Mark Your Calendar: Tier II and Air Emissions Inventories Due

January means getting ready to meet the March, April, and May federal and state reporting deadlines, and we want help you in your preparation.  Depending on your state, air emissions inventories are due in March, April, or May (see below).

Tier II Deadline:  March 1, 2017

If your facility is covered by the Federal Emergency Planning and Community Right-to-Know Act (EPCRA) requirements, you 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 by March 1, 2017.

Minimum thresholds for Tier II reporting under Title III, Section 312 are as follows:

  • For Extremely Hazardous Substances (EHSs) designated pursuant to 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.)

Also by March 1, 2017, you need to report hazardous chemicals that were present at your facility at any time during 2016 at levels that equaled or exceeded these thresholds.

Air Emissions Inventory:  

March 1 for Connecticut and Pennsylvania,

April 1 for Maryland,

April 15 for New York,

April 30 for Delaware,

May 15 for New Jersey, and various other deadlines for other states

Make sure to check with your state for its filing deadline for the annual air emissions statement. While each state has slightly different requirements, most states mandate an annual inventory of air emissions to the atmosphere. The inventory must include a list of all criteria pollutants [oxides of nitrogen, carbon monoxide, sulfur dioxide, particulate, ground-level ozone (through reporting of VOC) and lead], greenhouse gases such as carbon dioxide and methane and hazardous air pollutants.

Reporting data can include stack tests, Continuous Emissions Monitoring data, material balance calculations and industry-specific emission factors.

Pennsylvania Residual Waste Biennial Reporting Deadline:  March 1, 2017

While most states only require the federal hazardous waste biennial report every two years, with the next report due in March 2018, Pennsylvania requires a biennial residual waste report every two years on alternating years with the hazardous waste report. Pennsylvania’s next residual waste biennial report is due on March 1, 2017.

Need help meeting these deadlines? We can help you not only meet the requirements but exceed them. We also are committed to sustainability and can work with you to improve the environment of your facility while contributing to a sustainable environment for everyone!

Please contact us at Environmental and Engineering Solutions or call us at 215-881-9401 to discuss your particular situation.

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