Electronic Reporting for the Secondary Aluminum Industry

As Chuck described in his January blog, the Subpart RRR amendments include provisions requiring that performance test data to be electronically submitted through the U.S. Environmental Protection Agency (U.S. EPA) Electronic Reporting Tool (ERT).  While E-reporting might seem like an easy option at face value, we have found that the ERT is anything but user friendly.

So what do you actually have to do?

The rule requires that performance tests (including any associated fuel analyses) [40 CFR §63.1516(b)(3)(i)(A)] be submitted to U.S. EPA using the ERT.  This does not mean just attaching a PDF copy of your test report or submitting your results – the ERT requires a whole host of information, including but not limited to the following:

• Test plan (must be completed before test results can be reported)
• Sampling location information
• Control device parameters
• Calibration gas concentrations
• Process data

Results must be submitted through ERT within 60 days after completing the performance test, so make sure to plan ahead!

If you have any questions or need help using ERT or CEDRI, please contact me at kturney@all4inc.com or (610) 933-5246 x143.