Poking Holes In Your Electronic Compliance Report

So maybe you’re one of the many facilities who are now subject to electronic reporting requirements under a 40 CFR Part 60 (NSPS) or Part 63 (NESHAP) rule.  Perhaps even this past year was your first time having to submit your semi-annual or annual compliance report via the U.S. EPA Compliance and Emissions Data Reporting Interface (CEDRI).  If either of these sounds like you, you may have also had your fair share of questions or issues while reporting, especially if your compliance report involved reporting continuous monitoring system (CMS) data.

While assisting my clients, I’ve learned that some of these questions don’t have a straightforward answer or even published guidance, so they can be left to individual interpretation.  That means that your approach for completing some of the ambiguous CEDRI forms may not be interpreted by others the way you intended them to be.  Keep in mind that submitted reports are as easy to access on U.S. EPA’s WebFIRE database as a simple point and click, so it’s easy for an inexperienced viewer to download your data in an attempt to poke holes in what you reported.  So how confident are you with the way your data is represented online?

ALL4 has completed and reviewed many compliance reports across different industries, and I’ve summarized some common “holes” and potential solutions or strategies below:

Reporting “0” for CMS averaging data during process down

Although the CEDRI form to submit monitoring data may seem like a numerical value needs to be input for each averaging period (e.g., each day), if the process was down, entering a “0” can lead to misinterpretation of your data by regulators and non-governmental organizations.  Instead, you can leave the data fields blank and add a comment explaining why the field is blank.

Change of an operating limit in the middle of a reporting period without differentiating that in your CMS averaging data

This one can be a little tricky since the CEDRI form for CMS only allows you to enter in one operating limit.  However, if your operating limit was re-established in the midst of the reporting period (especially if your limit was lowered), then your data could be misinterpreted and improperly compared against the wrong limit.  One way to minimize this confusion is to visually break up your data by leaving a blank line between the dates where the limit switched.  This should also be accompanied by a comment to the reviewer noting the change in operating limit.  Furthermore, be sure that you define the end date for the previous limit, the begin date, including the date of the first valid compliance average for the re-established limit, and any gaps in data that may occur as the compliance average was being “built”.

Reporting CMS data for monitors not required

This is very rule dependent.  However, it is important to read the applicable regulation as well as supporting guidance for your industry thoroughly before submitting your report.  In some cases, the CEDRI form may prompt you to submit CMS averaging data but under the rule, a particular CMS may be exempt from this requirement (e.g., PC NESHAP dioxin/furan temperature averages).  If you are prompted with a form to report CMS averaging data for a CMS in which it is not required, you can leave the form blank and add a comment to the reviewer justifying the blank form.

These are just a few of the common “holes” we’ve seen in electronically submitted reports.  My advice is to always review your reports asking the question “How would someone with no understanding of my facility interpret this report?”  Maybe even have an experienced third party review your report.  The U.S. EPA “NextGen” strategic plan includes expanded transparency.  Expanded transparency leads to increased scrutiny.  It’s your data, be accountable for it.

If you have any questions about specific rule requirements or how to complete CEDRI reports, please contact me at kturney@all4inc.com or (610) 933-5246 x143.