March 2022 Environmental Reporting Deadlines
Jack Benton, CSD
Environmental Health & Safety Manager, Fire Inspector, Building & Fire Protection Plan Reviewer & Loss Control Consultant
For many facilities, March 2022 brings deadlines for reports on hazardous waste generation and management, chemical inventory and emergency preparedness, and/or air emissions of greenhouse gases.
RCRA Biennial Report
Regulatory Requirement: 40 CFR 262.41
Report Deadline: March 1
By March 1 of every even-numbered year, a large quantity generator (LQG) of hazardous waste must submit a Biennial Report that covers all hazardous waste activity from the previous year. A generator that exceeds the LQG generation threshold during any month in 2021 must submit a report that covers all hazardous waste activity from the reporting year (i.e., 2021).
Note: A very small quantity generator or small quantity generator that exceeded the LQG threshold due to an “episodic event”—and complied with the alternative management standards at 40 CFR 262, Subpart L—would not have to prepare a biennial report (unless they exceeded the LQG threshold in any other months in 2021).
As part of the Biennial Report, LQGs must submit the Site ID Form (Form 8700-12) to re-notify EPA of the generator’s activities [40 CFR 262.18].
EPCRA Hazardous Chemical Inventory Report
Regulatory Requirement: 40 CFR 370
Report Deadline: March 1
Facilities subject to OSHA’s hazard communication requirement (29 CFR 1910.1200) to prepare or have Safety Data Sheets (SDSs) for hazardous chemicals may have to prepare a report for certain hazardous chemicals present at the site.
This Emergency Planning and Community Right-to-Know Act (EPCRA) report must include every hazardous chemical that was present at the site above a specific amount at any time during the previous year.
For most hazardous chemicals, the reporting threshold is 10,000 pounds or more. For Extremely Hazardous Substances (EHS) listed in 40 CFR 355, Appendix A, the reporting threshold is either the Threshold Planning Quantity (TPQ) or 500 pounds, whichever is lower.
For example, acrylonitrile is subject to inventory reporting for its TPQ of 100 lbs. Adiponitrile, on the other hand, has a TPQ of 1,000 lbs. and so is subject to the 500 lbs. threshold.
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Facilities may submit a Tier I Form, which groups substances by hazard category (e.g., flammable, corrosive) or submit a Tier II Form for each covered substance. Generally, local emergency responders and state regulations dictate which form(s) facilities must submit.
Greenhouse Gas (GHG) Emission Report
Regulatory Requirement: 40 CFR 98
Report Deadline: March 31
Certain stationary source categories, large combustion facilities, and greenhouse gas suppliers may be required to submit information electronically to EPA regarding their greenhouse gas emissions during the previous calendar year.
Twenty-one source categories must report annually, regardless of their GHG emission volume. However, most covered sources must exceed a minimum carbon dioxide equivalent (CO2e) threshold of 25,000 metric tons or more of the covered greenhouse gases.
The EPA maintains a list of covered greenhouse gases, such as carbon dioxide, methane, nitrous oxide, and various hydrofluorocarbons. Each listed substance is assigned a global warming potential (GWP) 40 CFR 98, Table A-1]. A substance’s CO2e is determined by multiplying the actual emissions by the assigned GWP.
Methane, for example, has a GWP of 25. So, 1,000 metric tons of methane emissions would be the CO2e of 25,000.
Information courtesy of Lion Technology Inc. ©