Electronic Reporting: Great in Theory

As Sean described in his August blog, U.S. EPA has promulgated several regulations which require electronic reporting (“E-Reporting”) through its Compliance and Emissions Data Reporting Interface (CEDRI).  E-Reporting is applicable to various rules that fall within 40 CFR Part 60 [New Source Performance Standards (NSPS)] and 40 CFR Part 63 [National Emission Standards for Hazardous Air Pollutants (NESHAPs)] and is used for reporting test results, monitoring data, compliance reports, and/or emissions reports.  Below are a few examples of regulations with pressing upcoming deadlines for E-Reporting; however, there is a litany of other deadlines that aren’t far behind.

• 40 CFR Part 63, Subpart S (NESHAPs from the Pulp and Paper Industry)
• 40 CFR Part 63, Subpart LLL (NESHAPs from the Portland Cement Manufacturing Industry)
• 40 CFR Part 63, Subpart DDDDD (NESHAPs for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters)
• 40 CFR Part 63, Subpart HHHHHHH (NESHAPs for Polyvinyl Chloride and Copolymers Production)

You might be thinking that the notion of E-Reporting and submitting data through an electronic interface seems pretty similar to other U.S. EPA programs and, if you’ve realized the day and age we’re in, it is likely something you couldn’t help but expect to come down the pike at some point or another.   However, “some point or another” is upon us, and for many facilities subject to NSPS and/or NESHAPs, the time to come up with a game plan for E-Reporting is now.

So, where do you start?

In order to access CEDRI, you first have to create an account through U.S. EPA’s Central Data Exchange (CDX).  If you need to submit a performance test report, you will need to download and complete the Electronic Reporting Tool (ERT).  Hint: the whole “three acronyms per one submittal” thing does not usually indicate a straightforward task.

The ERT is a Microsoft Access based program that, like most new applications, has a few (or more) quirks and caveats that you need to know in order to make the program function properly.  Luckily for you, ALL4 has been working with several of our clients, U.S. EPA, and the National Council for Air and Stream Improvement (NCASI) to hone our ERT expertise and learn how to handle these issues.  We have also registered multiple accounts within CDX so we are at the ready if you find you need help navigating the process.  Feel free to reach out to me at mgreene@all4inc.com or 678-460-0324 x213 or any of the other members of the CDX team (Hailey, Kayla, and Sean) with any questions!