For Environmental Health and Safety (EHS) Managers or professionals, the new year brings a new outlook on your job, promises to yourself and your company, and the desire for improvement over the past year. Unfortunately, the new year also brings the crushing realization that March is just around the corner, almost taunting you for becoming cocky in November and December when few environmental reports are due to the State or EPA. March marks the beginning of the annual reporting deadlines.
The reporting calendar begins with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II report and the Annual Waste Summary (AWS) due March 1st, and then you dive right into the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) Benchmark Monitoring (BM) reporting and Discharge Monitoring Report, and the Air Emissions Inventory Report (AEIR), all due on March 31. Individually the reports are not overly difficult or time consuming to complete; but working on all of the reports within the same time period can be stressful. And if you are lucky enough to have multiple facilities, the effort and related stress can follow a nearly exponential trajectory.
For the past few years, W&M has looked at the all the major reporting deadlines during a one hour-long webinar. Realizing it was far too much material to cover and in an effort to avoid skimping on some of the reports, we sat down this year and decided to reorganize the webinar.
Maybe we had an epiphany, maybe we were excited about our acquisition by Braun Intertec Corporation, or maybe it just made too much sense to ignore, but this year, we are going to do something a little different. We’re breaking the material into two webinars so we can spend a little more time with each topic and answer some more questions from our faithful listeners. This first webinar is set for January 24, 2019 and will cover the reports due in March:
- Annual Waste Summary
- Stormwater Benchmark Monitoring and Discharge Monitoring Reporting
- EPCRA Tier II reporting, and
- the Texas Air Emissions Inventory
The second webinar is set for March 28, 2019 and will cover the reports due on July 1:
- EPCRA Toxics Release Inventory (TRI) Form R and Form A reports
- Pollution Prevention (P2) Plan Annual Progress Reporting.
In each of these webinars, we will cover some of the best ways to prepare yourself for the work involved and give you some tips on how to be successful. Remember all those hazardous waste and Class I waste manifests that you have been accumulating for the past year? Now might be a good time to get a head start on entering those into your STEERS AWS Annual Prep File (APF). Do you remember those stormwater samples you collected at the beginning of the year when it was so rainy, and then panicking because we didn’t see rain for nearly three months? And do you remember feeling relieved when we starting experiencing rain again in September, only to panic when the rain never stopped that month? You can go ahead and start preparing your SWP3 annual reports. While you are planning your end of the year activities, get a head start on your year waste inventory so you can fill that part of the AWS out correctly.
We will review tips like these to help you stay ahead of the curve as well as the changes you can expect this year. Two of the larger changes are that the Texas Tier II reports will now be submitted electronically via the new Tier II online reporting system and the SWP3 DMR will be submitted electronically via the TCEQ’s online NetDMR system. We will make sure you know how to register for these systems, so you don’t hit a snag down the road.