MEMORANDUM From: The Office of Air Qu ality 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, emi ssion factor development and annual emission rate determinations. In conduc ting these required review s, 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, st ack testing firms have typically collected performance test data in electronic format, making it possibl e 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. Speci fically, 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 construc ted 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/i ndex.cfm?action=fire.main

. As proposed above, data entry would be through an electronic emissions te st 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 elec tronically to the EPA woul d apply only to those performance tests conducted using te st methods that will be supporte d 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 fr om 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 re quired to be reported by this proposed rule. Another advantage is that the ERT clearly states wh at testing information would be required. Another important proposed benefit of submitti ng these data to the EPA at the time the source test is conducted is that it should substantially reduce the effort involv ed in data collection activities in the future. When the EPA has performance test data inhand, there will likely be fewer or less substantialdata collection requests in conjunction with prospectiv e 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 collect ion requests) and the EPA (in term s of preparing and distributing data collection requests a nd assessing the results). State, local and tribal agencies could also bene fit 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 evaluati on of the source provided data and calculations easier and more efficient. In additi on, 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 thes e 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 mo re representative of current industry operational procedures. A common complaint heard from industry and regulator s is that emission fact ors are outdated or not representative of a particular sour ce 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 de velopment, 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 ti me, money and effort while also improving the quality of emission inventories and, as a result, air quality regulations.