Workshop T Regulatory Whirlwind: Priceless Insights on the Numerous - - PDF document

Workshop T

Regulatory Whirlwind: Priceless Insights on the Numerous U.S. EPA’s MACT Standards for Hazardous Air Pollutants … a Flurry of Risk and Technology Reviews

Tuesday, March 24, 2020 3:30 p.m. to 4:45 p.m.

Biographical Information

Joanne Reinhold, Sr. Environmental Manager GE Aviation 1 Neumann Way, Cincinnati, OH 45215 513-638-2333 joanne.reinhold@ge.com Joanne is the Sr. Environmental Manager for the GE Aviation plant in Evendale, OH. At GE Aviation, Joanne is responsible for regulatory compliance for the environmental programs, including air permitting, water programs, waste management, and remedial

• programs. Joanne has been with GE for approximately 9 years. Prior to joining GE,

Joanne worked as an engineering consultant for various industrial companies specializing in air compliance and permitting. Joanne is a graduate of the University of Cincinnati with a B.S. In Chemical Engineering. DJ Wheeler, Managing Consultant Trinity Consultants 110 Polaris Parkway, Suite 200, Westerville, Ohio 43082 614.433.0733 Fax: 614.433.0734 dwheeler@trinityconsultants.com

• Mr. Wheeler provides air quality permitting and compliance services for industries such

as oil and gas, metallurgical coke production, secondary aluminum recycling, petroleum refineries, steel mini-mills, and gas-fired electricity generating units. He has provided specialized stack testing and CEMS support to numerous clients including overseeing performance tests, coordinating RATAs, reviewing test reports, and auditing CEMS data.

• Mr. Wheeler currently operates as a Managing Consultant in Trinity’s Columbus, Ohio
• ffice.

He received a Bachelor’s degree in chemical engineering from the University of Michigan.

MEC Workshop T U.S. EPA Risk and Technology Reviews for Hazardous Air Pollutants

Cincinnati, OH –March 24, 2020

DJ Wheeler –Trinity Consultants, Inc. Joanne Reinhold – GE Aviation

Status of EPA NESHAP RTRs

˃ EPA required to conduct RTR periodically per the Clean Air Act ˃ RTR deadline has passed for several NESHAP rules ˃ EPA could, at any time, elect to move forward with RTR

rulemaking, or be forced to do so by court order



Such as the citizen suit filed in April 2015 for failure to complete RTR for several NESHAPs ˃ EPA has put out 20 rule proposals in 2019



Most with no changes or minor updates



All rule proposals update startup, shutdown, and malfunction language

♦ Maintenance vents are now subject to emission standards. ♦ EPA proposed work practices for maintenance vents in some cases.



Many include updates for electronic reporting

˃ California Communities Against Toxics v. E. Scott Pruitt



“[EPA’s] justifications for its inability to meet their timeline are too vague; citing other obligations but failing to describe what they are, what type of resources they consume, and whether they could be delayed to prioritize the RTR rulemakings at issue.”

˃ Blue Ridge Environmental Defense League v. Scott

Pruitt



“…the Clean Air Act makes clear that Congress contemplated that the EPA could promulgate dozens of air toxics rules in a condensed amount of time.”

˃ Community In‐Power and Development Association,

• Inc. v. E. Scott Pruitt



“[EPA] must at least try to make a persuasive claim that it is currently so cash strapped that it cannot possibly start the mandated reviews…”

Regulatory Deadlines

Not Just an Industry Headache!

Source Category Latest Action Date Status

• Misc. Organic NESHAP (MON)

12/17/2019 Proposed Organic Liquids Distribution (OLD MACT) 10/21/2019 Proposed Ethylene Production 10/9/2019 Proposed Taconite Iron Ore Processing 9/25/2019 Proposed Paper and Other Web Coating 9/19/2019 Proposed Lime Manufacturing Plants 9/16/2019 Proposed Cellulose Products Manufacturing 9/9/2019 Proposed Plywood and Composite Wood Products Manufacture 9/6/2019 Proposed Miscellaneous Coating Manufacturing (MCM) 9/4/2019 Proposed Site Remediation 9/3/2019 Proposed Automobiles and Light‐Duty Trucks, Miscellaneous Metal Parts, Plastic Parts Coatings 11/1/2019 Proposed Integrated Iron and Steel Manufacturing 8/16/2019 Proposed Iron and Steel Foundries 10/16/2019 Proposed Rubber Tire Manufacturing 10/30/2019 Proposed Municipal Solid Waste Landfills 2/25/2020 Final Solvent Extraction for Vegetable Oil Production 2/25/2020 Final Surface Coating of Metal Cans and Metal Coil 2/25/2020 Final Boat Manufacturing and Reinforced Plastics Composites Production 2/25/2020 Final Engine Test Cells/Stands 5/8/2019 Proposed Asphalt Processing and Asphalt Roofing Manufacturing 1/30/2020 Final Stationary Combustion Turbines 1/31/2020 Final Hydrochloric Acid Production (HCl MACT) 2/4/2019 Proposed

Remaining RTRs

˃

EPA has yet to complete the RTR for the following sources:

Source Category Consent Decree or Court Ordered Date for Signature of Final Rule Mercury Emissions from Mercury Cell Chlor‐Alkali Plants 10/1/2021 Semiconductor Manufacturing 10/1/2021 Generic MACT II ‐ Cyanide Chemicals Manufacturing 10/1/2021 Generic MACT II ‐ Spandex Production 10/1/2021 Generic MACT II ‐ Carbon Black Production 10/1/2021 Primary Copper Smelting 10/1/2021 Flexible Polyurethane Foam Fabrication Operations 10/1/2021 Refractory Products Manufacturing 10/1/2021 Primary Magnesium Refining 10/1/2021

2 4 6 8 10 12 14

30 60 90 120 150 180 210 240 270 300 330 360 390 420 450 480 510 540 570 600 630 660 690 720 750 780 810 840 870 900 930 960 990 1020 More

Frequency Days from Proposed Rule to Final Publication

The graph shows the days taken for the final publication of a rule from the day it was proposed. The average time for a rule to be finalized is about 300 days from the publication of the proposed rule.

All RTR Proposals

SSM Revisions: Comply At All Times

˃ Removal of startup, shutdown and malfunction (SSM)

blanket exemptions from emission control standards.

˃ Sources are expected to comply with emission limits

and work practice standards during all emission generating periods, including startup / shutdown.

˃ Work Practice Standards for Malfunctions and

Maintenance.

˃ The requirement for SSM Plans are completely

removed, along with associated SSM recordkeeping and reporting

˃ Detailed records for events associated with each

failure to meet an applicable standard – including impacted equipment & HAP emitted, estimation methodology

All RTR Proposals

SSM Revisions: Comply At All Times

Malfunction Records and Enforcement Discretion

“The EPA is also proposing to add…a requirement that sources keep records that include a list of the affected source or equipment and actions taken to minimize emissions, an estimate of the quantity of each regulated pollutant emitted over the standard for which the source failed to meet the standard, and a description of the method used to estimate the emissions. Examples of such methods would include product loss calculations, mass balance calculations, measurements when available, or engineering judgment based on known process parameters. The EPA is proposing to require that sources keep records of this information to ensure that there is adequate information to allow the EPA to determine the severity of any failure to meet a standard, and to provide data that may document how the source met the general duty to minimize emissions when the source has failed to meet an applicable standard. “ [84 FR 56320‐56321]

All RTR Proposals

Electronic Reporting (CEDRI)

˃ US EPA is incorporating requirements for electronic

data submittal through US EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) into all recent regulatory actions.

˃ Such reporting requirements thus far have included:



Submittal of NESHAP Performance Test Reports



Submittal of Fenceline Monitoring Reports



Semiannual NESHAP Initial and Semi-Annual Compliance Reports ˃ All RTR amendments, across all source categories, are

incorporating some level of CEDRI reporting, and NESHAP regulated sources can expect to eventually use CEDRI for all US EPA reporting submittals.

MON RTR Proposal

MON RTR Proposal Overview

˃ Removal of SSM Provisions ˃ Addition of work practice standards for periods of SSM

 Certain “Subset” of Flares – EO, olefins, polyolefins  PRDs  Maintenance Vents

˃ Clarification of provisions for certain vent control

bypasses

 Closed vent systems containing bypass lines  Flares connected to fuel gas systems

˃ Equipment Leaks – Lower thresholds ˃ Heat Exchange Systems – Modified El Paso Method

MON RTR Proposal Overview

˃ Monitoring and operational requirements for

flares used as APCDs that control:



Ethylene oxide emissions



Olefins production and polyolefins production;



Allow option for flares outside of this category to “opt in” in lieu of compliance with current flare standards.

˃ Electronic reporting of performance test results

and reports, performance evaluation reports, and compliance reports

MON RTR Proposal Overview

˃ Specific Requirements for MCPUs with ethylene oxide

(EO)



LDAR



Process Vents



Storage Tanks



Fuel Gas Systems



Scrubber Monitoring

MON MACT RTR

Flare Requirements

˃ Refinery sector data suggest that general flare provisions do

not guarantee 98% destruction efficiency



Over-steaming



Low-load conditions

˃ New requirements for “subset” flares



Net heating value of combustion zone ≥ 270 Btu/scf

♦ Net heating value dilution parameter ≥ 22 Btu/square foot for perimeter assist air



Consolidated tip velocity equation for steam-, air-, and non-assisted flares



Pilot considered extinguished if absent for 1 minute in a 15-min block



Five-minute Method 22 observations

♦ Once each day that flare receives regulated material ♦ Whenever visible emissions occur while flaring regulated material ♦ Surveillance cameras may be used in lieu of the daily observations ♦ Extend observation period to 2 hours if emissions occur for >1 min in 5 min period

MON MACT RTR

Flare Requirements

˃ Flare management plan for “subset” flares



Identify procedures for limiting discharges as a result of process upsets or malfunctions

˃ Root cause analyses for “subset” flares



Triggered if smokeless design capacity is exceeded and either…

♦ VE limit is exceeded ♦ Flare tip velocity limit is exceeded



Take corrective action to prevent recurrence



Events caused by operator error poor maintenance are prohibited



No more than 1 triggering event with the same root cause from the same equipment in any rolling, 3-year period

♦ Force majeure events are excluded from this analysis



No more than 2 triggering events from the same flare in any rolling, 3- year period for any reason

MON MACT RTR

Pressure Relief Devices

˃ PRDs vented to control devices



Comply with existing MON requirements for closed vent systems and control devices

˃ PRDs vented to atmosphere



Parametric monitoring system to indicate time/duration of releases



No more than 1 release with the same cause from a single PRD in a 3- year period



No more than 2 releases from a single PRD in a 3-year period



Releases attributable to operator error or poor maintenance are prohibited



Releases attributable to force majeure do not count against the allowable 2-3 events per 3-year period



Exemptions for certain PRDs

♦ PRDs with design release pressure < 2.5 psig ♦ PRDs in heavy liquid service ♦ PRDs designed solely to release due to liquid thermal expansion ♦ Pilot operated and balanced bellows PRDs if primary release valve is vented to

controls

MON MACT RTR

Maintenance Activities

˃ Prior to opening process equipment to atmosphere…



Reduce VOC that may be released to less than 50 lbs, or



Drain and purge to a closed vent system, and



Achieve a hydrocarbon concentration ≤ 10% LEL

♦Alternatively, if 10% LEL cannot be achieved, equipment may be

• pened if the pressures is ≤ 5 psig

˃ If installation of blind flange prohibits compliance, then…



Depressurize to 2 psig prior to opening, and



Maintain at 2 psig during blind flange installation

MON MACT RTR

Ethylene Oxide Process Vents and Tanks

˃ Reduce EO emissions from process vents by…



Achieving 99.9% control or 1 ppmv for each process vent, or



Achieving < 5 pounds per year for all combined vents, or



Vent to flare meeting “subset” requirements ˃ Reduce EO emissions from storage tanks by…



Achieving 99.9% control or 1 ppmv for each process vent, or



Vent to flare meeting “subset” requirements

˃ Initial and periodic (every 5 years) testing for non‐flare

control devices

MON MACT RTR

Ethylene Oxide Equipment Leaks

˃ Option 1



Light liquid pumps – monitor monthly at 1,000 ppm leak def.



LL/GV connectors – monitor annually at 500 ppm leak def. ˃ Option 2 for Max Individual Risk > 100/1,000,000



Pumps must be leakless and monitored annually at 0 ppm above bkg.



Valves must be either…

♦ Leakless and monitored annually at 0 ppm above bkg., or ♦ Monitored quarterly at 0 ppm above bkg.



Connectors must be monitored monthly at 100 ppm leak def.

MON MACT RTR

Non-EO Equipment Leaks

˃ Option 1



Increase stringency for light-liquid pumps at existing batch processes



Monitor monthly at 1,000 ppm leak def. ˃ Other more stringent Options (2‐4) considered cost

infeasible

MON MACT RTR

Heat Exchange Systems

˃ Quarterly monitoring using Modified El Paso Method at

leak definition of 6.2 ppmv

˃ Delay of repair action level of total strippable hydrocarbon

concentration in the stripping gas of 62 ppmv



Repair immediately if exceeded

˃ Re‐monitor at original leak location to confirm repair ˃ Systems with ≤ 10 gpm cooling water flow exempt

OLD MACT RTR Proposal

OLD MACT RTR Proposal

SSM

˃ Removal of safety device opening allowance of 40 CFR

63.2346(i) beginning 3 years after publication of the final rule.

˃ Removal of 240 hr/yr planned routine maintenance

allowance for storage tanks and transfer racks working losses.

˃ Removal of 240 hr/yr bypass of fuel gas system or

process allowance for storage tanks and transfer racks working losses.

OLD MACT RTR Proposal

Flares

˃ Flares – Direct application of petroleum refinery flare rule

requirements of 40 CFR 63, Subpart CC (63.670 / 63.671 and Tables 12/13) with some clarifications.



Similar to MON RTR for “subset” flares

˃ No work practice standards for emergency flaring – not

needed.

OLD MACT RTR Proposal

LDAR

˃ Addition of connectors to the monitored equipment

component types at a leak definition of 500 ppm



(i.e., requiring connectors to be compliant with either 40 CFR part 63, Subparts UU or H).

OLD MACT RTR Proposal

Storage Tanks

˃ Revision of average true vapor pressure thresholds

• f the OLD storage tanks for existing sources

requiring control to align with those of the Refinery MACT (40 CFR part 63, subpart CC) and the HON (40 CFR part 63, Subpart G) where the thresholds are lower; and

˃ Requiring leak detection and repair (LDAR) using

Method 21 with a 500 ppm leak definition for fittings on fixed roof storage vessels (e.g., access hatches) that are not subject to the 95 percent by weight control requirements.

OLD MACT RTR Proposal

Other Changes

˃ Testing to confirm the annual average true vapor

pressure at least every 5 years, or with a change of commodity in the tank’s contents, whichever occurs first

˃ Significant changes to allowed performance test

methods

OLD MACT RTR Proposal

Fenceline Monitoring Alternative

˃ Fenceline monitoring option available to existing

and new OLD facilities in lieu of implementing certain requirements for storage vessels and equipment leaks.

˃ OLD operations located at facilities that are

required to implement a fenceline monitoring program under the Petroleum Refinery NESHAP at 40 CFR part 63, subpart CC not eligible to use this alternative compliance option.

˃ Reported monitored data to be publicly available

OLD MACT RTR Proposal

Fenceline Monitoring Alternative

˃ Exempted from:



Connector monitoring for equipment leaks,



Annual inspections on storage tank closures on fixed roof tanks,



Controls for storage tanks between 20,000 and 50,000 gallons

Ethylene MACT RTR Proposal

Ethylene MACT RTR Proposal

˃ Direct application of petroleum refinery flare rule

requirements of 40 CFR 63, Subpart CC (63.670 / 63.671 and Tables 12/13) with some clarifications in 63.1103(e)(4)

˃ Changes to Heat Exchanger (Modified El Paso

Method) and Storage Vessel Control Requirements (lower thresholds for control)

˃ Removal of BWON Exemption

Site Remediation RTR Proposal

Site Remediation RTR

Pressure Relief Devices

˃ PRDs vented to control devices



Comply with existing MACT GGGGG requirements for closed vent systems and control devices

˃ PRDs vented to atmosphere



Parametric monitoring system to indicate time/duration of releases



No more than 1 release with the same cause from a single PRD in a 3- year period



No more than 2 releases from a single PRD in a 3-year period



Releases attributable to operator error or poor maintenance are prohibited



Releases attributable to force majeure do not count against the allowable 2-3 events per 3-year period



Exemptions for certain PRDs

♦ PRDs in heavy liquid service ♦ PRDs designed solely to release due to liquid thermal expansion ♦ Pilot operated and balanced bellows PRDs if primary release valve is vented to

controls

Site Remediation RTR

Control Evaluations

˃ Increasing control efficiency from 95% to 98%

determined to be cost infeasible

˃ Increased stringency for LDAR requirements



Comply with MACT UU for pumps and gas/vapor, light liquid valves



Leak definition for gas/vapor, light liquid valves = 500 ppm



Leak definition for pumps = 1,000 ppm



Connector monitoring determined to be cost infeasible

MCM RTR Proposal

Miscellaneous Process Coatings MACT RTR

SSM Changes

˃ Bypasses (including opening of safety devices) must be

included in calculations of emission reduction provisions for process vessels in Table 1 or reported as emissions deviations.

Miscellaneous Process Coatings MACT RTR

Table 11

˃ Table 11: OHAP that must be included in calculated total

OHAP content if present at 0.1% or greater.



Includes all compounds categorized by EPA’s Prioritized Chronic Dose Response Values for Screening Assessments (5/9/14) as a “human carcinogen, probable or possible human carcinogen”

Miscellaneous Process Coatings MACT RTR

˃ Performance Testing



5 year cycle for periodic testing of control devices (except condensers)

Integrated Iron and Steel RTR Proposal

Integrated Iron and Steel RTR

Control Evaluations

˃ Upgrading blast furnaces to include ventilated

baghouses considered cost infeasible

˃ Requesting comment on feasibility of dioxin/furan

controls for sinter plants



Urea injection



Windbox exhaust gas recirculation



Post-exhaust windbox chemical spray



Elimination of certain inputs (e.g., ESP dust)

˃ No developments in practices, processes, or control

technologies for fugitive sources

Integrated Iron and Steel MACT

Mercury Limits

˃ Proposed separately from RTR in response to Sierra

Club petition

˃ Emission limitation for basic oxygen processing

furnaces



Existing units: 0.00026 lb Hg per ton of scrap input



New units: 0.00008 lb Hg per ton of scrap input

˃ Demonstrate compliance using one of two options



Annual stack test, or



Certify that all scrap either…

♦ Originates from the National Vehicle Mercury Switch Recovery Program

participants,

♦ Originates from participants in a similar program approved by the agency, or ♦ Is unlikely to contain mercury.

Final MSW Landfill RTR

MSW Landfill RTR

Control Evaluations

˃ Determined three recent developments in control

technology are cost infeasible



Disposal restrictions to reduce HAP formation within landfill



Increase collection of landfill gas (LFG) through earlier installation

• f gas collection and control systems (GCCS)



Improve destruction efficiency by treating collected LFG in enclosed flares, thermal oxidizers, or turbines

˃ New work practice standard for GCCS downtime events



Shut down gas mover system and close all valves in the collection and control system contributing to gas venting within 1 hour



Complete repairs to GCCS as expeditiously as practicable



Compliance with this work practice standard does NOT necessarily fulfil the general duty clause!

MSW Landfill RTR

Additional Revisions

˃ Regulatory streamlining



Incorporate 2016 New Source Performance Standards (NSPS)



Option to satisfy NSPS through MACT compliance ˃ Revisions to operational standards



Eliminating operational standards for nitrogen and oxygen concentrations in LFG collection systems



Increasing wellhead operating temperature standard to 145 °F and added monitoring requirements for exceedances

♦Weekly observations for subsurface oxidation events (SOE) ♦Weekly monitoring of wellhead temperature, CO, O2, and CH4 ♦24-hour electronic report if temp > 170 °F or CO > 1,000 ppmv ♦Annual downwell monitoring if temp > 165 °F

Final Turbine RTR

40 CFR 63 Subpart YYYY

˃ EPA maintains stay of the 91 ppbv @ 15% O2

formaldehyde limit for new and reconstructed lean premix and diffusion flame gas‐fired turbines.



Constructed or reconstructed after January 14, 2003 ˃ Additional time needed to consider comments on

proposed removal of stay and petition to de‐list stationary combustion turbines

Significance of Lifting Stay

˃ Affected sources will be required to comply with

Subpart YYYY immediately following final action (i.e., publication of final rule)

˃ Required performance tests must be conducted within

180 calendar days after the final action

˃ Note: EPA can defer the lift of the stay beyond the

finalization of the rule

40 CFR 64 Subpart YYYY

˃ Removal of startup, shutdown, and malfunction

exemptions

˃ Recordkeeping and Reporting



Document startup conditions and excess emission events



For excess emissions, estimate amount of emissions over standard and provide method for the calculation



Electronic reporting via the Compliance and Emissions Data Reporting Interface (CEDRI)

CEDRI

CEDRI and Electronic Reporting

˃ The Compliance and Emissions Data Reporting Interface

(CEDRI) is located on the Central Data Exchange (CDX)

˃ CEDRI supports submission of multiple reports at one time ˃ CEDRI aggregates the uploaded files and completed forms

into a single package for submission. The source then certifies and signs the package using the CDX Cross‐Media Electronic Reporting Regulation (CROMERR) service

˃ Submission files stored in CDX CROMERR, available to:



Submitters, authorized EPA, regional, state, local, and tribal reviewers immediately after submittal



Although submission files are available to state reviewers, there have been issues with accessibility



Files also available to public in WebFIRE after review

S

• urce:

https:/ / www3.epa.gov/ ttnemc01/ meetnw/ 2015/ electronicreporting.pdf

Accessing CDX and CEDRI

˃ https://cdx.epa.gov/ ˃ CEDRI can be added as a program service of CDX

CEDRI Roles

˃ Preparer: the person responsible for the

preparation of reports for signature

 Contractors are permitted to register as a Preparer and

may assemble submission packages for the Certifier's approval and signature ˃ Certifier: the duly authorized representative of

the source/facility or more commonly referred to as the "owner" or "operator" of the facility

 The Certifier is authorized to modify the package a

Preparer has assembled, and sign and submit the package to CDX ˃ Note “Organization” should be the user’s

employer

Certifier Registration

˃ For users registering as a Certifier, identity proofing is

required

˃ Certifiers are prompted to follow the registration steps

using the LexisNexis identity verification or the Electronic Signature Agreement (ESA) signing process



The LexisNexis identity verification requires Personally Identifiable Information (PII). If this verification is passed, the ESA can be signed instantly and electronically



Otherwise, the ESA process requires the Certifier to send a paper form to the EPA and can take up to 2 weeks to complete the registration process



The ESA must be processed before the Certifier role is activated within CDX



Be aware of timing – recommend setting up the Certifier in advance

Setting up CEDRI

˃ An account must be associated with a facility

 CEDRI has the ability to search for or create a facility

Submitting in CEDRI

˃ Once the Certifier or Preparer is logged in,

select the Role(s) hyperlink to review or prepare reports

CEDRI Supported Reports

˃ Performance Test Reports ‐ Performance Test Reports use

the Electronic Reporting Tool (ERT), built in Microsoft Access, to generate files containing emissions source test

• data. Facilities upload these files to CDX using CEDRI.

˃ Notification Reports ‐ A Notification Report or Notification

• f Compliance Status (NOCS) is typically submitted by a

regulated facility to notify the designated authority that the facility has achieved compliance with an applicable

• regulation. (Note: In CEDRI some Notification Reports will

be uploaded in PDF form.)

˃ Air Emissions Reports ‐ Air emissions reports are periodic

reports submitted to the delegated authority after the facility achieves initial compliance that demonstrate that the facility has maintained continuous compliance with an applicable regulation over the reporting period (e.g., 6 months).

Electronic Reporting Tool (ERT)

˃ The ERT is designed to electronically create and

submit stationary source sampling test plans to regulatory agencies and, after approval, to calculate and submit the test results as an electronic report to the regulatory agency

˃ ERT is an Microsoft Access based program that

can be downloaded at: https://www3.epa.gov/ttnchie1/ert/

˃ Data is manually inputted into the ERT ˃ ERT produces a submittal package (.zip), which

consists of the test data and an XML export file

˃ Files are uploaded and submitted in CEDRI

Electronic Reporting Tool (ERT)

˃ Enter data within ERT for:

 Test plan  Test data  Process data

˃ ERT cannot be opened and used

immediately, requires extensive review

˃ Recommend stack testing company

prepare ERT submittal file and upload to CEDRI

ERT Helpful Hints

˃ ERT is frequently updated ‐ Make sure you are

using current version!

˃ Make sure you enable macros after opening

program

˃ Program is buggy and will crash ˃ Difficult to open ERT files completed by others ˃ Report (PDF) preview function can appear sloppy ˃ State/local agency requires hardcopy test report

unless they have specified otherwise!

ERT Main Menu

ERT Test Plan

ERT Stack Test Run Data

ERT Stack Test Process Data

ERT Report Preview (PDF)

Creating ERT Submittal File

Submitting ERT File in CEDRI

Notification Reports

˃ Used to submit NOCS directly in CEDRI ˃ Data can be uploaded for some subparts

using:

 Forms  XML  Bulk Upload (Excel)

˃ Other subparts may only allow a PDF

upload

Notification Reports

Notification Report - Form

Notification Report - Excel

Notification Report - PDF

Air Emissions Reports

˃ Think “Compliance or Monitoring Reports” ˃ In some cases, similar to state monitoring forms ˃ Data can be uploaded for some subparts using:

 Forms  XML  Bulk Upload (Excel)

˃ Other subparts may only allow a PDF upload ˃ Opportunity to assist facilities with preparation of

reports or templates

Air Emissions Report - Forms

Air Emissions Report - Forms

Air Emissions Report - Templates

Air Emissions Report - PDF

Air Emissions Report - PDF

Helpful Hints (CEDRI)

˃ Don’t assume EPA has prepared appropriate

reporting forms for each rule

˃ Existing forms/uploads may or may not request all

information that a rule may require in a compliance report

˃ Consider supplementing with additional

information in forms/PDF attachments

˃ Forms may not be setup to accept information for

your monitored parameter, fuel, etc.

˃ Call CDX Help Desk with issues ˃ Hit Save!

Helpful Hints (CEDRI)

˃ State/local agency requires hardcopy unless they

specify otherwise!

˃ This means facilities will likely be duplicating

effort – Could be filling out state monitoring form and CEDRI monitoring form in some cases

˃ Have Certifier approved well in advance of

submittal deadline

˃ Make sure reports are linked with facility –

• therwise certifier cannot see them!

˃ The CEDRI forms change frequently – look out for

changes!

Questions?

DJ Wheeler – dwheeler@trinityconsultants.com 110 Polaris Parkway, Suite 200 Westerville, OH 43082 (614) 433-0733 (phone) (614) 433-0734 (fax)