# Compliance and Emissions Data Reporting Interface
Integrated Project Team

Guidance and Recommendations

Document

Version: 1.0
Revision Date: September 26 , 2013ii | P a g e



## Revision History

Version Number Description of Change Change Effective Date Change

Entered By
0. 1 Initial draft delivered to CEDRI

IPT 08/ 2 3 /2013 EPA

0.2 Second draft delivered to IPT

Participants 0 9 / 03 /2013 EPA

1.0 IPT participant comments

incorporated 09/26/2013 EPAiii | P a g e



## Table of Contents
Revision History

................................ ................................ ................................ ................................ ............ ii

1 Introduction

................................ ................................ ................................ ................................ .......... 1

1.1 CEDRI Background

................................ ................................ ................................ ......................... 1

2 IPT Objectives & Structure

................................ ................................ ................................ .................... 2

2.1 Objectives

................................ ................................ ................................ ................................ ...... 2

2.2 Structure

................................ ................................ ................................ ................................ ....... 3

2.3 Reference Documents

................................ ................................ ................................ ................... 3

3 Summ ary of Findings

................................ ................................ ................................ ............................. 5

3.1 General Interest and Success Measures

................................ ................................ ....................... 5

3.2 Dataflow

................................ ................................ ................................ ................................ ........ 5

3.2.1 Processing Time for State Review

................................ ................................ ......................... 6

3.3 Data Resubmission

................................ ................................ ................................ ........................ 6

3.4 Data Requirements:

................................ ................................ ................................ ...................... 7

3.4.1 S/L/T Specific Data

................................ ................................ ................................ ................ 7

3.4.2 Report Identification

................................ ................................ ................................ ............. 8

3.5 Data Access

................................ ................................ ................................ ................................ ... 8

3.5.1 CEDRI ve rsus WebFIRE Access

................................ ................................ .............................. 9

3.5.2 Notifications

................................ ................................ ................................ .......................... 9

3.5.3 Review File Access

................................ ................................ ................................ ............... 10

3.5.4 Alternate ERT Formats

................................ ................................ ................................ ........ 10

4 Guidance and Recommendations

................................ ................................ ................................ ....... 111 | P a g e 

## 1 Introduction

This document provides a summary of the information gathered through the Compliance and Emissions Data Reporting Interface (CED RI) Integrated Project T eam (IPT) and the guidance and recommendations derived from these inputs . The content in this document is based on input from the CEDRI IPT that was formed to address data submission, data resubmission

, and data access requirements for eReporting under 40 Code of Federal Regulations (CFR) Part 60 and 63.



### 1.1 CEDRI Background

CEDRI is an application being created on the Environmental Protection Agency’ s ( EPA’s ) Central Data Exchange (CDX) to collect electronic reports required under 40 CFR Parts 60 and 63 from regulated entities

. CEDRI is undergoing a phased development approach

. The first phase , already implemented, allows regulated entities to
submit performance test and performance evaluation reports. The second phase of CEDRI , scheduled for release in the first quarter of fiscal year 2014, will allow regulated entities to submit certain air emissions data reports (reports similar to semi

- annual or excess emissions reports) in addition to performance test reports and evaluation reports

. N otification of compliance status reports will be included in a later CEDRI release. The CEDRI application is being designed to tr ansition the EPA to electronic reporting which will support improved data quality and facilitate review of reports

. EPA is making CEDRI available to State, Local, and Tribal (S/L/T) agencies as an optional tool to assist them in receiving reports.

EPA’s go al is to implement a dual

- reporting structure where a ir e missions r eports will be sent to EPA and to the S/L/T agencies

. M aintaining the present mode of reporting by regulated entities to S/L/T agencies is important

. Therefore, s ources are obligated to sub mit reports to EPA electronically via CEDRI

, and to their S/L/T agency in the agency designated manner (paper or electronic reporting system)

. S/L/T agencies ha ve the opt ion to participate in EPA ’s electronic reporting system

. In addition, EPA plans to release the XML (eXtensible Markup Language) schema for their reporting tools so that S/L/T agencies currently with electronic reporting systems can modify their systems to be compatible with CEDRI.

The current plan is to use the Web

- based Factor and Information Retrieval System ( WebFIRE ) as a repository for all files submitted to EPA through CEDRI. This includes p erformance t est r eports via the Electronic Reporting Tool ( ERT )

, n otification of compliance r eports, and a ir e missions r eports. WebFIRE is being modified to accommodate this expanded functionality.2 | P a g e 

## 2 IPT Objectives & Structure

2.1 Objectives

The objectives of the CEDRI IPT were to gather requirements and ideas from S/L/T agencies on the data flow process within the CEDRI application

. Areas of particular interest were the submittal and electronic report review process

. Consequently , and as defined by the CEDRI IPT charter, the topics of discussion were limited to data submission, data resubmission, and data access requirements of the CEDRI data flow

.

The IPT sought to answer the questions listed in Exhibit 2

- 1

.

Exhibit 2

- 1 CEDRI IPT Questions

Category Topic Data Flow I nformation submitted via CEDRI into the CROMERR CDX archive will not be immediately entered into the WebFIRE database

. What is an appropriate period of time to have reported data available in the WebFIRE database? 30 days? More than 30 days?

a. Performance Test Reports (ERT reports) b. Air Emissions Data Reports/Continuous Emissions Monitor data
summaries

c. Notification of Compliance Status Reports

Data Resubmission Should data

, resubmitted to correct previously submitted data

, follow the same process as data entered for the first time? Data Requirements Do the empty fields [memo fields] and the a bility to attach PDF documents to the Air Emissions Data Reports templates ade quately accommodate the need for sources to submit information not required by the Federal rules? The goal of this feature is to allow sources to meet both Federal and State or Local requirements in the same electronic submittal package

. Reports being submitted are identified in CEDRI by the Code of Federal Regulations citation to where the report is required to be submitted

. Is this adequate for S tate /L ocal /T ribal (S/L/T) agencies ’ purposes?
Data Access How would S/L /T prefer to access this data? We presume agencies would like immediate access to the data submitted to CEDRI.

a. U sing a user restricted interface in CEDRI or by setting up an automatic system to view the data via the Exchange Network. b. Through a user restricted interface in WebFIRE. How do we identify the reviewers to notify when reports are received by the CROMERR CDX archive? EPA wants to provide a universal output format other than Microsoft Access for use by S/L/T agencies to review the data found in the ERT performance test reports

. a. What alternatives should EPA consider for release at the same time CEDRI undergoes its next update? (i.e. XML Schema data dictionary definitions)3 | P a g e



### 2.2 Structure

The CEDRI IPT was composed of the following represe ntatives from EPA, state, and local agencies

.

Exhibit 2

- 2 CEDRI IPT Participants

Participant Name State or Organization Colin Boswell U.S. EPA, OAQPS Mike Ciolek U.S. EPA, OAQPS Robert Schell U.S. EPA, OAQPS Gerri Garwood U.S. EPA, OAQPS Bernard McKee North Carolina Dept. of Environment and Natural Resources Nathan Wilkes U.S. EPA, OIC Christy Monk Alabama Dept. of Environmental Management Erica Engel

- Ishida Ohio E nvironmental P rotection A gency Heather Sessing Oklahoma Dept. of Environmental Quality Mike Ahe rn Ohio E nvironmental P rotection A gency Janell White Linn County , Iowa Jason Swift U.S. EPA , OECA Jim Hodina Lin n County , Iowa Kevin Vuilleumier U.S. EPA, Region V Ray Walters New Hamps h ire Dept. of Environmental Services Rob Lischinsky U.S. EPA, OECA
Ron Evans U.S. EPA , OAR Haley Stowe U.S. EPA Region 7 Jim Pennington Florida Dept. of Environmental Protection

IPT meetings were held every 2 weeks between May 14, 2013 and September 10 , 2013

. A total of 8 meetings
were conducted. The meetings were conducted via on

- line conference call

.

Prior to the IPT sessions

, a questionnaire was distributed to the IPT participa nts. Questionnaire results are
summarized in the spreadsheet and the PowerPoint presentation made part of this document by reference . The spreadsheet and presentation were used during the IPT meetings to guide and facilitate discussion s

.


### 2.3 Reference Document s
The documents listed below were used by the CEDRI IPT:



### 1. CEDRI IPT Questionnaire 05012013.docx


### 2. CEDRI IPT Questionnaire Summary 05202013.xlsx


### 3. CEDRI IPT Meeting Minutes 05142013 _Final .docx


### 4. CEDRI IPT Meeting Minutes 05282013_Final.docx


### 5. CEDRI IPT Meeting Minut es 06112013_Final.docx


### 6. CEDRI IPT Meeting Minutes 06252013_Final.docx


### 7. CEDRI IPT Meeting Minutes 07092013_Final.docx4 | P a g e



### 8. CEDRI IPT Meeting Minutes 07232013_Final.docx


### 9. CEDRI IPT Meeting Minutes 08062013_Final.docx5 | P a g e 

## 3 Summary of Findings

Report findings are organized by question groups as established in the objectives in the IPT Charter documen t. For each question group

, a brief discussion of the question topic is first presented summarizing IPT viewpoints and considerations. The summary i s then distilled into “Consensus Fin d ings” for each question in the question

group.



### 3.1 General Interest and Success Measures

A poll of the general level of interest of IPT participants in pursuing some form of e lectronic r eporting had 67%
interested and 33% unsure. No participants stated that they had no interest in p ursuing electronic r eporting

.
With respect to ut i lizing EPA’s electronic reporting program (using the CEDRI application to receive and review reports) , 43% were interested, 14% were not interest ed

, and 43% were not sure. Respondents cited the fact that they were already pursuing their own electronic reporting initiatives as the reason for not being interested. The
conclusion reached is that key factors for adopting EPA’s electronic reporting prog ram are: the system should be able to accept data collected by the S/L/T agencies , and that the data exchange is centralized and efficient.

Two overarching principles that emerged from the IPT as fundamental to the CEDRI implementation are :

1. Identification of valid submissions:

a. A goal of the system should be to determine that the data submission is complete prior to state review and then only make quality

- assured data available for public review. This could be accomplished by acknowledging that submissions m ay have not yet been reviewed; though the S/L/T agencies would need the ability to remove the flags once reviewed.
b. S/L/T agencies all observe best practice s to identify whether or not a submission has been reviewed, regardless of the type of submission (A ir Emissions Report or ERT Performance Reports). Therefore, the ability to mark or flag a report should be given to all reporting types.
2. Incorporating current S/L/T procedures:

a. With all requirements and decisions, the intent is to maintain current process es and procedures implemented by sources and S/L/T agencies . There is the possibility that a state may not review a report for a long time, due to existing framework that S/L/T agencies have for viewing tests and recording results.
b. S/L/T agencies want a wa y to tie their own reporting/reviewing flows into the data being collected, reviewed, and published in CEDRI

.
c. S/L/T agencies have the desire to minimize duplicated work/effort. Some S/L/T agencies keep information on reports and reviews in their own state system. d. All state parties desire a mechanism for easy transferability between review files uploaded/created with state

- specific procedures and the state review file component of CEDRI.



### 3.2 Dataflow

The assumption was made that S/L/T agencies would like access to report submissions as soon as they are received by CEDRI and have sufficient time to review and process reports before they are made available to the6 | P a g e

public through WebFIRE. The amount of time necessary for S/L/T agencies to review re ports is addressed in the dataflow question group.

3.2.1 Processing Time for State Review The period of time that submitted reports should be made available to S/L/T agencies to review and process was found to vary by state, report type and also report complexit y

. The standard among the S/L/T agencies is that reports (stack test reports) are required to be submitted within 30 to 60 days after the end of each quarter, and
the S/L/T agencies then allow 30 to 60 days for the review and processing of the submitted re ports.

State processing time will vary by report since the time it takes to review reports depends on the type of test, the source, the quality of the data, and the presentation of the data in the final report.

Submitted reports that are released to WebFI RE for public access should indicate if the report has undergone state level review. This indicator may potentially be worked into the quality rating for the emission factor data. There is not a desire however to prevent the rel ease of the report to WebFIR E if a state level review has not
occurred.

Consensus findings : The processing periods for all reporting types will begin on the date the report is submitted. The following consensus was reached regardi ng submission processing periods:



### 1. ERT Performance Test Reports

– The typical review period for ERT Performance Test Reports was
determined to be 120 day s. This is the consistent time S/L/T’s are given to enter data associated with their review of Performance Test Reports into the Air Facility System ( AFS )

. 

### 2. Air Emissions Reports

- A shorter review process is typical for Air Emissions Reports than for ERT
Performance Test Reports. IPT participants suggested a processing period of 30 days to be sufficient

. 

### 3. Notification Reports

– Since the CEDRI application w ill be collecting only the semi

- annual Notification Reports, the review process will be much shorter than for ERT Performance Test Reports. 30 days was determined to be an appropriate period of time.



### 3.3 Data Res ubmission

The data resubmission question group addressed the handling of report resubmissions that incorporate S/L/T
review comments. In the event a report must be re

- submitted, the IPT agreed that the re

- submission s should follow the same process as the initial report and be subject to the original processing period

. On average 25% of submitted reports require resubmittal to correct anomalies. Some S/L/T agencies experience higher rates (33%

- 50%) that may reach as high as 67% for some reporting types.
Suggestions for handling resubmitted reports tha t did not garner group consensus, but should be considered in the application include:

 The ability to mark resubmissions as ‘Ready to Release’ was suggested as a way to allow a resubmitted report to be released to WebFIRE at the completion of the review

. T he same approach may be applied
to initial submissions as well.7 | P a g e

 Incorporating metadata th at describes the reasons for resubmission

, version chronology, resubmission timestamp
, AFS ‘Pass/Fail’ results, and whether the review was conducted on paper or electr onically.

Con s e n sus was not reached regarding whether both reports should be made publicly available through
WebFIRE.

Those in favor of publishing both reports reasoned that:

 Some re

- submissions may be due to serious problems or heavily invalid data/calc ulations and should be
treated as a whole new test.

 Since WebFIRE is a public repository, both reports should be publicly available.

 If both reports are published, the re

- submission must be distinguished, so as not to be duplicative.

Those who argued tha t only the final report should be published reasoned that:

 Some re

- submissions are corrections to calculations or results that use the original field data. These should be treated as revisions to the original report, and indicated as such, instead of a co mpletely new

test

.

 The original reports should not be stored in WebFIRE but still be available upon request.

 Only final reports should be published if there is a penalty for supplying incorrect information.
Consensus findings : The following consensus was reached regardi ng report re submission:



### 1. Reports that are resubmitted should undergo the same processing period as the superseded submission.


### 2. Notifications sent to reviewers should indicate that the report is a resubmission

. 

### 3. Notifications should also provide traceability to the superseded report and contact information of the individual submitting the report.


### 4. An electronic records trail should be maintained for resubmitted reports.



### 3.4 Data Requirements:

The data requirements question group is intended to determine how best to address the following S/L/T reporting requirements:

 How to capture additional S/L/T data beyond th at required by federal regulation.

 How to identify, or reference, the reports that are received by CEDRI and are available for S/L/T rev iew.

3.4.1 S/L/T Specific Data The data required by state, local

, and tribal agencies varies by S/L/T . The ability to add comments and attach PDF files to reports submitted through CEDRI will accommodate many S/L/T agencies ’ reporting requirements
, but not all . Further more, since the reporting frequency required by the S/L/T agencies does not necessarily correspond with the required federal reporting frequency

, report submission date s need to be time

- stamped for compliance evaluation purposes.8 | P a g e

Interest was expressed by some S/L/T agencies in having CEDRI accommodate S/L/T specific data elements directly in the reporting forms. This type of functionality will require considerably more elaboration and is outside the scope of this IPT. The general requirement though is noted for future consideration.

The use of memo fields and the ability to attach PDF files is necessary, but may not be sufficient for capturing quality assurance checks and data calculations.

Consensus findings : The following conse nsus was reached regardi ng S/L/T specific data requirements:



### 1. Report submission date/time must be captured so S/L/T agencies may determine reporting compliance.


### 2. Memo fields and file attachments are necessary for capturing S/L/T specific information, but may not be sufficient for capturing all S/L/T specific data. Further analysis is required to develop an approach for collecting quality assurance checks, data calculations , and other S/L/T specific data elements

.

3.4.2 Report Identification Allowing the source faci lity to apply a descriptive label to the reports being submitted was determined to be an important feature and would facilitate execution of report searches

. The common practice is to label reports (stack test) by year, quarter, and facility, and having separate metadata for reporting perio d would further enhance report search ing capabilities

.

Reference to the CFR citation, although not typically used by S/L/T, was seen as potentially useful so that cross referencing may be performed

. The Army Corps of En gineers maintains a citation cross

- walk service for statutes in the Clean Air Act which may be utilized to provide cross reference between S/L/T citations and federal

citations.

Consensus findings : The following consensus was reached regardi ng the use of CFR citations to identify reports:



### 1. The CFR citation is of limited use to S/L/T agencies as permit citations and other S/L/T citations are used to identify required reports.


### 2. Further analysis is required to determine access to and the potential for utilizin g the Army Corps of Engineers cross

- walk service.



### 3.5 Data Access
The ability for S/L/T agencies to access report submissions may be provided through CEDRI

, WebFIRE or both

. Th e public may only access reports through WebFIRE and only after the S/L/T agency processing period has elapsed and the reports are transferred from CEDRI.

The data access question group addressed the following elements of data access:



###  Which system should S/L/T agencies use to access reports before they are made publicly available?



###  How should submission notifications be routed to S/L/T reviewers?9 | P a g e



###  Should the S/L/T review results be stored with the report submission and should they be available for public access?



###  What are the preferred alternate formats for ERT Performance Report submissions?

3.5.1 CEDRI versus WebFIRE Access The IPT participants did not have a preference between CEDRI and WebFIRE for accessing reports. Whichever system is used

, however

, must allow access to S/L/T agencies prior to the reports bei ng made publically
available.

Consensus findings : The following consensus was reached regardi ng the system used by S/L/T agencies for accessing report
submissions:



### 1. Although there was not a preference between CEDRI and WebFIRE, the consensus was that publi c access must be restricted until S/L/T agencies have a sufficient amount of time to complete review.

3.5.2 Notifications
The need for notifying S/L/T reviewers that a report has be en submitted through CEDRI and is available for review and processing is underst ood to be necessary to streamline the electronic reporting process

. Email alerts are intended to be used as the mechanism to notify individuals registered as S/L/T Reviewers that a report has been submitted by a facility within their S/L/T of interest.

Although CEDRI does not restrict the number of users who may register in the “State Reviewer” role and does
not restrict the number of S/L/T agencies any given reviewer may register to access, alerts are typically not configurable at the level of granulari ty necessary to fully support S/L/T review operations

. Although the criteria used to assign reports for review varies among the S/L/T agencies

, a few criteria emerged that were common. Common criteria used to assign and route reports for review include fac ility and type of report (Stack Test, Emissions, etc.). Other less common criteria were also identified such as whether the facility is under an enforcement action or the industry sector to which the facility operates (NAICS code).

Registration for the “S tate Reviewer” role will utilize the closed registration process in CDX, meaning the CDX support staff will initiate the registration process and the registrant will complete the process. Within the closed registration process reviewers may be registered t o review reports from multiple S/L/T agencies

. Consensus findings : The following consensus was reached regarding notification of submissions:



### 1. An email alert and a message in the CDX Inbox would be the best way to notify reviewers that a report has been submitted and is available for review and processing.


### 2. It is feasible for S/L/T agencies to identify the personnel who will be conducting reviews . This will facilitate the closed registration process. 

### 3. Providing notification of submission s based on report type and/or facility to specific reviewers is a desirable feature.10 | P a g e



### 4. Facilities should be identified by both the Facility Registry System ( FRS ) an d the Air Facility System ( AFS ) 1 number s as AFS number is the identifier most commonly used at the state/local /tribal level. FRS number is not commonly used.

3.5.3 Review File Ac c ess The ability to include review files with a submitted report was generally agree d to be a necessary feature. A
standardize d review file template to minimize the variability in review comments was also thought to be a necessary feature. Inclusion of S/L/T specific requirements was stated as necessary by some participants. To

accom modate both standardization and S/L/T specific requirements, a baseline template with the ability to attach additional material was determined to be sufficient to meet review requirements.

It was agreed that review files should be stored along with the sub mitted reports and be available for public viewing.

Consensus findings : The following consensus was reached regardi ng S/L/T review comments:



### 1. S/L/T review comments should be retained and stored with the report submission.


### 2. S/L/T review comments should be ma de publicly accessible.


### 3. A standardized review file template should be developed.


### 4. The ability to attach S/L/T specific review files to a report submission (or to a standardized review file template) should be supported.

3.5.4 Alternate ERT Formats
The ERT
, used to report stack test results

, is the collection mechanism used by the current CEDRI application and will be used by the new CEDRI application. It is understood that alternate formats may be more efficient and preferred by S/L/T agencies

.

IPT consensus was that the current Microsoft Access Database did not provide transparency in the underlying equations which made it difficult to audit calculations

. Use of an Excel spreadsheet was suggested as a means of making the equations more transparent. Excel however, was thought to provide less security , thereby allowing potential manipulation of the underlying equations.

HTML5 was also suggested as an implemen tation approach to support both on

- line and off

- line completion of
reports.

Defining and publishing an XML schema was seen as a necessary element regardless of implementation approach

. A published schema allows testing companies to configure their test pro grams to produce output reports in a compliant format and supports quality assurance checks on the data contained in the reports. EPA
should focus on defining the data required rather than on trying to develop a system that satisfies all industry participa nts. Furthermore, EPA is actively pursuing a web

- based ERT.

1 AFS is scheduled to b e replaced by ICIS

- Air in September 2014. Therefore, any reference to AFS should assume reference
to ICIS

- Air Program ID after implementation

.11 | P a g e

Consensus findings :
The following consensus was reached regardi ng alternatives to the ERT:



### 1. An XML schema with business rules should be published that defines required data elements.


### 2. S/L/T agencies and other third parties may develop the ir own systems to produce compliant test report
data.



## 4 Guidance and Recommendations

IPT consensus findings are summarized by question group in Exhibit 4

- 1 . These findings will be used by EPA to develop the functional requirements for the CEDRI application

.

Exhibit 4

- 1 CEDRI IPT Consensus Findings Summary

Question Group Topic Finding Data Flow Processing Time 

### 1. ERT Performance Reports

– The typical review period for ERT Performance Reports was determined to be 120 day s. 

### 2. Air Emissions Reports

- IPT participants suggested a processing period of 30 days to be sufficient

. 

### 3. Notification Reports

– 30 days was determined to be an appropriate period of time.

Data Resubmission Data Resubmission 

### 1. Reports that are resubmitted should undergo the same processing period as the superseded submission. 

### 2. Notifications sent to reviewers should indicate the report is a resubmission

. 

### 3. Notifications should provide traceability to the superseded report and contact information of the individual submitting the report. 

### 4. An electronic records trail should be maintained for resubmitted reports.

Dat a Requirements S/L/T Specific Data 

### 1. Report submission date/time must be captured so S/L/T agencies may determine reporting compliance. 

### 2. Memo fields and file attachments are necessary for capturing S/L/T specific information, but may not be sufficient for
cap turing all S/L/T specific data.12 | P a g e

Question Group Topic Finding

Report Identification 

### 1. The CFR citation is of limited use to S/L/T agencies as permit citations and other S/L/T citations are used to identify required reports.
Data Access CEDRI/WebFIRE 

### 1. Although there was not a preference between CEDRI and WebFIRE, the consensus was that public access must be restricted to all report ing types until S/L/T review is complete. Notifications 

### 1. An email alert and a message in the CDX Inbox would be the best wa y to notify reviewers that a report has been submitted and is available for review and processing. 

### 2. It is feasible for S/L/T agencies to identify the personnel who will be conducting reviews. This will facilitate the closed registration
process. 

### 3. Providing notification of submission based on report type and/or facility to specific reviewers is a desirable feature. 

### 4. Facilities should be identified by both FRS and AFS number as AFS number is the identifier most commonly used at the state/local level. FRS number is not commonly used. Review File Access 

### 1. State review comments should be retained and stored with the report submission. 

### 2. State review comments should be made publicly accessible. 

### 3. A standardized review file template should be developed. 

### 4. The ab ility to attach S/L/T specific review files to a report submission (or to a standardized review file template) should be supported. ERT Alternatives 

### 1. An XML schema should be published that defines required data elements. 

### 2. Industry can develop the systems to produce compliant test report data.