March 1st marks the filing deadline for a variety of annual environmental compliance reporting for industrial, commercial, institutional, and other facilities, including Emission Statements and Tier II Reports. Even if you do not normally submit these Reports, this year more facilities may be required to report due to the Pennsylvania Department of Environmental Protection (PA DEP) expanding the criteria for Emission Statement Reporting, as well as a surge in chemical usage at many hospitals and other institutions, potentially triggering Tier II thresholds. Being late with these reports can result in violations and penalties. We recommend that you talk with a regulatory specialist now if you need assistance in determining what reporting is required for your facility, or for assistance in submitting before the deadline.
Emissions Statements
Based on your facility’s Potential to Emit (PTE) for various air pollutants, you may be subject to Annual Emission Statement Reporting. This year, PA DEP is requiring all facilities to submit using their Annual Emission Statement AES*Online web-based software platform. New Jersey and other states use different reporting platforms. Generally, facilities are required to submit if:
- You are a Synthetic Minor or Title V source;
- You have submitted in previous years;
- You have received a letter or email from PA DEP requesting you to begin submitting; or
- PA DEP has requested you to submit after reviewing trends in your site’s actual emissions.
Tier II Reports
U.S. businesses and organizations that have chemical inventories above a certain quantity are required to fill out and submit Emergency Planning and Community Right to Know (EPCRA) Tier II Reports annually by March 1st. These reports are submitted to the Department of Labor & Industry with copies to your local Emergency Planning Commission and local fire departments. The Reports include a site plan with chemical locations, maximum and average quantities of substances onsite throughout the year, and emergency contacts.
To determine if you need to report, it is recommended that you do an inventory of what is onsite and then compare against EPA’s List of Thresholds along with state listings of affected substances. Reporting thresholds vary by chemical. Common chemicals to be reported include lead and acid from batteries, fuel oils, boiler chemicals, wastewater treatment plant chemicals, and oxygen and other gases. Other cleaning agents and chemicals may also require reporting. Pennsylvania uses a reporting system called PATTS while other states have similar reporting programs.
Residual Waste Biennial Reports
Residual Waste is industrial-related waste material that is not hazardous waste by definition under state or federal regulations. Please note that the Residual Waste Program is specific to the Commonwealth of Pennsylvania, and is not required in other states. Refuse typically identified as municipal waste in other states may be regulated under the Residual Waste Program in Pennsylvania. Examples of residual waste include, but are not limited to: waste tires, used oil, contaminated soil, used asphalt, dredge material, agricultural waste, coal refuse, and asbestos-and PCB-containing waste.
Generators of residual waste, who exceed either the 2,200 lbs/month average or 13 tons/year reporting threshold, are required to submit a biennial report to the Pennsylvania Department of Environmental Protection (PADEP or Department) by March 1, 2021.
The biennial report will typically include facility details, EPA ID number, waste generation data, source reduction strategies, disposal facilities information, and other data. Biennial reports can be submitted to the Department electronically.
Facilities requiring assistance with their 2020 Reporting Year Report should reach out to their regional PA DEP office or can contact EARTHRES at 800-264-4553 or click here.
Don’t risk getting a violation or fine by missing the deadline with one of these reports. Act now while you still have time to meet the deadlines. Contact us if you have questions or need assistance in figuring out or completing these or other required reports for your facility.
