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It’s All About Who You Know and Knowing What To Look For

Let’s face it, during environmental reporting season, it seems like co-workers will intentionally walk halfway around your facility to avoid being sighted out your doorway.  The co-workers that normally stop by your office every other day or go to lunch with you are all of the sudden M.I.A.  The hint of Tier II, TRI, AEIR, or AWS talk sends them scrambling for the exits.  Information gathering for environmental reporting is time consuming but it doesn’t have to be scary or tedious.

Before you dive headfirst into your data gathering, consider assembling a team of veteran coworkers from the various departments within your facility.  Some of the more valuable helpers we rely on are purchasers, maintenance managers, and line managers from each value stream.  Purchasers have access to a wealth of knowledge such as quantities of chemicals purchased, typical or average inventory, and which departments are ordering which chemicals.  Maintenance managers are typically responsible for making sure that all of the equipment is running as intended.  As such, they often know reservoir capacities, lead-acid battery locations and sizes, types and amounts of various oils on-hand and at what frequency the oil is changed in the machines.  Line managers often have production numbers and amounts and locations of chemicals stored in their areas.  Another often overlooked resource is a member of the IT Department.  Uninterruptable Power Supplies (UPSs) contain lead-acid batteries and are often associated with server rooms or computer rooms and are typically inventoried by the IT Department.

When assembling your team, it is important to consider traits such as:

  • experience – do they have an in-depth understanding of the operations,
  • consistency – are they likely to be with the company in future reporting years,
  • availability – are they a part-time employee or are they in the middle of another project that might preoccupy their time when you are depending on them to help you, and
  • reliability – are they going to make the data gathering a priority and get requested data to you in a timely manner.

In order to effectively gather the information you need, it is important to be specific and make sure your team members know the purpose of the report and specific details that are needed.  While the Emergency Planning Community Right-To-Know Act (EPCRA) Tier II and Toxics Release Inventory (TRI) reports seem similar at first glance, it is necessary to differentiate between the two and stress that the Tier II report looks at hazardous chemicals present at your site at any given time while the TRI report deals with the amount of chemicals manufactured, processed, or otherwise used (MPOU) during the previous calendar year.  When gathering information for your annual waste summary (AWS) it is important to know what wastes are reportable.  Generally, only hazardous and class I wastes that are not recycled are reportable.  By ruling out the non-reportable wastes, it will cut down on the amount of data required and, consequently, the amount of time required.  In terms of your annual stormwater benchmark monitoring report (BMR) and/or discharge monitoring report (DMR), this information should be maintained within your Stormwater Pollution Prevention Plan (SWP3) binder.  The more specific you can be in your requests, the more efficient your team can be and the more likely they will agree to help you during the next reporting season.

The Texas Commission on Environmental Quality (TCEQ) and the U.S. Environmental Protection Agency (EPA) have compiled a handful of valuable resources that can be referenced throughout the reporting season.  We will go over some of those resources during our February 22, 2018 Webinar on tips and tricks for environmental reporting.  An often overlooked resource is an anonymous call to the regulating agency or the associated “help desk” which allows you to ask specific questions and get answers or related guidance on the topic at hand. As with any project, a well-rounded team that works together toward a common goal is extremely valuable.  Reporting season is a stressful time of year, so be sure you celebrate with your team after the reports are all complete and relax… at least for a couple days before it is time to start planning for the next year’s reporting season.

For questions or comments please contact Nick Foreman or Lori Siegelman.

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