Electronic Data Submissions Washington, DC June 10, 2004 Presenter: Ujjval Shukla U.S. EPA

Session Overview u Summary of the Electronic Data Reporting (EDR) Process u Data Reporting Process: Basics, EPA Software/User Registration, Submission and Compliance Periods u Emissions Tracking System (ETS) and EDR Data Checking u ETS Feedback Reports and Status Codes u Relationship between your EDR and EPAs Annual Reconciliation

ETS Source installs and maintains monitoring systems Source electronically submits hourly emissions data (NOx tons) to EPA each quarter EPA receives, processes, quality assures, and publishes data EPA provides feedback to source Summary: Data Reporting Process

Data Reporting Process: Basics u The data needs to be reported in the EDR format u EDR Instructions and format u Sources can be quarterly reporters or ozone season reporters. u EPA identifies reports that were not submitted by the appropriate reporting deadline u Use the EPA-provided software to submit your EDR

ETS-FTP v2.0 u ETS-FTP ã EPA-provided software that allows submittal of the EDR files to the EPAs mainframe Emissions Tracking System (ETS) ã Sources will receive instant feedback reports u SecuRemote ã EPA-provided software that ensures secure transmission of data to EPAs mainframe ã Must be used in conjunction with ETS-FTP

ETS-FTP/SecuRemote User Registration u Register to receive User ID and passwords for ETS-FTP/SecuRemote ã Follow user registration instructions on web site at u Download ETS-FTP software and instructions ã u Authorized Account Representatives (AARs) can register their staff persons as authorized users to receive their own User ID and passwords ã EPA Security Policy: NO sharing of User ID and passwords

Data Reporting Process: Submission Periods u EDR are required to be submitted during the 30 days following last day of the calendar quarter: Quarter Submission Period 1st QuarterApril 1 - April 30 2nd Quarter *July 1 - July 30 3rd Quarter *October 1 - October 30 4th Quarter January 1 - January 30 * includes Ozone Season

Data Reporting Process: 2004 Compliance Periods u Compliance Period for sources in States that were part of the OTC NOx Budget Trading Program: m May 1 - September 30 u Compliance Period for NOx Budget Trading Program units located in Alabama, Kentucky, North Carolina, Indiana, Illinois, Michigan, Ohio, South Carolina, Tennessee, Virginia, and West Virginia (States that were not part of the OTC NOx Budget Trading Program): m May 31 - September 30

Data Reporting Process: 2004 Compliance Periods (contd) u Beginning in 2005, all units will have the same compliance period: m May 1 - September 30 u It is important to note that regardless of the compliance periods, the hourly and cumulative emissions in the EDR files must be reported for the complete Ozone Season (May 1 - September 30).

ETS and EDR Data Checking u When you submit EDR to EPA, ETS applies automated data checks to your data. u Examples of ETSs basic checks: ã Does the quarterly report and each data record have the correct format and structure? ã Are the Facility code (ORISPL) and Unit/Stack/Pipe IDs correct? ã Are the required record types present?

ETS and EDR Data Checking (contd) u Examples of ETSs hourly/cumulative checks: ã Does the sum of hourly data equal the reported cumulative values? ã Does each recalculated hourly emissions value equal the reported value? u ETS also compares hourly data against the reported monitoring plan information

ETS and EDR Data Checking: Feedback Reports u After checking the EDR, ETS generates a feedback report. u The Feedback Report contains: EPA letter w/receipt, the Report Status Code, the error descriptions, and most importantly the EPA-accepted emissions values. u You may resubmit an EDR to correct identified errors or other deficiencies, and receive an updated feedback report.

ETS Status Code Summary for EDR u Acceptable Status Codes: m Status Code 10: ETS detected no reporting errors; future action may be required m Status Code 9: Quarterly Report contains informational errors m Status Code 7: Report indicates non-operational unit/stack u Critical rejection Status Codes: m Status Code 6:Quarterly Report Rejected m Status Code 5:Critical Error Rejection

Guidance for Correcting and Resubmitting EDR files u Status Codes 5 and 6 (Critical Errors found) ã Correct the critical and rejection errors identified in your feedback report ã Resubmission is required u Status Code 9 (Informational Errors found) ã Resubmission encouraged but not required ã EPA may reclassify informational errors as critical errors in the future

ETS: Additional Data Checking u After all EDR files are received, EPA performs additional off-line Quality Assurance checks: ã Additional checks that are not currently built into ETS (these may become future automated ETS checks) ã Audit reviews performed by the Emissions Monitoring Branch (EMB) ã EPA may require resubmission based on results

The EDR and Annual Reconciliation u The EPA-accepted emissions values in your EDR feedback report are used for compliance u Your allowance holdings are compared to the EPA-accepted emissions values in the EDR to determine if your units are in compliance

Feedback Report: Example of Typical EPA-Accepted Emissions

Feedback Report: Example of 2004-only EPA-Accepted Emissions /2004 ALTERNATE CUMULATIVE 2004 OZONE SEASON NOX MASS VALUE ORISPL: Plant Name: Some Plant Unit/Stack/Pipe ID: CT Alternate 2004 Cumulative Ozone Season NOx Mass Emissions (tons) : NOTE: The value displayed above is the EPA-Accepted NOx Mass value for the 2004 Ozone Season. The Alternate Cumulative 2004 Ozone Season NOx Mass value displayed above is calculated from the hourly NOx Mass Emissions values reported in RT 328 or RT 360 from May 31, 2004 through September 30, This table is only displayed for sources located in the following States: AL, IL, IN, KY, MI, NC, OH, SC, TN, VA and WV. These States are using an alternate Ozone Season Compliance period for 2004.

Quality of EDR is Important u Accurate emissions values are critical because they are used for compliance purposes u Hourly emissions data are used by EPA for compliance so every hour must be correct u Incorrect hourly emissions can cost you $$$ u Be sure to check your EDR files and correct problems before submitting them to EPA

Where is The Data Available? u Program data is available on the Clean Air Markets web site by using Data and Maps page at: ã u Generate reports or downloaded annual, ozone season, quarterly, monthly, daily, and hourly emissions data u Download as reported emission files (Raw Emissions Data) and compliance reports u For specific data inquiries contact Ketan Patel at (202)

ETS User Bulletins u ETS User Bulletins provide information regarding all new and upgraded quality assurance checks u Bulletins provide updates on reporting issues and compliance u Available at: ã

Conclusion u Use ETS-FTP/SecuRemote to submit your EDR files and receive instant ETS feedback reports. Monitoring Data Checking (MDC) must not be used for EDR submittals. u ETS feedback report is not same as the MDC feedback report. u Your ETS feedback report identifies errors and displays the EPA-accepted emissions values u Quality of emissions data is important because EPA uses the data to determine compliance u For further information on ETS and EDR reporting