Environmental Consulting
EHS and Sustainability Reporting
The annual environmental reporting season can start the year with a stack of challenges, including reporting on new media, changes in processes/tools, and sometimes new regulations to decipher. Trinity ensures compliance, enhances data accuracy, and boosts efficiency in managing environmental and sustainability reports.
Regulatory reporting of an organization's EHS data involves data collection, validation and analysis, and report preparation and submittal to U.S. EPA, state or local agencies, or other authorities with jurisdiction. Required reports may cover a variety of environmental programs and media: air, waste, stormwater, wastewater, hazardous substances, and hazardous chemicals. Many of these reports must be submitted annually, and some environmental data are required for multiple reports.
During the first half of every year, most EHS professionals are engaged in the task of environmental reporting which can consume much of their immediate attention and energy, leaving little time for typical day-to-day responsibilities.
By partnering with Trinity to perform streamlined, integrated environmental reporting, the pressure on EHS professionals can be greatly reduced. Centralized data for environmental reporting also increases accuracy, efficiency, and consistency among various reports.
Annual Reporting Support
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Overview
Who May Need Annual Reporting Support and Why?
Because annual environmental and sustainability reporting involves large amounts of data collection and analysis, understanding how these annual reports are related and implementing an efficient data management system is important to meeting all reporting requirements effectively and accurately. Much of the data gathered in the first quarter of the year can be used for various reporting programs, and efficient data collection and utilization can significantly increase the accuracy and efficiency of the annual reports.
Trinity Consultants is unmatched in our understanding of regulatory and sustainability reporting requirements and implementation of best practices to streamline reporting and ensure accuracy. Our processes, deployed for the benefit of hundreds of organizations annually, help lower the cost of compliance, free up valuable staff time, and drive down the likelihood of missed deadlines or non-compliance issues. Our expertise in regulations and experience in effective management of the related data provide the building blocks for an optimized reporting process that is custom-designed to individual client needs.
State-Specific EHS Reporting Requirements
While EPA and other federal regulatory agencies develop rules and compliance requirements, how each state’s regulatory agency applies those can be different for each state. Trinity’s local presence across the U.S. and expertise with each state’s specific regulatory requirements enable us to provide you with the guidance and support to meet your state-specific obligations efficiently and accurately.
Air Quality
Air emissions reporting is typically one of the most onerous aspects of environmental reporting due to the technical complexity and the variety of programs and requirements.
- Air emissions inventories - To complete an annual emissions inventory (EI), a facility must collect data such as material throughput, equipment operating hours, monitoring data, sampling/testing data, scheduled maintenance activities, emission event reports, etc. Emissions are then calculated using the data collected and emission calculation methodologies based on the facility's New Source Review (NSR) permits or other EPA/State EI guidelines.
- Greenhouse gas reports - EPA's GHG Mandatory Reporting Rule requires that greenhouse gases (GHG) from certain industries/sources be reported on an annual basis to EPA. GHG reports include unique information that may align with the air emissions inventory and additional information such as industry-specific GHG emission factors and reporting requirements.
- MACT/NSPS/Title V Compliance Reports - Typically, the same data used to develop annual EI is needed for these MACT, NSPS, and Title V compliance reports to determine any exceedance of permitted emission rates. Additional information related to compliance with the specific permit conditions and applicable state and federal requirements must also be collected and reported.
Water Quality
EPA and state agencies with permitting jurisdiction develop general permits for stormwater and wastewater direct discharges. The federal program is the National Pollution Discharge Elimination
System (NPDES). Some states developed different types of general stormwater discharge permits applicable to specific types of facilities. States and municipal POTWs have permitting requirements for indirect discharges of wastewater.
Wastewater and stormwater sampling and analysis are integral parts of Clean Water Act (CWA) compliance. The CWA and EPA's NPDES regulations may require permitted facilities to monitor the quality of their stormwater/wastewater discharge and report the monitoring data to their permitting authority on a discharge monitoring report (DMR) or a Benchmark Monitoring form.
Reporting is required in the case of any non-compliance with an effluent limit, as well as all sampling results for effluent limits or benchmark monitoring in accordance with Sector-specific requirements, regardless of whether there was an exceedance.
Waste Management
With respect to waste reporting, Large Quantity Generators (LQG) and Treatment, Storage, and Disposal Facilities (TSDFs) must submit a Hazardous Waste Biennial Report by March 1st of each even-numbered year for hazardous waste activities during the previous odd-numbered calendar year.
Many states and territories require similar reporting on an annual basis. They may require reporting by facilities other than LQG and TSDF (e.g., Small Quantity Generator (SQG), Very Small Quantity Generator (VSQG), any facility that ships hazardous waste, shipping state hazardous waste, etc.). The report summarizes the amount of hazardous waste and state-specific waste generated or managed at the site during the calendar year.
Hazardous Chemicals Reporting
Under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312, facilities must submit a hazardous chemical inventory form (Tier II) to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC) and the local fire department annually. Most states allow or require that the Tier II form be submitted in an electronic format. EPA makes available free Tier2Submit software. Other states may use state-specific software or an online reporting tool.
EPCRA Section 313 requires facilities in covered NAICS codes to file a Toxics Release Inventory (TRI) report annually for each Section 313 chemical exceeding an activity threshold. The Section 313 chemicals list contains over 600 chemicals and chemical compound categories. The data reported under TRI is used to assess exposure risk and Environmental Justice scores for the reporting facility.
Pollution prevention (P2) is any practice that reduces, eliminates, or prevents pollution at its source. The facilities that must prepare a P2 Plan include facilities that report to EPA using the Toxics Release Inventory Form R or LQGs or SQGs of hazardous waste that report to the state agency on the Annual Waste Summary.
Energy & Sustainability Reporting
The CDP is an investor-sponsored, non-profit organization based in the United Kingdom that represents the collective interest of more than 800 institutional investors with over $100 trillion in assets. Given the strong investment community influence, CDP's objectives have always centered on gathering, analyzing, and reporting environmental data (initially carbon/energy, then water and forest ecosystems) to improve investors' management of long-term risk in their portfolios.
Through a focus on measuring, reporting, manage, CDP firmly believes that companies will pay appropriately close attention to long-term sustainability issues and develop effective strategies for mitigation while, in the process, improving business performance.