ERT and CEDRI: Required Air Emissions Reporting

(April 21, 2021) -- The iron and steel foundry Residual Risk and Technology Review Rule (RTR) for both major (Foundry MACT) and area sources (Foundry Area Source Rule) of hazardous air pollutants did not institute any new emission limits or require any new air pollution controls.  The rule did, however, institute new reporting requirements that affect almost every US iron and steel foundry.

Beginning on March 9, 2021, iron and steel foundry major and “large” area  sources of hazardous air pollutant (HAPs) must now use USEPA’s Electronic Report Tool (ERT) to compile results of both performance tests (i.e. stack tests) and visible emission observations.  USEPA’s ERT compiles the test results into a format that can be submitted via USEPA’s Compliance and Emissions Data Reporting Interface (CEDRI).

CEDRI is located on EPA's CDX web-based platform for data management and sharing between EPA and state, local, and tribal agencies.  Foundries may already be familiar with CDX as the system used to submit and certify certain reports such as for the Toxic Release Inventory.  CEDRI is just one of 42 reporting platforms in CDX.

In addition to performance tests and visible emission observations, the Foundry RTR rule requires that semiannual reports, initial notifications, and notifications of compliance status for every iron and steel foundry subject to either the Foundry MACT or Foundry Area Source Rule be submitted electronically via CEDRI.  Per the Foundry RTR, these semiannual reports must now be prepared using a USEPA spreadsheet template and using a 3rd party utility formatted (zipped) prior to submission.  The final version of the templates for these reports are located on the CEDRI website at

In summary, the Foundry RTR rule requires any iron and steel metal casters to submit initial notifications, notifications of compliance status, performance test reports, performance evaluation reports, and semiannual reports electronically using ERT with CEDRI or CEDRI alone beginning on March 9, 2021.

To assist metal casters with these requirements, AFS’s Air Quality Committee has developed a “How-To” series on using ERT and CEDRI available on the Air Quality section of the AFS website.

In closing a few final recommendations and reminders on CEDRI:

  • It important to remember that submission of results and reports via CEDRI only meets the requirement to submit to the regional office of USEPA.  You may have a continued obligation to report the results to your state regulatory agency via existing means.
  • While the Foundry MACT and Foundry Area Source Rule are addressed above, if your foundry is impacted by other standards such as the Miscellaneous Metal Parts Coating MACT (Subpart MMMM, 63.3920 (f)) there could be similar requirements.
  • Providing any required notifications for upcoming testing is not addressed within the ERT or CEDRI, so a foundry would continue to make those notifications through their existing channels.
  • Make sure the report preparer and certifier have set up their CDX accounts.
  • Make sure the electronic signature agreement (ESA) process is completed by the certifier’s account so reports can be certified and submitted

Marty Stromberger, Senior Project Manager, TRC