MEMORANDUM 

From: The Office of Air Quality Planning and Standards 

 U.S. Environmental Protection Agency 

To: Combustion Turbine NSPS Docket (EPA-HQ-OAR-2004-0490) 

Date: June, 2012 

Subject: Electronic Data Submittal 

Electronic Data Submittal 

The EPA must have performance test data to conduct effective reviews of CAA sections 111 standards, 

as well as for many other purposes including compliance determinations, emission factor development 

and annual emission rate determinations. In conducting these required reviews, the EPA has found it 

ineffective and time consuming, not only for us, but also for regulatory agencies and source 

owners/operators, to locate, collect and submit performance test data because of varied locations for data 

storage and varied data storage methods. In recent years, though, stack testing firms have typically 

collected performance test data in electronic format, making it possible to move to an electronic data 

submittal system that would increase the ease and efficiency of data submittal and improve data 

accessibility. 

Through this proposal the EPA is presenting a step to increase the ease and efficiency of data submittal 

and improve data accessibility. Specifically, the EPA is proposing that owners/operators of stationary 

combustion turbines submit electronic copies of required performance test reports to the EPA’s 

WebFIRE database. The WebFIRE database was constructed to store performance test data for use in 

developing emission factors. A description of the WebFIRE database is available at 

http://cfpub.epa.gov/oarweb/index.cfm?action=fire.main. 

As proposed above, data entry would be through an electronic emissions test report structure called the 

Electronic Reporting Tool (ERT). The ERT would generate an electronic report which would be 

submitted using the Compliance and Emissions Data Reporting Interface (CEDRI). The submitted report 

would be submitted through the EPA’s Central Data Exchange (CDX) network for storage in the 

WebFIRE database making submittal of data very straightforward and easy. A description of the ERT 

can be found at http://www.epa.gov/ttn/chief/ert/index.html and CEDRI can be accessed through the 

CDX website (www.epa.gov/cdx). 

The proposal to submit performance test data electronically to the EPA would apply only to those 

performance tests conducted using test methods that will be supported by the ERT. The ERT contains a 

specific electronic data entry form for most of the commonly used the EPA reference methods. A listing 

of the pollutants and test methods supported by the ERT is available at 

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

We have concluded that industry would benefit from this proposed approach to electronic data 

submittal. Having these data, the EPA would be able to develop improved emission factors, make fewer 

information requests, and promulgate better regulations. 

One major advantage of the proposed submittal of performance test data through the ERT is a 

standardized method to compile and store much of the documentation required to be reported by this 

proposed rule. Another advantage is that the ERT clearly states what testing information would be 

required. Another important proposed benefit of submitting these data to the EPA at the time the source 

test is conducted is that it should substantially reduce the effort involved in data collection activities in 

the future. When the EPA has performance test data in hand, there will likely be fewer or less substantial 
data collection requests in conjunction with prospective required residual risk assessments or technology 

reviews. This would result in a reduced burden on both affected facilities (in terms of reduced 

manpower to respond to data collection requests) and the EPA (in terms of preparing and distributing 

data collection requests and assessing the results). 

State, local and tribal agencies could also benefit from more streamlined and accurate review of 

electronic data submitted to them. The ERT would allow for an electronic review process rather than a 

manual data assessment making review and evaluation of the source provided data and calculations 

easier and more efficient. In addition, the public stands to benefit from electronic reporting of emissions 

data by improving both the public's ability to easily access such information and the timeliness by which 

the public can access such information. Finally, another benefit of the proposed data submittal to 

WebFIRE electronically is that these data would greatly improve the overall quality of existing and new 

emissions factors by supplementing the pool of emissions test data for establishing emissions factors and 

by ensuring that the factors are more representative of current industry operational procedures. A 

common complaint heard from industry and regulators is that emission factors are outdated or not 

representative of a particular source category. With timely receipt and incorporation of data from most 

performance tests, the EPA would be able to ensure that emission factors, when updated, represent the 

most current range of operational practices. 

In summary, in addition to supporting regulation development, control strategy development and other 

air pollution control activities, having an electronic database populated with performance test data would 

save industry, state, local, tribal agencies and the EPA significant time, money and effort while also 

improving the quality of emission inventories and, as a result, air quality regulations.