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Georgia Environmental News

Manufacturers and Importers Required to Submit TSCA CDR Reports in 2016

Tuesday, October 06, 2015

Environmental managers should be planning and budgeting for 2016 to be a year requiring submittal of reports to EPA for the Chemical Data Reporting (CDR) program under the Federal Toxic Substances Control Act (TSCA). This reporting requirement is now on a 4 year reporting cycle, and is the continuation of the old Inventory Update Rule (IUR) requirements under a new name. The purpose of the rule is to ensure that EPA is able to maintain a complete inventory of all chemical substances in commerce in the U.S., how those substances are used, and who is exposed to those substances so that they can make better decisions on what substances merit additional study for health or ecosystem risks.

Reporting is required for any entity that introduced a substance into commerce in the U.S. in 2012-2015 by either manufacturing it (through a chemical change) or importing it. In most cases, the threshold for this activity triggering the reporting requirement is 25,000 pounds in any year, but for some substances EPA has selected for additional scrutiny, lower thresholds may apply. Once reporting is triggered for a given substance, all reports must include information on manufacturing or import volumes in 2012, 2013, 2014, and 2015. This reporting cycle will be more complex and in-depth than previous reporting cycles as a result of the August 16, 2011 amendments (76 FR 50816). These amendments significantly expanded the scope of information required in each report, in many cases requiring the manufacturer or importer of the substances to provide data on the "downstream" users and uses of the substance. This is information that many reporters may not have ready access to and will need to expend additional effort in conjunction with their accounting and marketing departments to gather, potentially even requiring outreach to customers in order to gather information on the end use of these products. Furthermore, EPA no longer accepts paper reports. Company officials will need to submit notarized registration forms to EPA to obtain a CDX account. This is necessary not only for electronically signing the final report, but also to electronically start the report. A third party such as a consultant cannot start the report on behalf of the company; they can only draft the report once the company initiates the report in the system. Regulated entities should plan on at least a month to get a CDX account established and ready for use before the reporting period begins.

Given that this is a less-than-annual reporting requirement with a significantly expanded reporting burden as a result of regulatory changes, the regulated community should budget for additional effort and expenses next year, and start making plans now for successfully gathering and reporting the required data during EPA's reporting window of June 1 through September 30, 2016. Trinity's Atlanta office has TSCA reporting expertise and can assist if needed.

For additional information on 2016 CDR reporting, click here.

Old EPD Title V Database Has Said "Au Revoir"

Thursday, August 06, 2015

As of August 1, 2015, EPD no longer accepts changes to the old database and all Air Branch applications are required to be submitted through the new Georgia Environmental Online System (GEOS). The Watershed Branch will require all municipal NPDES applications to be submitted through GEOS by January 1, 2016. EPD is conducting GEOS training sessions in various places throughout the state over the next few months. Please note that EPD is not planning on transferring information from the old Title V database into the new system. It is recommended that the Responsible Official (RO) go ahead and create a GEOS Account as soon as possible to ensure that facility information and processing can be completed before an application will need to be submitted through the system. For additional details and scheduling of training events, please see the official GEOS website.

Energy Assessment Deadline Rapidly Approaching

Thursday, May 07, 2015

The deadline for completion of the energy assessments required for boilers and process heaters by EPA's Boiler MACT (40 CFR 63, Subpart DDDDD) is rapidly approaching. The Boiler MACT requires a one-time energy assessment (EA) for major sources to be completed by January 31, 2016 and for area sources that was due March 21, 2014. EPA mandates that the EAs be completed by a qualified energy assessor (QEA).

Trinity Consultants has extensive qualifications to assist you in these assessments. We have 10 registered certified energy auditors (CEAs) nationwide, including one CEA located in the Atlanta local office. The CEA certification is given by the Association of Energy Engineers to qualified professionals with demonstrated expertise and experience in the field of energy auditing.

The Atlanta office alone has completed Boiler MACT EAs for several major sources and area sources in industries such as power generation, petrochemical, fiber manufacturing, automotive and wood products. An overview of the EA process consists of visual inspections of the boiler and process heater systems, evaluation of operational characteristics of the boilers, process heaters and major energy use systems, review of the facility's energy management practices, identification of energy conservation measures along with estimates of savings potentials.

To learn more, call Anu Krishnan at Trinity's Atlanta office at (678) 441-9977, ext. 231.

EPD Proposes Amendments to the Georgia Rules for Air Quality Control

Tuesday, December 16, 2014

The Georgia Environmental Protection Division (EPD) proposes to amend Rule 391-3-1-.03(8) “Permit Requirements” to remove the fine particulate matter (PM2.5) Nonattainment New Source Review (NNSR) requirements for the Macon Area and for Floyd County. A public hearing will be held at 2:30 PM on Friday, December 5, 2014 in the EPD Training Center located at 4244 International Parkway, Suite 116, Atlanta, GA 30354. The public will be allowed to present data and make written or oral comments. The proposed Air Rule Amendments will be considered for adoption on January 13, 2015. This meeting will take place at 9:00 a.m. in the DNR Board Room located at 2 Martin Luther King Jr. Drive, Suite 1252, East Tower, Atlanta, GA 30334 and is also open to the public.

Redesignation of Georgia (Chattanooga Area) Nonattainment Area

Tuesday, December 16, 2014

On September 14, 2012, the Georgia Environmental Protection Division (EPD) submitted a request to redesignate the Georgia portion of the Chattanooga Nonattainment Area (NAA) to attainment status with respect to the 1997 annual fine particulate matter (PM2.5) National Ambient Air Quality Standard (NAAQS). The Georgia portion of the Chattanooga NAA includes Catoosa and Walker County. Per the Federal Register on November 12, 2014, the Environmental Protection Agency (EPA) has proposed rules to approve the request by EPD and to accept EPD’s maintenance plan. Comments must be submitted to EPA by Wednesday, December 3, 2014. Comments may be submitted via email (, Fax (404.562.9019), or mail (see address below). Please visit the following URL for additional information:

Regulatory Development Section
Air Planning Branch
Air, Pesticides, and Toxics Management Division
U.S. Environmental Protection Agency
Region 4
61 Forsyth Street SW
Atlanta, GA 30303-8960

Georgia Environmental Online System is Coming Soon

Tuesday, October 07, 2014

In a September 12, 2014 presentation at the Air and Waste Management Association (AWMA)-Southern Section Conference, Jimmy Johnston with EPD announced that the new Georgia Environmental Online System (GEOS) is scheduled to begin soft rollout in October 2014. GEOS will be a web-based application that will replace the existing Title V database when preparing Title V applications for facilities that operate as major sources with respect to the Federal Title V program. GEOS will initially include applications in Title V and National Pollutant Discharge and Elimination System (NPDES) permitting, but is expected to incorporate and “phase in” minor source permitting sometime in the future. Full rollout of GEOS is expected by January 2015. The new system offers paperless draft permits, real time application status tracking, and easy emission path grouping. We will keep you updated as rollout begins over the next few months! For more information, you can view the presentation by visiting the URL listed here.