Barker 

Jonathan Carney 

Jon Harwick 

Jorge Lopez 

Kale Walch 

Karen Kajiya-Mills 

Karen Mongoven, NACAA 

Kdhe mw 

Kelly Poole 

Kendra 

Kerri Nicholas 

Ketan Bhandutia 

Kevin 

KY 

Larry Brown 

Laura 

Laura Nikkei-Dumyahn 

Laurie Halvorson 

Lisa Ehrhart 

Lisa Jones 

Luis Sierra 

Maribel Lopez 

Mary Douglas 

Mary Lchman-Sclunidt 

Matt Stanfield 

MDEQ 

Megan Hayes - VADEQ 

Michael Hern1sen 
Michae l Klein 

Mitch Haimov 

Mohamed 

Mstotts 

NCDAQ 

Ocir 

OKDEQ 

Patty Campbell 

Peter Park 

Phil Stiff 

Ppacheco 

Rayna Broadway 

Rebecca Wiscovithc 

Regis- Puerto Rico 

Rick Bolfing 

Robert 

Rupesh Patel 

Russ Brichacek 

Sandra Etzel 

Santos Olivarez 

S Blackburn 

Scott Porter - Pima County DEQ 

Sean Hackett 

Shibi Paul 

Sonja Lewis 

Stephen Ours 

Thomas Maza 

Tim Kuntz 

Tom Tyler 

Tran Vo 

Rayna Broadway 

Regina Bish 

Renae Held 

Renee 

Rhonda Jeffries 

Sandra Etzel 

Scot Stinson 

Sherry Tostenson 

Tom Fitzgerald - NMED 

Tom Valentour 

T. Thompson 

Virginia DEQ 

Wanda Parnell 

Washoe Co AQMD 

Will 

William Sarraf 

Zach Klotovich 
Section B 

Presentation 
Overview of the EPA’s Proposed Rule:

Electronic Reporting and Recordkeeping Requirements for 

New Source Performance Standards (NSPS)

Gerri G. Garwood, P.E.

OAR/OAQPS/SPPD/

Measurement Policy Group

May 5, 2015
Topics for Discussion

► Overview of the Process

► Where We Are Now

► Information on the Rule

► Benefits of E-Reporting

► Requests for Comment

► Useful Websites

Please note: Because this rule is currently open for comment, 

the EPA is only allowed to answer clarifying questions. 

All comments should be submitted formally through one of the 

mechanisms described in the preamble of the proposed rule
Overview of the Process
CDX 

Central Data Exchange

CEDRI

Compliance and 

Emissions Data 

Reporting Interface

Air Emission 

Reports, e.g. 

Excess Emission 

Reports

(fillable form in 

CEDRI)

Source Tests 

and RATA 

(ERT upload)

Compliance 

Status Reports

(pdf upload)

WebFIRE 

Database

Public Access

Up to 60 

Days

Review by 

Delegated Agency
Where are we now?

► Electronic Reporting Tool (ERT)

► Version 5 released last year, updated in January

► 41 Test Methods

► 3 Performance Specifications

► Can extract data from tagged Excel spreadsheets

► Required ERT in Section 114 requests and about 2 dozen 

rules

► CEDRI 

► Went live January 1, 2012

► Currently accepts ERT files

► Currently accepts a limited number of other reports 

► Can create templates for reporting

► Supports submission of multiple reports in one package
More on CEDRI

► Supports “roles” for users

► Preparer

► Certifier

► Agency reviewer

► Preparers and certifiers must be registered for the same 

organization in order to share reports 

► Preparers and certifiers can each be linked to multiple 

organizations

► Multiple preparers can be linked to one certifier

► Can only see data for which the preparer and certifier match

► Link with Facility Registry System (FRS)

► Pre-populate data

► Generate a new FRS ID if needed

► Help is available: cedri@epa.gov
How do I register?

► Send a request for registration to cedri@epa.gov

► Include this information in the email:

► Name

► Government email address

► Phone number

► Street address 

► Once registered, receive notifications of submitted reports

► Can be for your whole state/local district or select counties

► Can specify notification frequency 
WebFIRE

► Public access site

► Houses electronic reports

► ~25 rules with e-reporting

► >3000 submissions 

► EPA’s online emissions factor repository

► Recommended Procedures for Development of Emissions 

Factors (August 2013)

► Test data reported with ERT via CEDRI 

► ERT assigns test rating to the report

► Statistical procedures (MDL, outliers, combinations)

► Letter grades changed to representativeness

► Recently used in refinery emissions factors

► Will be able to create user-defined factors

► Notifications of submissions available
Electronic Reporting and 

Recordkeeping Requirements for 

NSPS
Basic Information

► Proposal published March 20, 2015

► 60 day comment period

► General Provisions and approximately 75 subparts

► Applies to existing sources subject to the NSPS

► Effective 90 days after promulgation

► Only reporting format is different

► No new data elements

► No new reports

► No new timeframes
Delegated Agency Impacts

► Reporting and recordkeeping unaffected 

► May choose to modify requirements to accept report through 

CEDRI in lieu of hard copies

► Have full access to reports and associated data as soon as they 

are submitted

► Does not require purchase of new software or hardware

► Permit revisions

► Title V operating permits will likely need revision

► Area sources may also need permit revisions 

► Depending on timing, may be completed as part of a permit renewal

► Likely a minor modification

► May have other suitable mechanisms for revisions
What’s in the rule?

► Covers the following reports

► Stack tests and CEMS Performance Evaluations

► Summary Reports and Excess Emission Reports

► Notification of Compliance Status Reports

► Subpart Specific Reports

► Added 40 CFR 60.8(j)

► NSPS that rely on the General Provisions not specifically 

amended

► Changes for consistency

► Where subpart-specific reports require inclusion of stack test 

reports, replaced with identifying information:

► Process unit 

► Pollutant tested

► Date of test 
What’s in the rule?

► Electronic reporting cannot be exempted in delegation 

agreements

► Do not have to report to EPA regional office

► Includes e-records in lieu of paper records

► Ultimately, each submission stored in two places 

► CROMERR COR is retained in CDX

► Same file without the CROMERR COR available through WebFIRE

► Both WebFIRE and CDX: 

► Back up their files daily 

► Have dual back-up systems
The Processing Period

► Time between submittal and public availability

► 60 days for ERT reports

► 30 days for other reports 

► EPA/delegated agency reviewers have access through 

CEDRI

► Source may submit corrections 

► If changes are made prior to end of processing period, starts 

over 

► Only the corrected package will be available in WebFIRE

► All versions of submitted reports remain part of the official 

record
Other report formats

► Plan to release XML schema for ERT

► Plan to release XML schema for air emissions reports in 

CEDRI

► Will not preapprove third party software 

► Third party software validated through CEDRI submittal

► For CEDRI subpart-specific reports, will be able to upload 

data instead of filling in the form 

► Development of a web-based version of the ERT
What if the forms aren’t ready?

► Plan to have all fillable forms complete by promulgation

► If CEDRI form not complete, sources continue submitting 

the way they do now

► 90 days from the date of availability to commence electronic 

reporting 

► During 90 day period may report either hard copy or 

electronically

► Notice will be sent out through the CHIEF Listserv 

► Notice of availability will be added to the CEDRI website 
What’s not included?

► NSPS that do not require the submission of any of the 

reports in the rule

► NSPS being addressed under separate rulemakings

► Emission guidelines: 

► Prevent burden to delegated agencies

► Will address as they are opened for other changes

► Delegated agencies may choose to revise and submit state plans to 

incorporate proposed electronic reporting requirements 

► Plan to address electronic reporting in the Federal Plans that 

implement the emission guidelines
Electronic Reporting Benefits

► The EPA believes that the electronic submittal of the reports 

addressed in this proposed rulemaking:

► Will increase the usefulness of the data contained in those reports 

► Is in keeping with current trends in data availability 

► Will further assist in the protection of public health and the 

environment 

► Ultimately results in less burden on the regulated community 

► Universally considered to be faster, more efficient and more 

accurate for all parties once the initial systems have been 

established and start-up costs completed
Why does EPA want this data?

► Emission factors revisions

► Emission inventory improvement

► MACT floor development

► Risk and technology review

► Control device assessment

► Detection limit review
Benefits to Air Agencies

► Report standardization

► Quicker reviews

► Faster response to violations

► More complete data

► Imbedded QA checks

► Software “search” options

► Ability to download and analyze data in spreadsheets

► Federal repository

► Includes data back-up

► Reduces hardcopy storage needs/costs

► Accessibility

► Improved emissions factors/inventories

► Reduced requests for information
Benefits to Regulated Entities

► Reduced data entry

► Report standardization

► Required elements outlined

► Imbedded QA checks

► Minimize duplicative reporting

► Improved emissions factors

► Improved inventories

► Section 114 requests

► Decrease in number

► Less extensive

► Maintenance and storage of paper records

► Overall estimated savings: $300,000 per year
Benefits to the Public

► Improved inventories

► Quicker reviews

► Delegated agency compliance reviews

► CAA-required technology and risk reviews

► Accessibility
Requests for Comments

► Submission of data not already required

► Creation of web-based ERT

► Lack of access to computers and the Internet

► Electronic recordkeeping in lieu of paper

► Impacts on small businesses

► Comments from states, locals, and tribes

► Long-term emissions data/process data 
Websites of Interest

► CDX 

http://www.epa.gov/cdx

► ERT

http://www.epa.gov/ttn/chief/ert/index.html

► CEDRI 

http://www.epa.gov/ttn/chief/cedri/index.html

► WebFIRE

http://cfpub.epa.gov/webfire/

► Emissions Factor Procedures

http://www.epa.gov/ttn/chief/efpac/procedures/index.html

► CHIEF listserv

http://www.epa.gov/ttn/chief/listserv.html#chief
Questions?

Reminder: Because this rule is currently open for comment, 

the EPA is only allowed to answer clarifying questions. 

Gerri Garwood

garwood.gerri@epa.gov

919-541-2406