What is and isn't Required for Submitting your NESHAP and NSPS Reports following the recent CEDRI Update?

Environmental ConsultingEnvironmental Consulting
11/04/2024
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The US EPA is moving faster than their regulatory updates anticipated and is now asking for all reports to be submitted electronically. These reports are to be submitted into the Compliance and Emissions Data Reporting Interface (CEDRI) on the US EPA’s Central Data Exchange (CDX).

The US EPA continues to propose and amend federal rules to require electronic submission of notifications and reports utilizing Agency developed reporting worksheets for each regulation via CEDRI, including the SOCMI NSPS and NESHAP regulations. Regulatory updates typically include requirements to utilize rule-specific templates for reports within one (1) year after the template is made available. The complete list of reports able to be submitted in CEDRI and their associated templates, if available, 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.

On September 25th, 2024, the US EPA published a notice allowing all entities subject to 40 CFR Part 59-63 to electronically submit reports, notifications, and other submission types historically submitted in paper format. This notice can be viewed here: Federal Register :: Cross-Media Electronic Reporting: Electronic Submission of Reports, Notifications, and Other Submission Types. US EPA Regions are following suit, requesting that all submissions are to be made electronically. Additionally, performance test reports without electronic reporting requirements may utilize the Electronic Reporting Tool (ERT) to submit reports to CEDRI.

To accommodate the submission of documents not currently required to submit electronically and/or without available reporting templates, CEDRI now provides a “catchall” submission labeled as Other. This allows for any applicable document to be submitted in CEDRI via a pdf, .xls, .doc, or .zip file. Additionally, while US EPA is eliminating paper submissions, this has no impact on current submissions to your State, Local, or Tribal authority NSPS and NESHAP reporting. Such reports will continue to be submitted in accordance with your local program requirements. If you have concerns or questions about having to submit reports in 2 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, 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.

I joined Trinity Consultants because I wanted to take my experience as an engineering student and apply it to a job that was people-oriented and allowed me to explore a wide range of industries. In my time at Trinity, I’ve had the opportunity to both work on a variety of projects and develop my own areas of expertise. As someone who was interested in air dispersion modeling early on, I’ve had the opportunity to grow my experience in that subject area without sacrificing opportunities to try new projects and work with great people. As a Senior Consultant, I now support clients in a variety of industries including data centers, surface coating, Portland cement, lime manufacturing, oil and gas, and more. My project work covers a broad range as well, including air dispersion modeling, routine compliance support, new construction permitting, and stack testing support.

Sam Najmolhoda
Senior Consultant

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