Over the last several years, as US EPA finalizes risk and technology reviews (RTRs) for National Emissions Standards for Hazardous Air Pollutants (NESHAPs) and New Source Performance Standards (NSPS), rule amendments now require electronic submission of reports through the Compliance and Emissions Data Reporting Interface (CEDRI) in the US EPA’s Central Data Exchange (CDX).
These reports must be submitted utilizing US EPA developed templates for each regulation via CEDRI in addition to the reports currently submitted to your local program (i.e. state, county, Tribal, etc.) delegated to administer the Clean Air Act (CAA). These templates cover all sorts of submissions, including one-time notifications and periodic reports. Additionally, performance test reports with electronic reporting requirements are required to utilize the Electronic Reporting Tool (ERT) to submit reports to CEDRI.
Multiple regulations impacting the SOCMI regulated community now include CEDRI reporting requirements, with the timeline requiring use of US EPA templates and CEDRI submission by the compliance date of the amendment or within one (1) year after the template is made available, whichever is later. The initial deadline for reporting in CEDRI has passed for several regulations and is imminent for many other regulations. The table below provides a quick reference summary of key regulations and associated CEDRI periodic reporting timeframes.
Regulation | Report Required to be Submitted in CEDRI | Initial Template Availability Date | Compliance Date for CEDRI Reporting | Use CEDRI Template After… |
NSPS VV/VVa | Semiannual Report [60.487(a) and 60.487a(a)] | 05/29/24 | 07/15/25 | 07/15/25 |
NSPS VVb | Semiannual Report [60.487b(a)] | 05/29/24 | 07/15/24 | 05/29/25 |
NSPS III | Semiannual Report [60.615(j)] | 05/29/24 | 07/15/25 | 07/15/25 |
NSPS IIIa | Semiannual Report [60.615a(i)] | 05/29/24 | 07/15/24 | 05/29/25 |
NSPS NNN | Semiannual Report [60.665(l)] | 05/29/24 | 07/15/25 | 07/15/25 |
NSPS NNNa | Semiannual Report [60.665a(j)] | 05/29/24 | 07/15/24 | 05/29/25 |
NSPS RRR | Semiannual Report [60.705(l)] | 05/29/24 | 07/15/25 | 07/15/25 |
NSPS RRRa | Semiannual Report [60.705a(k)] | 05/29/24 | 07/15/24 | 05/29/25 |
MACT Subpart H | Periodic Report [63.182(d)] | 05/29/24 | 07/15/27 | 07/15/27 |
MACT Subpart YY | Cyanide Chemicals Manufacturing – Periodic Report [63.1110(e)] | 05/07/24 | 05/18/25 (existing sources) | 11/19/21 (new sources) | 05/07/25 |
The complete list of reports able to be submitted in CEDRI and their associated templates is located here: CEDRI – List of Rules | US EPA. Please note, upon the regulatory prescribed deadline to report via CEDRI, reports must go to both the US EPA and your local program, regardless of any waivers for US EPA submissions that have historically been given to your Site. Additionally, this CEDRI submittal requirement to the US EPA has no impact on current submissions to your State, Local, or Tribal authority. Such reports will continue to be submitted in accordance with your local program requirements, albeit with new RTR requirements incorporated where necessary. If you have concerns or questions about having to submit reports in two different formats, consider reaching out to your State, Local, or Tribal authorities to discuss accepting submissions in US EPA’s new CEDRI template format.
If you have any questions about the changes to the reporting requirements for the HON, SOCMI NSPS, or other rules, reach out to Chemical Sector Services: Inaas Darrat and Gena Driscoll. For a smooth transition to CEDRI reporting, Trinity can help with updating your existing reporting formats to the new CEDRI-required reporting template.