Working Together for ERT Success
The EPA’s Electronic Reporting Tool (ERT) allows for the creation of test plans and reporting of compliance and emissions data to regulatory agencies by using a Microsoft Access database as a repository for all the information. This information is uploaded to the Compliance and Emissions Data Reporting Interface (CEDRI) using the EPA Central Data Exchange (CDX) website. Sixty days after being uploaded, the public can access the data online using the Web Factor Information Retrieval System (WebFIRE).
Mentioning “ERT” in conversation with Source Operators and Testing Contractors alike may provoke a similar response: deep sigh in conjunction with a dramatic eyeroll. Generating an ERT is no simple feat. It requires a massive amount of time and attention to detail. And, if you’ve ever been through the ERT process, you know that it requires a bit of patience during those inevitable database glitches.
A successful ERT submittal requires a coordinated effort between the Source Operator and the Testing Contractor. As a Testing Contractor, CleanAir has had its fair share of trials at the mercy of the ERT process. That’s why we have come up with a few simple tips that Source Operators can follow to help Testing Contractors like us facilitate a smooth and successful ERT submittal process.
1. Tell us a little about yourself.
When the Testing Contractor is doing the bulk of the data entry, the Source Operator can expedite the process by ensuring that we have accurate and complete information regarding the facility and affected emissions source. Provide a recent copy of the facility operating permit.
The Testing Contractor may also have a questionnaire regarding facility specific information needed for ERT completion. Filling out this document in a timely fashion is a great help.
2. Planning makes perfect.
Including ERT requests early in the project planning phase allows the Testing Contractor to allocate the resources necessary for ERT completion. Make sure the ERT preparation in explicitly included in the project Scope of Work.
3. Set a clear schedule.
Communicate ERT internal and regulatory submission due dates and CEDRI upload needs as part of the project timeline that the Testing Contractor bids upon.
4. Narrow the focus.
Define all ERT test parameter requirements. In some cases, not all testing performed as part of the project is required for the ERT. Additionally, not all EPA test methods are supported in the ERT database.
5. Manage divided responsibilities.
Share the name and contact information of your registered ERT certifier. The Testing Contractor can upload the ERT submission package to CEDRI on the Source Operator’s behalf, but the ERT will not be finalized until the Source Operator’s registered ERT certifier provides a signature through the CDX website.
6. Don’t re-invent the wheel.
Test Plans are probably the most time consuming and labor-intensive part of the entire ERT process. If you have a previous ERT submission package, consider sharing it with the Testing Contractor. Chances are you have already reviewed and approved the previous test plan information, saving everyone a lot of time.
The author of this blog post has been putting together source emissions reports for CleanAir’s Emission Measurement Group since long before there was an ERT. For more tips and tricks regarding ERT, contact Jennifer Wright at jlwright@cleanair.com.
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