March 1st Environmental Reporting Deadline

The Environmental Protection Agency (EPA) as well as state and local environmental agencies require a number of annual reports for qualifying facilities.  A few of these reports have a deadline of March 1st.  It is good practice to start these reports early to provide ample time to complete all reports by the March 1st deadline.  Two of these include the Tier II Chemical Inventory Report and the Hazardous Waste Report, both due March 1st, 2014.

The Tier II Report is an inventory of hazardous chemicals stored and used at a facility.  Submission of the Tier II form (when requested) is required by Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986, Section 312.  The minimum thresholds that require reporting are as follows:

  • For Extremely Hazardous Substances (EHSs) designated under section 302 of Title III, the reporting threshold is 500 pounds (or 227 kg.) or the threshold planning quantity (TPQ), whichever is lower;
  • For all other hazardous chemicals for which facilities are required to have or prepare an MSDS, the minimum reporting threshold is 10,000 pounds (or 4,540 kg.).

This report can be mailed in or done electronically, depending on the location of the facility.  For example, in Pennsylvania, the Pennsylvania Tier II System (PATTS) can be used to create and submit the Tier II report.

The Biennial Hazardous Waste Report is also due by March 1st, 2014.  This report is due every other year.  It is required by Resource Conservation and Recovery Act (RCRA). A facility is required to complete this report if the site:

  • Met the definition (see below) of a RCRA Large Quantity Generator (LQG) during 2013; or
  • Treated, stored, or disposed of RCRA hazardous wastes on-site during 2013

A site is a RCRA Large Quantity Generator (LQG) for 2013 if the site met any of the following criteria:

  1. The site generated, in any single calendar month, 1,000 kg (2,200 lbs.) or more of RCRA non-acute hazardous waste; or
  2. The site generated, in an single calendar month, or accumulated at any time, more than 1 kg (2.2 lbs.) of RCRA acute hazardous waste; or
  3. The site generated, in any single calendar month, or accumulated at any time more than 100 kg (220 lbs.) of spill cleanup material contaminated with RCRA acute hazardous waste.

In addition to these two reports, a number of states also require annual air emissions reporting.  These reports are often due March 1st as well.  These reports require facilities to submit an inventory of all air emissions created during the previous year.  For example, in Pennsylvania, the Annual Emissions Statement is required for various facilities.  The report contains operating schedules, throughputs, and emission estimates to calculate air emissions from industrial sources.

These three detailed reports can be cumbersome, time-consuming and at times, difficult to complete.  Using an environmental consultant can decrease a facilities time spent on these reports, as well as ensure that the reports are completed on time and correctly.  EES can help your facility with any or all of these reporting requirements. Contact us with any questions.

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