Environmental Reporting Deadlines Fast Approaching

If your business or facility emits pollutants (including greenhouse gases) to the air, has storm water flows, manages hazardous waste, or stores or otherwise uses certain toxic substances, then these regulatory reporting deadlines may apply to you.

 

Air emissions. Massachusetts Air Source Registration emissions reporting is required for certain triennial filers to the Massachusetts Department of Environmental Protection (MADEP) by April 3, 2023 for emissions that occurred in 2022. MADEP issued notices to those required to file. Deadlines for Annual Filers is May 1 or June 1, 2023, depending on your status.   If you must file by these deadlines and need help, or if you don’t know when your deadline is, contact SAK Environmental.

 

Toxic Substances Inventory Reporting. USEPA requires companies that store or otherwise have on-site Listed toxic substances at quantities that equal or exceed Planning Thresholds listed in Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) to submit EPCRA Tier II Inventory Form(s) to their State Emergency Response Commission, Local Emergency Planning Committee, and the local fire department.  Reporting is due March 1 annually and the March 1, 2023 deadline has past. Contact SAK Environmental if you need assistance with this filing or unsure if you are supposed to file.

Toxic Release Inventory Reporting.  TRI reporting is in addition to “inventory reporting” and may be required at both the federal and state level for Listed toxic substances that are manufactured, processed, or otherwise used at quantities equal to, or greater than, thresholds.  At the federal level, the USEPA requires reporting under EPCRA 313(b)(2).  In Massachusetts, reporting is required under the Toxic Use Reduction Act 310 CMR 50.00. The nature of reporting is similar for both federal and state regulators, and reporting to both agencies by July 1 annually is required.  The deadline this year is July 1, 2023 for toxic substances manufactured, processed, or otherwise used above regulatory thresholds in 2022.   

 

Storm Water.  Storm water generated from certain commercial and industrial properties may be subject to USEPA’s Multi-Sector General Permit (MSGP) if your business activity falls under a Listed NAISC code.  Entities subject to the MSGP must notify USEPA and prepare a site-specific storm water pollution prevention plan, or certify that your property satisfies criteria for Conditional No Exposure Exclusion.   Contact SAK Environmental if you generate storm water but don’t know if you are in a regulated NAIC code or require assistance implementing your storm water management program. 

 

Mercury Reporting.  Businesses and other entities that handle Mercury may require reporting to both the USEPA under the Toxics Substance Control Act (TSCA), and the Interstate Mercury Education & Reduction Clearinghouse (IMERC).  Reporting to both agencies is triennial for any amount of Mercury managed. Last year’s deadline was July 1, 2022 and the next deadline is April 15, 2025. If you manufacture, import, or use mercury or mercury-containing products, reporting may be required.  Contact SAK Environmental if you need assistance determining if reporting applies to your operation. 

 

Contact SAK Environmental at 978-688-7804, if you need assistance or have questions, and let our expert staff help you.