How Electronic Reporting is Shaping Our Regulations

This article is available as a podcast episode on ALL4’s Air Quality Insider

I recently published a blog about the Portland Cement (PC) National Emission Standards for Hazardous Air Pollutants (NESHAP) Residual Risk and Technology Review (RTR). Being ALL4’s Continuous Monitoring Systems (CMS) Focus Area Leader, I found a few aspects of U.S. EPA’s publication intriguing from a CMS perspective and wanted to share those aspects in this blog.

U.S. EPA is required to review the technology-based standards (i.e., NESHAPs) and revise them ‘‘as necessary’’ no less frequently than every eight years. The historical completion of these reviews often required the U.S. EPA to submit data collection and emissions testing requests to the regulated industry. The U.S. EPA then used the information provided by the industry to complete their required analysis.

What data collection activities were conducted to support the most recent PC NESHAP RTR?

None. U.S. EPA did not submit data collection requests to the industry nor did they request emissions testing by the industry.

Where did the data used in the RTR come from?

All PC manufacturers are required to report their greenhouse gas emissions to the EPA annually. Consequently, U.S. EPA relied upon a comprehensive list of facilities and kilns compiled from the Greenhouse Gas Reporting Program (GHGRP).

The PC NESHAP requires affected facilities to submit performance test results to the U.S. EPA via the Compliance and Emissions Data Reporting Interface (CEDRI), which is accessed through U.S. EPA’s Central Data Exchange (CDX). Information concerning operating hours, stack parameters, and stack locations are examples of the data that is recorded and made publicly available through the U.S. EPA’s CDX.

How were the emissions data used in the RTR developed?

Emissions data are electronically reported by the PC industry in units of pounds per hour (lb/hr), allowing U.S. EPA (or any interested party) to easily calculate ton per year (tpy) emissions for sources and facilities. Actual emissions data were developed by the U.S. EPA using facility operating hours, which are also reported by facilities electronically on a semi-annual basis.

Pursuant to U.S. EPA’s Next Generation Compliance, Strategic Plan (2014-2017) “EPA policy now states that e-reporting is the default assumption for new regulations”. With electronic systems being used in modern day for almost every kind of transaction, it only makes sense for U.S. EPA to shift away from the outdated manual collection and evaluation towards more efficient electronic solutions.

Electronic reporting is changing how Environmental Managers customarily operate. New risks and liabilities are sometimes associated with these changes. If you have a role in electronic compliance reporting, take time to ensure that your report provides the information needed to tell the reader the story you intend to tell, because the data may be used for a purpose you did not intend.

Feel free to contact me if you would like to discuss anything related to continuous monitoring (e.g., CEMS, COMS, CPMS). My contact information is (610) 933-5246, extension 120 or jkleinle@all4inc.com.