See the latest EHS federal and state regulatory updates due to COVID-19

Environmental and Sustainability Reporting

Regulatory reporting of an organization's environmental data involves data collection, validation and analysis, and report preparation and submittal to the U.S. Environmental Protection Agency (EPA), state or local agencies, or other authorities with jurisdiction. Required reports may cover a variety of environmental programs and media: air, waste, stormwater, wastewater, hazardous substances, and hazardous chemicals. Many of these reports must be submitted annually, and some environmental data are required for multiple reports.

During the first half of every year, many environmental professionals are engaged in the task of environmental reporting which can consume much of their immediate attention and energy, leaving little time for typical day-to-day responsibilities. By partnering with Trinity to perform streamlined, integrated environmental reporting, the pressure on environmental professionals can be greatly reduced. Centralized data for environmental reporting also increases accuracy, efficiency, and consistency among various environmental reports.

Environmental Reporting Requirements

Air Quality

Air emissions reporting is typically the most onerous of aspects of environmental reporting due to the technical complexity and the variety of programs and requirements.

  • Air emissions inventories - In order to complete an annual emissions inventory (EI), a facility must collect data such as 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.
  • Greenhouse gas reports - EPA's GHG Mandatory Reporting Rule requires that greenhouse gases (GHG) from certain industries/sources be reported on an annual basis to EPA. 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.
  • MACT/NSPS/Title V Compliance Reports - 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.

Waste Management

With respect to waste reporting, Large Quantity Generators (LQG) and Treatment, Storage, and Disposal Facilities (TSDF) must submit a Hazardous Waste Biennial Report by March 1st of each even-numbered year for hazardous waste activities during the previous odd-numbered 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.

Water Quality

EPA and state agencies with stormwater permitting jurisdiction develop general permits for stormwater and wastewater discharges. The federal 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 case of any non-compliance with an effluent limit for any of the hazardous metals as well as all results of sampling for effluent limits or benchmark monitoring 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 or a Benchmark Monitoring form.

Hazardous Chemicals Reporting

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.

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.

Pollution prevention (P2) is any practice that reduces, eliminates, or prevents pollution at its source. 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

Sustainability Reporting - Carbon Disclosure

The CDP is an investor-sponsored, non-profit organization based in the United Kingdom which 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.

Through a focus on measure, report, manage, 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.

Optimized Reporting

Since annual environmental and sustainability reporting involves large amounts of data collection and analysis, understanding how these annual reports are related and implementing an efficient 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 can significantly increase the accuracy and efficiency for the annual reports.

Trinity Consultants is unmatched in our understanding of regulatory and sustainability reporting requirements and implementation of best practices to streamline reporting and ensure accuracy. Our processes, deployed for the benefit of hundreds of organizations annually, help lower the cost of compliance, free up valuable staff time, and drive down the likelihood of missed deadlines or non-compliance issues. Our expertise on the regulations and experience in effective management of the related data provide the building blocks for an optimized reporting process that is custom designed to individual client needs.

For more information, please contact Trinity at  (800) 229-6655 or Contact Us online.

Related Resources

Articles

Training

Classroom Training

On Demand