The End of the CEDRI Webform

For several key 40 CFR Part 60 [Standards of Performance for New Stationary Sources, also referred to as New Source Performance Standards (NSPS)] and 40 CFR Part 63 [National Emission Standards for Hazardous Air Pollutants (NESHAP), also referred to as Maximum Achievable Control Technology (MACT)] regulations, the Compliance and Emissions Data Reporting Interface (CEDRI) “optional” bulk upload templates are officially removed.  As of September 24, 2020, the U.S. Environmental Protection Agency (U.S. EPA) Central Data Exchange (CDX) no longer supports the CEDRI webform reporting interface that many facilities have relied on to fulfill their compliance reporting obligations.  Read on to see how this could impact your facility.

Who This Affects

The following regulations are affected by this change:

• 40 CFR Part 60, Subpart IIII (NSPS for Stationary Compression Ignition Internal Combustion Engines)
• 40 CFR Part 60, Subpart JJJJ (NSPS for Stationary Spark Ignition Internal Combustion Engines)
• 40 CFR Part 63, Subpart LLL [NESHAP From the Portland Cement Manufacturing Industry (PC MACT)]
• 40 CFR Part 63, Subpart ZZZZ [NESHAP for Reciprocating Internal Combustion Engines (RICE MACT)]
• 40 CFR Part 63, Subpart DDDDD [NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (Boiler MACT)]

ASK HOW ALL4 CAN HELP YOU NAVIGATE THIS NEW REPORTING LANDSCAPE

The Bulk Upload Templates (Excluding Boiler MACT)

With the exception of Boiler MACT, the “bulk upload templates” for the above listed regulations are fairly comprehensive.  ALL4 recommends facilities that have previously utilized the CEDRI webform compare the new templates to their historical CEDRI webform printouts.  This is best practice to ensure consistency and completeness in reporting as facilities transition from the webform to the new templates.  Because each template also allows facilities to upload a separate file with additional information, it is also important for facilities to review the text of the regulation and any supplemental information that has previously been provided.  This is the best way to verify a facility has fulfilled its reporting requirements.

The Boiler MACT Bulk Upload Templates

Unfortunately for facilities who report under the Boiler MACT, the “bulk upload templates” are substantially less intuitive than the templates for other regulations.  To start, each required report for a Boiler MACT subpart has its own “bulk upload template” to be populated.  For instance, a facility that must comply with both the Boiler MACT tune up [40 CFR §63.7550(c)(1)] and fuel analysis [40 CFR §63.7550(c)(2)] reporting requirements must populate the appropriate template for each when submitting the semiannual compliance report.  Previously, both sets of reporting requirements were able to be submitted under a single webform.  Now, two separate reports must be submitted to cover each set of requirements.

For each “template”, the required information is as follows:

• Facility Name
• Facility Address
• Company Name
• The filename for the report itself

That last bullet point might raise a red flag in your brain.  If it feels like there is something missing here, that is because there definitely is.  It may come as a surprise, but the new Boiler MACT templates provide almost no help whatsoever when it comes to populating facility compliance data into a report.

“Do It Yourself” Boiler MACT Reporting

Unlike the CEDRI webform, the Boiler MACT bulk upload templates provide no guidance whatsoever on the specifics of reporting.  They do not walk through the requirements and prompt the user for the necessary information like the webforms did.  Instead, the bulk upload template simply requires the user to attach a file containing required data.  As such, each facility is responsible for formatting and compiling its own reports.  For facilities who have historically relied on the CEDRI webform as a guide for what information is required, this could mean significantly more reporting effort may be necessary to produce and populate new internal reporting templates.

Steps to Developing a Boiler MACT Report

ALL4 recommends the following approach for developing a Boiler MACT reporting template from scratch:

1. 1.  Start with the text of the rule

This is absolutely the best resource for ensuring completeness in reporting what is required.  For each report, lay out the actual text of each requirement in a table, and provide responses to each.

1. 2.  Gather supplemental information

For some reporting requirements, it is either impossible or impractical to include complete information in the main table from Step 1 due to the shear volume of information required (e.g., CEMS summary table for CMS reporting requirement [40 CFR §63.7550(c)(2)]).  In these cases, it may be necessary to develop a supplemental table and provide reference to it in the main reporting template.  U.S. EPA maintains some templates for supplemental information on their main CEDRI page.

1. 3.  Use historical reporting resources

Although the CEDRI webform is no longer supported for future reporting, historical webform submission printouts can provide some guidance on how to format the new report.  However, be careful when using these historical printouts as they may not reflect the current version of the regulation.  The text of the specific rule and associated applicable requirements dictate what is required.

1. 4.  Build in redundancy

Under the new bulk upload requirement, an individual facility may be required to prepare multiple reports for a single emissions unit.  Expect overlap in the requirements for these reports and ensure each one can be viewed by a regulator or the public as a independent documents.

If you have any questions regarding bulk upload template reporting, please contact us.