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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New Final Rules on HFCs

The Environmental Protection Agency (EPA) finalized two rules this week aimed to reduce the projected growth and emissions of hydrofluorocarbons (HFCs). These are chemicals commonly used in refrigeration and air conditioning that are highly potent greenhouse gases, much more powerful than carbon dioxide.

The first rule involves the Significant New Alternatives Policy (SNAP) program. The EPA will be “adding to the list of safer and more climate-friendly chemicals for use in the refrigeration and air conditioning and fire suppression sectors; listing several new substitutes as unacceptable in specific end-uses in the refrigeration and air conditioning sector; and changing the status of a number of substitutes that were previously listed as acceptable in the refrigeration and air conditioning and foam blowing sectors.”

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TSCA Chemical Substance Inventory


The Chemical Data Reporting (CDR) Rule requires that manufacturers and importers report to the EPA information concerning the manufacturing, processing, and use of certain chemical substances listed in the TSCA Chemical Substance Inventory. The submissions for 2016 are due by September 30, 2016. This is the first time since 2012 that this reporting has been required, and some of the requirements have changed. The 2016 submissions are now required to report on activities conducted between 2012-2015, not just the previous year as required in 2012.

The submissions must be submitted via the EPA’s Central Data Exchange (CDX), the web-based reporting tool. Submissions can be submitted between June 1, 2016 and September 30, 2016. The reporting threshold for the listed substances is 25,000 lbs per site and is triggered if this threshold is met during any of the calendar years between 2012-2015. There is a smaller list of substances with a 2,500 lb threshold. These thresholds are the same for both processing and use information.

If your facility exceeds the threshold for any substance for any one calendar year between 2012-2015, that substance must be reported for all four years. For more detailed information, the EPA has published a guidance document for reporting and also a fact sheet.

If your facility needs assistance with completing these reports, contact us at EES and we can help.

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New Proposal for Electronic Hazardous Waste Fee Payments

In late June, the Environmental Protection Agency (EPA) issued a new proposed rule on the methodology for setting and revising user fees for the hazardous waste electronic manifest (e-Manifest) system. This is part of a larger development project aiming for a national system of tracking hazardous waste electronically.

According to the EPA, the e-Manifest system “will improve access to higher quality and more timely shipment data and will significantly reduce burden associated with the current paper system”.

This particular proposal involves the user fee methodology, specifically the following considerations:

  • who must pay e-Manifest user fees;
  • the types of transactions that will give rise to fees;
  • the formula that will be used to set fees;
  • options for making fee payments;
  • the process EPA will use to revise fees; and
  • the possible sanctions for non-payment.

The EPA also proposes “to tailor user fees according to whether manifests are submitted electronically or via paper to reflect the varying processing costs of these options”. The rule is currently open for comment on the Federal Register.

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Philadelphia Prison Systems Receives Special Recognition from the EPA

The Environmental Protection Agency (EPA) awarded special recognition in April to the City of Philadelphia for the Philadelphia Prison Systems innovative food recovery achievements. The prison system composted 1.35 tons of wasted food each day and saved the city $31,000 a year in landfill fees.

“The Philadelphia Prison System sets a tremendous example on using innovation to reduce food waste,” said EPA Mid-Atlantic Regional Administrator Shawn M. Garvin. “Businesses and communities across America are taking positive steps to address the food waste challenge, and they’re saving money, helping the environment, and feeding hungry people in the process.”

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Latest U.S. Greenhouse Gas Inventory Report

Last week, the Environmental Protection Agency (EPA) released the 21st annual Inventory of U.S. Greenhouse Gas Emissions and Sinks, more commonly known as the GHG Inventory. The report reviews greenhouse gas emissions on a nation-wide scale from 1990-2014.

The report tracks emissions and removals by source, economic sector, and type of greenhouse gas by utilizing national energy data, data on agricultural activities, and other national statistics. Additionally, the Greenhouse Gas Reporting Program provides data from individual facilities and suppliers of certain fossil fuels and industrial gases.

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Revisions to Hazardous Waste Regulations

In September 2015, the EPA announced a proposal for a large number of changes to the existing hazardous waste regulations. The current regulations were established by the Resource Conservation and Recovery Act (RCRA) and are housed in title 40 of the Code of Federal Regulations (CFR). The proposed changes would consolidate all of the regulations into two parts, 260 and 262 with 260 focusing on the classification of waste and 262 focusing on management standards.

There are over 50 proposed changes to the regulations. In a recent webinar by Triumvirate Environmental, 7 of the major changes were discussed and are summarized below:

  1. Large Quantity Generators (LQGs) with Conditionally Exempt Small Quantity Generator (CESQG) satellite facilities can consolidate waste at one facility and send out as one waste stream. CESQG will be renamed to Very Small Quantity Generators (VSQGs).
  2. CESQGs and Small Quantity Generators (SQGs) can have one event per year out of their status limitations without having to change their current status. Notification will be required 30 days prior to the event for planned events and 24 hours after the event for unplanned events.
  3. LQGs and SQGs will need to make arrangements with Local Emergency Planning Committees (LEPC) for emergency contingency plans. New LQGs will be able to submit an executive summary to the LEPC rather than a full contingency plan.
  4. LQGs and SQGs will need to mark containers with hazardous waste codes in satellite accumulation areas and in central accumulation areas.
  5. Biennial reporting will be required only for LQGs to report all waste generated. They can include the transferred waste from CESQGs in the same report.
  6. Cannot mix incompatible waste in the same container at satellite accumulation areas. If there is a danger to keeping containers closed, the container may remain open until danger subsides.
  7. If you are an LQG and cannot close as a “clean close”, you will have to close as a landfill.

The comment period for these proposed changes closed in December of 2015. There is no word at this point as to when the final rule will be issued, however it may come out in 2016.

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EPA’s 2017-2019 Enforcement Initiatives

On February 18th, the Environmental Protection Agency (EPA) announced its seven National Enforcement Initiatives for fiscal years 2017-2019. These initiatives are selected every three years by the EPA to “focus resources on national environmental problems where there is significant non-compliance with laws, and where federal enforcement efforts can make a difference”.

Out of the seven chosen initiatives, four are retained from the current set, one is expanded from the current set, and two are new. The four being retained and the one expansion are:

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Health Systems Come Together at the Conference on Climate Change

Health system representatives from 16 countries have come together at the United Nation’s Conference on Climate Change in Paris this week to announce a number of commitments and actions to reduce carbon emissions in the healthcare industry. More than 50 health systems, representing over 8,200 hospitals, have come to the conference to join the 2020 Health Care Climate Challenge. The challenge, led by Health Care Without Harm, requires health systems to pledge “to reduce their own carbon footprint, become climate resilient anchors in their communities, and pursue both political and economic solutions that will protect public health from climate change”.

“These hospitals and health systems are leading by example, reducing their own carbon emissions by 30, 50, even 80 percent.” said Gary Cohen, Founder and President of Health Care Without Harm. “At the same time, many are investing in clean renewable energy, while calling on leaders to implement policies locally, nationally, and internationally that foster a global transition away from fossil fuels.”

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Proposed Updates to the Cross-State Air Pollution Rule

The Environmental Protection Agency (EPA) is proposing updates the existing Cross-State Air Pollution Rule (CSAPR). The goal of the updates is to reduce summertime emissions of oxides of nitrogen (NOx) from powerplants that contribute to downwind ozone issues in other states.

As part of the Clean Air Act, states are required to develop state implementation plans (SIPs) that address interstate transport of air pollution that affects the ability of downwind states to meet clean air standards. In lieu of developing their own plans, states can default to the federal implementation plan (FIP). The updates to CSAPR provide the FIP that would apply if a SIP is not developed.

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