On May 2, 2024, the U.S. Environmental Protection Agency (EPA) initially made the electronic semiannual reporting form template available for 40 CFR 63 Subpart MM, National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills. Under Subpart MM, pulp mills with sources subject to the rule must begin submitting the semiannual electronic reporting form in U.S. EPA’s Central Data Exchange (CDX) – Compliance and Emissions Data Reporting Interface (CEDRI) for reports due on or after May 2, 2025. For most mills, the first Subpart MM compliance report required to be submitted in CEDRI will cover the 2025 1st half semiannual reporting period.
Information required to be submitted in the electronic reporting form for each semiannual period includes:
- Facility/Reporting Period Information (address, reporting period, etc.)
- Emission Unit, Monitoring, and Stack Configuration Data
- Continuous Monitoring System (CMS) Equipment and Certification Data
- Opacity Excess Emissions and Continuous Opacity Monitoring System (COMS) Performance Data
- Operating Limit Parameter Exceedances and Continuous Parameter Monitoring System (CPMS) Performance Data
- Information on Changes to CMS, Emission Sources, and Control Devices
- Certification Statements
- Detailed Information on CMS Downtime and Excess Emission/Exceedance Events (required if downtime, excess emissions, or exceedances are greater than established thresholds or if a violation occurs as defined under the rule)
- Detailed Information on Violations (as defined under the rule)
The reporting template can be downloaded from U.S. EPA’s CEDRI website. U.S. EPA has already published 2 revisions to the reporting form template since the initial availability date of May 2, 2024. Facilities should ensure that the most recent version of the template is used to complete the applicable reports.
Trinity has assisted numerous industries (including pulp and paper) with reporting and certification assistance related to U.S. EPA’s electronic reporting initiatives. If your company needs assistance in developing a site-specific template or completing electronic reporting, reach out to your local Trinity office for assistance.
