Don’t Let Your Air Emissions Reporting Deadline Fly By

Major reporting deadlines for environment, health, and safety (EHS) managers are heavily weighted in the first half of the year—the reporting season, so to speak. Make sure you are prepared for the 2018 whirlwind of reporting activity.

Note. Over the course of the next few Advisors, we will review major air, hazardous waste, and chemical reporting requirements applicable to most EHS managers. The major reports we will be discussing do not comprise the entire list of reports EHS managers are responsible for submitting. Make sure to check all applicable federal and state regulations. In addition, take a look at all your permits—they may require reporting specific to your facility or source.

General Air Emissions

From February through July, most states and/or local air agencies require that permitted sources report actual emissions of air pollutants for the previous year—the Emissions Inventory Report. Reporting requirements and the reporting form itself differ from state to state. So, if you have a permitted source in 2017, it is critical to check your specific state air emissions reporting requirements.

Usually, when preparing an emissions inventory, an EHS manager would quantify emissions of:

• Sulfur dioxide (SO₂)
• Particulate matter (both PM-10 and PM-2.5)
• Nitrogen oxides (NOx)
• Volatile organic compounds (VOCs)
• Carbon monoxide (CO)
• Lead
• Each individual hazardous air pollutant (HAP)
• Sum of all HAPs
• Greenhouse gases (GHGs)

Your state may specify additional pollutants that must be quantified.

GHG Emissions

Certain facilities that emit GHGs and suppliers of fossil fuels and industrial GHGs are also required to submit annual reports of GHG emissions to the U.S. Environmental Protection Agency (EPA) by March 31 for the previous calendar year. The GHGs covered under this reporting requirement are:

• Carbon dioxide (CO₂),
• Methane (CH₄),
• Nitrous oxide (N₂O),
• Sulfur hexafluoride (SF₆),
• Hydrofluorocarbons (HFCs),
• Perfluorochemicals (PFCs), and
• Other fluorinated gases (e.g., nitrogen trifluoride, hydrofluorinated ethers)

In general, the federal reporting rule applies to:

• Fossil fuel suppliers and industrial gas suppliers; and
• Certain industrial facilities that emit GHGs (primarily large facilities emitting 25,000 metric tons of carbon dioxide equivalent (mtCO₂e) or more of GHG emissions per year).

So far, the EPA has targeted 41 source categories for GHG reporting. There are reporting requirements specific to each source category.

For the majority of reporters, the EPA collects data at the facility level. There are a few exceptions where reporting is at the corporate level for some supplier source categories (e.g., importers of fuels or industrial GHGs). For several source categories, reporters are required to provide information at the unit-level or process-line level, as well as for the facility as a whole.

All GHG reports must be submitted to the EPA using the Agency’s electronic Greenhouse Gas Reporting Tool (E-GGRT).

Check with Your State

If you emit GHGs, be sure to check with your state for additional reporting requirements. It is important to note that this federal GHG reporting requirement does not preempt or replace state GHG reporting programs. Many state programs are broader in scope.

Do you know the major chemical reporting deadlines for 2018, the new one, and the one you can take off your to-do list for next year? Tune in to tomorrow’s Advisor for a review.