It is hard to believe that 2017 is upon us. Every year at this time, we look ahead to a new season of reporting—and those deadlines will come up faster than you think. So, it is time to start thinking about what reports you must submit in the upcoming months.
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There are the usual suspects: Tier II, state air emissions inventories, greenhouse gas (GHG) emissions reports, and Toxics Release Inventory (TRI) reports. But the good news is that the reporting load is lighter than last year, as the Toxic Substances Control Act’s Chemical Data Reports (CDRs) are not due again until 2020, and 2017 is a nonreporting year for federal hazardous waste biennial reports.
Air Emissions Inventories
Let’s start with state air emissions inventories. Most states require permitted sources to submit some type of report detailing the source’s actual emissions of air pollutants during the previous calendar year. Each state’s report is unique in terms of content, pollutants reported, de minimis levels, and methods of submittal. In addition, due dates for these reports vary, ranging from early February through July. So, if you have a permitted air emissions source, be sure to check your state requirements and your permit conditions to determine your emissions reporting responsibilities and deadlines.
March: In with a Report and Out with a Report
Although some facilities will be submitting emissions inventory reports in February, the first reporting deadline of 2017 for most facilities will be March 1. This is the due date for hazardous chemical inventory, or Tier II, reports. If your facility used or stored any Extremely Hazardous Substance, as listed in 40 CFR 355 Appendix A, in excess of 500 pounds (lb) or the threshold planning quantity, whichever is lower, or if your facility used or stored any other hazardous substance in excess of 10,000 lb, you are required to submit a Tier II report.
While 2017 may not be a reporting year for federal hazardous waste biennial reports, keep in mind that many states have annual hazardous waste reporting requirements. In most cases, these state hazardous waste annual reports are due by March 1.
March also brings the reporting deadline for GHG emissions. Sources subject to the U.S. Environmental Protection Agency’s (EPA) Mandatory Greenhouse Gas Reporting regulations under 40 CFR 98 must submit reports of their 2016 GHG emissions by March 31. All reports must be submitted to the EPA using the agency’s electronic Greenhouse Gas Reporting Tool, known as E-GGRT. The EPA made numerous revisions to various subparts of the GHG reporting regulations in 2016, so be sure you are in compliance with the current requirements.
After March and depending on when your state air emissions reports are due, you may get a bit of breather from reporting deadlines, which means there will be plenty of time to compile data before July.
The Arrival of July Means TRI
Due July 1, the TRI report is a summary of how a facility within the regulated source categories disposes or otherwise releases any of over 650 listed toxic chemicals, and it also includes information about how facilities manage those chemicals through pollution prevention, recycling, energy recovery, and treatment.
In November, the EPA finalized a rule to add a hexabromocyclododecane (HBCD) category to the list of reportable chemicals, with a 100-lb reporting threshold. The HBCD category includes 1,2,5,6,9,10-HBCD (CAS# 3194-55-6) and HBCD (CAS# 25637-99-4), which are primarily used as flame retardants. However, you do not need to include HBCD on your 2016 TRI report, but you should begin to track it as of January 1, 2017, because it will need to be included on the 2017 TRI report due on July 1, 2018.
The Takeaway: Don’t Procrastinate!
Even without the biennial reports and the CDR, there are still plenty of man-hours to be spent complying with your 2017 reporting obligations. Therefore, it is not too early to get started compiling the 2016 data you may need to fulfill all of your applicable reporting obligations. Make a plan, and get started—2017 is here!
But, please note that the reports discussed do not comprise an exhaustive list of the reports you may be required to submit. As always, check the federal and state regulations applicable to your facility, as well as your permits, to be certain you are satisfying all of your reporting requirements.