4 The record articles

Top of the Year Reporting Lookouts

Posted: February 2nd, 2018

Authors: Stacy A. 

This article is available as a podcast episode on ALL4’s Air Quality Insider

As many of our clients and other environmental professionals are finishing up the first month of 2018 reporting, it’s only the start of the reporting season. The following list contains some environmental reports and associated deadlines that your facility may be subject to during the year. While not a comprehensive list of all environmental reports that are required by the United States Environmental Protection Agency (U.S. EPA) and state and local regulatory agencies, the list serves as a reminder of what’s ahead. It is important to also check your individual facility operating permits and federal, state, and local regulations (which may have been revised) to determine specific reporting requirements and deadlines.

  • Pennsylvania Chemical Analysis of Residual Waste Annual Report (Form 26R) –
    by March 1st

    • This report is required for persons or municipalities in Pennsylvania that generate more than an average of 2,200 pounds of residual waster per month.
  • Tier II Emergency and Hazardous Chemical Inventory Form – by March 1st

    • The Tier II form is required by local and/or state agencies for facilities with hazardous chemicals above specified thresholds. Facilities are required to report the quantity and location of hazardous chemicals in order to help agencies plan for and respond to chemical emergencies.
    • Reports are submitted to the local and/or state agency that manages Tier II Forms as dictated by a state’s Tier II reporting requirements and procedures.
  • Greenhouse Gas (GHG) Reporting – by March 31st

    • GHG Reporting is required for sources that emit 25,000 metric tons or more of carbon dioxide equivalent (CO2e) per year.
    • Reports are submitted electronically to the U.S. EPA using the electronic Greenhouse Gas Reporting Tool (e-GGRT).
  • Toxics Release Inventory (TRI) Form R – by July 1st

    • TRI Form R reporting is required for facilities that meet three specific criteria: (1) The facility employs 10 or more full-time employees, (2) The facility manufactures, processes, and/or uses a TRI-listed chemical in quantities above threshold levels, (3) The facility is in a specified industry sector.
    • Reports are submitted using the U.S. EPA’s online TRI reporting application, TRI-MEweb.
  • Annual Compliance Certification – Varies by state and permit requirements

    • Compliance certification is required for all facilities operating under a Title V Operating Permit (TVOP).
    • Some states have a hard deadline for annual compliance certifications to be completed and submitted to the state agency; however, other states require certifications to be submitted no later than 30 days following the end of the facility’s previous certification period.
  • Annual Air Emissions Inventory and Annual Air Emissions Statements – Varies by state

    • The Air Emissions Reporting Requirements (AERR) requires all state and local agencies to collect and submit emissions data to the U.S. EPA by the end of the year.
    • Individual states have specific rules for who is required to submit emissions inventories/statements, how inventories/statements are submitted, and submittal deadlines.
  • Semi-Annual reports are due twice a year – January 31st and July 31st, or as otherwise stated in a facility’s operating permit

    • The January report is for July 1st through December 31st of the preceding calendar year, and the July report is for January 1st through June 30th.
    • Facilities may be required to submit different semi-annual reports depending on the reporting requirements specified in a facility’s operating permit.
    • Examples of semi-annual reports may include: excess emissions and monitoring system summary reports, Maximum Achievable Control Technology (MACT) standards, 40 CFR Part 63, Subpart DDDDD (Boiler MACT), etc.
  • Quarterly reports are typically due within 30 days following the end of the quarter.

    • Facilities may be required to submit different quarterly reports depending on the reporting requirements specified in a facility’s operating permit.
    • Examples of quarterly reports may include: excess emissions and monitoring system summary reports, Discharge Monitoring Reports (DMR), etc.

If you have any questions about your facility’s reporting requirements or need an extra hand with preparing reports, please don’t hesitate to reach out to me at 678.460.0324 x213 or sarner@all4inc.com.


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