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 Report ing 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 Attac hment 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 reminde d the audience that only clarifying questions could be answered. The clarifications provided by the EPA included:

• T he format for reports that are submitted through the Compliance and Emissions Data Reporting Interface (CEDRI).

• The EPA’s intention to rel ease 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

.
• T he 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.

• F or 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 AttendeesThe following people and/or agencies were recorded as being on the conference call :

EPA/ OAR/ OAQPS Gerri Garwood EP A/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, Californi a 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, KansasSection B Proposed AgendaNAC AA ENFORCEMENT & COM PLIANCE COMMITTEE Conference Call Wednesday , Ma y 6 , 201 5 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 N ext C all : 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.p dfSection 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 ProcessCDX 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 ► S treet 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
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