EQFall2019F-AnnualEnvironmentalReporting-Figure1Environmental reporting is a compliance requirement that involves the collection, documentation, and transfer of a source's (or multiple sources') environmental data from one entity to another. It may include reporting to US Environmental Protection Agency (EPA), state and local agencies, or other authorities with jurisdiction. Environmental reports cover a variety of environmental programs and media: air, waste, stormwater, wastewater, hazardous substances and hazardous chemicals. Many of these reports must be submitted at least once a year, and some environmental data may be required for multiple reports. Annual environmental reporting projects typically include the steps indicated in Figure 1.

The most common annual environmental reports, associated with various environmental programs, are summarized in the following paragraphs. In addition, we have included CDP Reporting (formerly known as the Carbon Disclosure Project) in this article. While this type of reporting is not mandatory, it does provide a platform for companies to voluntarily measure and manage their risks and opportunities to positively impact climate change, water security and deforestation.

EQFall2019F-AnnualEnvironmentalReporting-Figure2There is overlap of a facility's data and/ or companywide data that is used in annual environmental and sustainability reporting; and typically span these five data types illustrated in Figure 2.

During the first half of every year, many environmental professionals are engaged in the task of environmental reporting which consumes much of their immediate attention and energy, saving very little time for typical day-to-day responsibilities. This article provides an insight into various annual/periodic reporting requirements, reporting timeline, information required to prepare the reports, and how data collection can be streamlined for effective and efficient preparation of the submittals. With a mindset of integrated environmental reporting, the pressure on environmental professionals can be greatly reduced by streamlining the data collection effort to a single instance that is then utilized for multiple reports. Centralized data for environmental reporting will also encourage accuracy, efficiency, and consistency among various environmental reports.

Environmental Reporting - Air

Annual Emission Inventory

Requirements - As part of national and state efforts to protect human health and the environment, federal and state laws require each state to develop an annual emissions inventory (EI) of air pollutants. Federal and state environmental agencies use the EI to plan pollution control programs, promote compliance with laws and regulations, conduct permit reviews, develop airshed modeling and rulemaking activities, and supply required data to the EPA. Typically, facilities that exceed certain emission thresholds (e.g., facilities with Title V operating permits) or that are located in certain areas (e.g., in or near nonattainment areas) are required to submit annual EIs.

Reporting Timeline - Annual EI reporting is typically required once a year for the previous calendar year. The deadline to submit the EI report varies per state. For example, in Texas, the EI is due on March 31 of the calendar year immediately after the reporting year. Other state deadlines vary, however, most deadlines fall within the first half of the year.

Data Collection and Analysis - In order to complete an annual EI, a facility must collect data to prepare emission calculations. The typical data that needs to be collected includes material throughput, equipment operating hours, monitoring data, sampling data, scheduled maintenance activities, emission event reports, etc. Emissions are then calculated using the data collected and emission calculation methodologies, based on the facility's New Source Review (NSR) permit or other EPA/State EI guidelines.

Reporting Method - Required reporting methods vary and include online reporting, electronic file reporting, or paper submittal (as allowed). Examples of online systems include the State of Texas Environmental Electronic Reporting System (STEERS), Oklahoma's State and Local Emissions Inventory System (SLEIS), and Emissions Reporting and Inventory Center (ERIC) in Louisiana.

Greenhouse Gas Mandatory Reporting Rule (GHG MRR)

Requirements - 40 CFR Part 98 requires that greenhouses gases (GHG) from certain industries/sources be reported on an annual basis to EPA. In general, the rule calls for fossil fuel suppliers and industrial gas suppliers, manufacturers of vehicles and engines outside of the light-duty sector, and certain downstream facilities that emit GHG - primarily large facilities emitting 25,000 metric tons of carbon dioxide equivalent (MTCO2e) or more of GHG emissions per year - to submit annual reports to EPA.

Reporting Timeline - GHG reports are due by March 31 for the previous reporting year.

Data Collection and Analysis - GHG reports include unique information that may align with the air emissions inventory and additional information such as industry-specific GHG emission factors and reporting requirements.

Reporting Method - EPA's online electronic Greenhouse Gas Reporting Tool (e-GGRT) must be used for GHG MRR submittals.

MACT/NSPS/Title V Compliance Reports

Requirements - Affected facilities that are subject to 40 CFR Part 63 Maximum Achievable Control Technology (MACT) or 40 CFR Part 60 New Source Performance Standard (NSPS) regulations may be required to submit semi-annual or annual compliance reports. A facility with a Title V operating permit must also submit the semi-annual compliance report (aka Deviation Report) and annual compliance report, per the permit requirements.

Reporting Timeline - Due dates vary by regulation with many MACT and NSPS semi-annual reports due by January 31 and July 31 of each calendar year immediately following the reporting period. Other MACT and NSPS performance tests, compliance reports, and compliance status updates are specified in frequency and submittal dates per regulation. The Title V compliance report due dates are based on the timeline specified in the Title V permit or may be due by January 31 and July 31 each calendar year.

Data Collection and Analysis - Typically, the same data used to develop annual EI is needed for these MACT, NSPS, and Title V compliance reports to determine any exceedance of permitted emission rates. Additional information related to compliance with the specific permit conditions and applicable state and federal requirements must also be collected and reported.

Reporting Method - EPA's electronic portal, Central Data Exchange (CDX), includes the Compliance and Emissions Data Reporting Interface (CEDRI), which is required to be used for certain 40 CFR Part 60 and 63 compliance reports. Title V compliance reports are submitted using paper or electronic forms per state and/or local requirements. It is important to check with state and local agencies to confirm where and to whom these reports should be submitted.

EQFall2019F-AnnualEnvironmentalReporting-reportimageEnvironmental Reporting - Waste

Hazardous Waste Biennial Report

Requirements - Large Quantity Generator (LQG) and Treatment, Storage, and Disposal Facilities (TSDF) must submit a Hazardous Waste Biennial Report by March 1 of each even-numbered year for hazardous waste activities during the previous odd-numbered calendar year. For example, a biennial report is due on March 1, 2020 for hazardous waste activities during the 2019 calendar year. Many states and territories require reporting on an annual basis and may require reporting by facilities other than LQG and TSDF (e.g., Small Quantity Generator (SQG), Very Small Quantity Generator (VSQG), any facility that ships hazardous waste, shipping state hazardous waste, etc.). The report summarizes the amount of hazardous waste and state specific waste generated or managed at the site during the calendar year. For example, registered generators (active solid waste registrations) in Texas must submit an Industrial & Hazardous Waste Annual Waste Summary (AWS) each year for the hazardous waste or Class 1 waste generated each calendar year.

Reporting Timeline - Due by March 1 of each even-numbered year for hazardous waste activities during the previous odd-numbered calendar year. In Texas, the annual summary report via STEERS is due by March 1 of the year following the calendar year reporting period. The paper-based annual summary report is due by January 25 of the year following the calendar year reporting period.

Data Collection and Analysis - Waste manifests must be reviewed to calculate the hazardous waste and Class 1 industrial waste quantities. It is important to verify that correct waste codes are included in the manifests and the reports.

Reporting Method - Many states have state-specific reporting systems (e.g., Texas STEERS, Washington TurboWaste.Net, Wisconsin WAMS, Illinois' Hazardous Waste Annual Report software). For example, in Texas, LQGs, whether industrial or nonindustrial, generating more than 2,200 pounds of hazardous waste in any calendar month must submit this report electronically through STEERS. Those generating less than 2,200 pounds of hazardous waste can use paper reporting with the Texas Annual Waste Summary Form 00436.

Environmental Reporting - Water

Stormwater and Wastewater DMRs

Requirements - EPA and state agencies with stormwater permitting jurisdiction develop general permits for stormwater and wastewater discharges. The EPA program is the National Pollution Discharge Elimination System (NPDES). Some states developed different types of general stormwater/wastewater discharge permits applicable to specific types of facilities. A facility holding a Stormwater Multi-Sector General Permit (MSGP) must submit a discharge monitoring report (DMR) in the following cases:

  • Any non-compliance with an effluent limit for any of the hazardous metals
  • All results of sampling for effluent limits in accordance with Sector-specific requirements regardless of if there was an exceedance or not

Wastewater sampling and analysis is an integral part of Clean Water Act (CWA) compliance. The CWA and EPA's NPDES regulations require permitted facilities to monitor the quality of their stormwater/wastewater discharge and report the monitoring data to their permitting authority on a DMR.

Reporting Timeline - May vary per state though the majority are in the first quarter of the year. There may also be benchmark monitoring that is required on a semi-annual basis.

Data Collection and Analysis - Monitoring records for samples collected to demonstrate compliance with wastewater or stormwater permit requirements must include the following information:

  • Date, exact place, method and time of sampling, and name of sampler
  • Date of analysis
  • Name of analyst
  • Analytical techniques/methods used
  • Analytical results

Reporting Method - Reporting methods vary by state; however, EPA has an initiative to move the DMR reporting online in the near future. The NetDMR online reporting system is used for the stormwater and wastewater DMR submittal.

Environmental Reporting - Hazardous Chemicals

Tier II Chemical Reporting

Requirements - Under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312, facilities must submit an emergency and hazardous chemical inventory form to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC) and the local fire department annually. Most states allow or require that the Tier II form be submitted in an electronic format. EPA makes available free Tier2Submit software. Electronic reporting via this software may be recommended or required by many states. Other states may use state-specific software or an on-line reporting tool.

Reporting Timeline - The Tier II Inventory report is due by March 1 of every year for extremely hazardous substances and hazardous chemicals present at the facility at any time during the previous calendar year in an amount that exceeded the reporting threshold.

Data Collection and Analysis - Core information reported on the Tier II, generally includes:

  • Facility identification information
  • Emergency contact information
  • Chemical information (maximum and average daily amounts, physical and health hazards, number of days on-site and storage types, conditions, and locations)

Reporting Method - Tier2Submit software to generate a .t2S file, or state specific online reporting system (e.g., STEERS reporting in Texas).

Environmental Reporting - Comprehensive Reports

Toxics Release Inventory (TRI)

Requirements - EPCRA Section 313 requires facilities in covered NAICS codes to file a Toxics Release Inventory (TRI) report annually for each Section 313 chemical exceeding an activity threshold. The Section 313 chemicals list contains over 600 chemicals and chemical categories.

Reporting Timeline - Reports are submitted to EPA and State or Tribal officials by July 1 of the year following the end of the previous calendar year.

Data Collection and Analysis - The TRI report requires data for all environmental media. The material consumption data is required to determine if the TRI chemical manufactured, processed, or otherwise used exceed the threshold. To develop the release pathways, all environmental data will be required including air, waste, water, and hazardous chemicals information that are used in other environmental reports.

Reporting Method - TRI reporting is through an on-line reporting system hosted on the Central Data Exchange (CDX) called the TRI-MEweb (TRI Made Easy - web version). The TRI-MEweb allows users to preload data from previous years' chemical reporting.

Stormwater and Wastewater DMRs

Requirements - Pollution prevention (P2) is any practice that reduces, eliminates, or prevents pollution at its source. P2, also known as “source reduction,” is the ounce-of-prevention approach to waste management. Reducing the amount of pollution produced means less waste to control, treat, or dispose of. Less pollution means less hazards posed to public health and the environment. The facilities that must prepare a P2 Plan include:

  • Facilities that report to EPA using the Toxics Release Inventory Form R; or
  • LQGs or SQGs of hazardous waste that report to the state agency on the Annual Waste Summary

The P2 plan Annual Progress Report (APR) required in Texas is intended to encourage facilities to assess and monitor their pollution prevention efforts, and to measure statewide progress in preventing pollution. Other states (e.g., Arizona) also have similar reporting requirements.

Sustainability Reporting - Carbon Disclosure

CDP Reporting

Requirements - The CDP is an investor-sponsored, non-profit organization based in the United Kingdom with offices across Europe, South America, Australia, New Zealand, India, China, Japan and the United States (note that the US office is located in New York City). The organization represents the collective interest of more than 800 institutional investors with over $100 trillion in assets. Given the strong investment community influence, CDP's objectives have always centered on gathering, analyzing and reporting environmental data (initially carbon/energy, then water and forest ecosystems) as a means for investors to improve the management of long-term risk in their portfolios.

The CDP system is based on a simple formula: measure, report and manage the key parameters of concern. Through that process, CDP firmly believes that companies will pay appropriately close attention to long-term sustainability issues and develop effective strategies for mitigation, while in the process, improving business performance.

Reporting Timeline - CDP response is due by July 31 of every year.

Data Collection and Analysis - Core information reported on the Climate Change questionnaire generally include these topics:

  • Governance
  • Risks & Opportunities
  • Business Strategy
  • Targets & Performance
  • Emissions
  • Energy
  • Additional Metrics
  • Verification
  • Carbon Pricing
  • Engagement
  • Other Land Management Impacts
  • Signoff

Reporting Method - CDP offers an online reporting system (OLS) for direct reporting of governance, strategy, and emissions information.

For more information on CDP reporting, see our recent article, “Voluntary GHG Reporting Via CDP”.

Benefits of Centralized Data Collection/Storage for Reporting

EQFall2019F-AnnualEnvironmentalReporting-Figure3Since annual environmental and sustainability reporting involves large amounts of data collection and analysis, understanding how these annual reports are correlated, and implementing a better data management system is important to effectively and accurately meet all reporting requirements.

Much of the data gathered in the first quarter of the year can be used for various reporting programs, and efficient data collection and utilization will significantly increase the accuracy and efficiency for the annual reports (see Figure 3).

Organized Data Collection and Management - A facility may develop an environmental calendar for all the applicable environmental reporting projects. Since various reports may use the same source data, better data management will lower the overall cost for data collection and analysis. The TRI report is due by July 1 of each year, which is after most of the other annual reports (except CDP), and requires a large amount of data collection, review, and analysis. The TRI report covers all environmental media (i.e., air, water, waste, hazardous chemicals).

If all data used for other annual reports are well documented and maintained, most of the data collection steps for the TRI report have been completed once the EI, Tier II, and annual waste summary reports are submitted. For example, a facility's material inventory data can be used to calculate air emissions in the EI report, and can be used to determine if the chemical throughput is above the TRI reporting threshold. In addition, the calculated air emissions in the EI report is the information required in the TRI Form R for chemical release. Once the annual EI report is completed, a portion of the TRI report data is completed as well.

Easy Comparison and Consistency - A facility may have multiple staff members or different contractors/consultants work on various annual environmental reports. This can pose a challenge in that the data collection may not be in a consistent format, or the same set of data can be interpreted in different ways. This increases the potential for discrepancies between annual reports. For example, federal, state or local agencies may compare the air emissions between the EI report and TRI report and question differences in values. The same set of raw data could be calculated in different ways in the EI or TRI report if different staff/contractors/consultants handle these reports. A centralized data collection and storage for environmental reporting system will maximize the consistency of utilizing data in the same manner and eliminate the discrepancies between various annual environmental reports.

No matter the combination of reports that your facility is required to complete, consistency and efficiency will ensure that compliance reports are accurate. While some find these reports to be burdensome, confusing, and time-consuming, by aligning resources and having a plan, these stressors can be greatly reduced. Trinity can assist in providing the tools and knowledge necessary to streamline the reporting process saving time and energy for the reporting in 2020.

For more information, please contact Trinity at (800) 229-6655 or complete the Contact Us form on our website.