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January 04, 2016
2016 Reporting Season: What is on the horizon?
By Timothy P Fagan, Senior Legal Editor - EHS

Along with the New Year comes 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 have to submit in the upcoming months. There are the usual suspects: hazardous chemical inventory (Tier II) reports, state air emissions inventories, greenhouse gas (GHG) emissions reports, and Toxic Release Inventory (TRI) reports. But, in addition to these annual reports, 2016 is also a reporting year for two significant periodic reports: the hazardous waste biennial report and the Toxic Substances Control Act’s Chemical Data Report (CDR).


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 is a busy month

Although some facilities will be submitting emissions inventory reports in February, the first reporting deadline of 2016 for most facilities will be March 1. This is the due date for 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 you used or stored any other hazardous substance in excess of 10,000 lb. you are required to submit a Tier II report.

Also due on March 1 are the 2015 Biennial Reports. Large quantity generators (LQGs) of hazardous waste as well as treatment, storage, and disposal facilities must submit these reports to detail the types and quantities of hazardous waste shipped off-site and the efforts taken to reduce the volume and toxicity of the wastes generated. The Environmental Protection Agency (EPA) has already released the 2015 report form, and the only change from the previous form is a refinement of the definition of an LQG, which should help clarify who must report. In addition, some states require annual reports or have developed their own biennial report forms that require additional information, so be sure to check state requirements.

March also brings the reporting deadline for GHG emissions. Sources subject to EPA’s Mandatory Greenhouse Gas Reporting regulations under 40 CFR 98 must submit reports of their 2015 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.
After March, and depending on when your state air emissions reports are due, you may get a bit of a breather from reporting deadlines, but there will be plenty of data to compile for the upcoming summer deadlines.

The arrival of July means TRI

Due July 1, a TRI report is a summary of how a facility disposes or otherwise releases any of over 650 listed toxic chemicals. It also includes information about how facilities manage those chemicals through pollution prevention, recycling, energy recovery, and treatment. For the first time this year, chemicals in the nonylphenol category must be included in TRI reports.

Don’t forget about the CDR

The Toxic Substances Control Act’s (TSCA) CDR must be submitted every 4 years by companies manufacturing or importing any chemical in the TSCA Inventory above certain thresholds at a single site. The CDR provides the EPA with information on the production of chemicals and their use in commerce, meaning where and how chemicals are being used and by whom. The 2016 CDR must include data for each year from 2012 through 2015, and the EPA has made some significant changes in the reporting requirements since the last report in 2012. The CDR submission period begins June 1, 2016, and ends September 30, 2016.

The Takeaway: Don’t procrastinate!

 So, as you can tell, 2016 has the potential to be a very busy year if you are subject to many of these reporting requirements. Therefore, it is not too early to get started compiling the data you may need to fulfill all of your applicable reporting obligations.

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.
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