On May 29^th, 2024, the EPA added several report templates to the Compliance and Emissions Data Reporting Interface (CEDRI) website for Hazardous Organic National Emissions Standards for Hazardous Air Pollutants regulations (HON) and/or the Synthetic Organic Chemical Manufacturing Industry New Source Performance Standard (SOCMI NSPS) rules.

The CEDRI, located on EPA’s Central Data Exchange (CDX), is the online portal for accessing and submitting reports required by affected sources subject to 40 CFR Part 52, 60, 62, and 63. The complete list of reports able to be submitted in CEDRI is available here: CEDRI – List of Rules | US EPA. Reports such as Performance Test Reports, Notifications, and Periodic Reports, can be submitted to CEDRI if included on this list of reports. There are currently hundreds of rules by which electronic report submission is available, with the number of available reports constantly increasing.

The EPA continues to propose and amend federal rules to require electronic reporting requirements via CEDRI, including the aforementioned HON and SOCMI NSPS regulations. The updated reporting requirements language indicates the required timeframe to start a certain report or stack test results via CEDRI using the CEDRI templates. To address delayed issuance of report templates, CEDRI reports are often required once the template has been available for 1 year. The CEDRI templates for periodic reports are generally provided in an Excel format, with fields corresponding to the reporting requirements under each specific rule, while other reports are submitted as a pdf to the ERT.

In the HON and SOCMI NSPS rule updates finalized in May 2024, EPA added requirements to submit most reports in CEDRI. For example, 40 CFR Part 60, Subpart VVa (NSPS VVa) semiannual reporting requirements now include the following language:

“…Submit semiannual reports to the Administrator beginning 6 months after the initial startup date. Beginning on July 15, 2025, or once the report template for this subpart has been available on the CEDRI website for 1 year, whichever date is later, submit all subsequent reports using the appropriate electronic report template on the CEDRI website…”

The NSPS VVa semiannual report template was added to CEDRI on May 29, 2024. So, after July 15, 2025, (since this is later than 1 year after the report was made available on CEDRI) the Subpart VVa Semiannual Reports are required to be submitted in CEDRI using the CEDRI template.

It’s important to note that performance (stack) test reports and RATA results required to be submitted in CEDRI are completed through the Electronic Reporting Tool (ERT). The ERT requires detailed information from the test/RATA be entered and then outputs a submittal file, which must be uploaded, certified, and submitted in CEDRI. Trinity recommends only using personnel familiar with the test methods to complete the reports in the ERT.

The HON and SOCMI NSPS regulations with new report templates added to CEDRI in May are provided in Table 1 below.

If you have any questions about the upcoming changes to the reporting requirements for the HON, SOCMI, or other rules, reach out to your local Trinity office! For a smooth transition to CEDRI reporting, Trinity can help with updating your existing reporting formats to the new CEDRI-required reporting template.

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Table 1. HON and SOCMI Report Templates Available in CEDRI as of May 29, 2024

For more information on the new CEDRI templates, please contact Inaas Darrat ([email protected]).