MEMORANDUM

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

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

DATE: May 6, 2015

SUBJECT: Summary of Meeting with NACAA on May 6, 2015

The National Association of Clean Air Agencies (NACAA) held a meeting of its 

Enforcement and Compliance Committee on May 6, 2015 at 12:30 p.m. Eastern Standard Time. 

During the call, the EPA gave a brief overview of the recently proposed Electronic Reporting 

and Recordkeeping Requirements for NSPS rulemaking. To enhance the overview, the 

participants were provided the slides from the webinar that the EPA hosted for state, local, and 

tribal agencies on May 5, 2015. A list of attendees is included as Attachment A to this memo. 

The agenda for the meeting is included as Attachment B to this memo. The slides sent to the 

participants are included as Attachment C to this memo.

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

the audience that only clarifying questions could be answered. The clarifications provided by the 

EPA included:

• The format for reports that are submitted through the Compliance and Emissions 

Data Reporting Interface (CEDRI). 

• The EPA’s intention to release the extensible markup language (XML) schema 

for both the CEDRI forms and the Electronic Reporting Tool (ERT).

• The additional space available on the CEDRI forms for data that delegated 

agencies require beyond what is required in the federal regulations. 

• The need for state and local agencies to specify to sources what additional 

information would be required beyond the federal regulations, as the CEDRI 

forms cannot be made specific for each state and local agency.

• For stack test reports, the ability to select multiple purposes for performing the 

test. 

• The registration process for becoming an agency reviewer in CEDRI.
A local agency requested that the EPA do training on electronic reporting. The EPA 

clarified that training in the form of recorded webinars is currently available on its website and

that additional training can be provided in the future.

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 people and/or agencies were recorded as being on the conference call:

EPA/OAR/OAQPS

Gerri Garwood

EPA/OECA/OC

Robert Lischinsky

Julius Banks

NAACA

Mary Sullivan Douglas

State and Local Agencies

Clark County, Nevada

Dayton Ohio Regional Air Pollution Control

Delaware

Georgia

City of Houston

Iowa

Jacksonville, Florida

Kentucky

Linn County, Iowa

Louisville Metropolitan Area

Maricopa County, Arizona

Mecklenburg County, NC

Michigan

Missouri

Monterrey Bay, California

New Jersey

New Mexico

Oklahoma

Oregon

Pennsylvania

Puget Sound

San Diego

Santa Barbara County, California

South Carolina 

South Coast Air Quality Management District

Utah

Vermont

Washington, D.C.

Wisconsin

Wyandotte County, Kansas
Section B

Proposed Agenda
NACAA ENFORCEMENT & COMPLIANCE COMMITTEE

Conference Call

Wednesday, May 6, 2015

12:30 p.m. – 2:00 p.m. Eastern Time

Call-In Number: (866) 365-4406 Access Code: 5870993#

Press *6 to mute your line and *7 to un-mute it

AGENDA

With EPA

 Roll Call

 Electronic Reporting Proposed Rule for NSPS Sources – Use of Compliance and 

Emissions Data Reporting Interface (CEDRI) on EPA’s Central Data Exchange (CDX) –

Gerri Garwood (EPA-OAQPS) or Bob Schell (EPA-OAQPS)

NACAA Only

 Report from NACAA Spring Membership Meeting (Eddie Terrill – OK and Richard 

Stedman – Monterey, CA)

 Other Issues

 Announcement of Next Call: Wednesday, July 1, 2015 from 12:30-2:00 p.m. Eastern

time

Related Information:

Electronic Reporting and Recordkeeping Requirements for NSPS – Proposed Rule – March 20, 

2015 Federal Register Notice: http://www.gpo.gov/fdsys/pkg/FR-2015-03-20/pdf/2015-

05406.pdf
Section C

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