Upcoming Statewide Triennial Emissions Inventory

Two important reports are coming up next year that may have slipped your mind, given their infrequent occurrence. The Statewide Triennial Emissions Inventory will be due on April 15, 2024, and the Toxic Substances Control Act Chemical Data Reporting (TSCA CDR) will open on June 1, 2024, and will close on September 30, 2024. The beginning of each calendar year is already a busy time for reporting. With two additional reports being required, it is more important than usual for you and your environmental team to be proactive and prepare now for reporting season.

The Statewide Triennial Emissions Inventory is required by the Utah Division of Air Quality (UDAQ) every three years. Both minor and major sources are required to submit their emissions inventories for the previous year, i.e., all those with an air permit are required to report on their estimated actual emissions from 2023. This report focuses on emissions to the atmosphere of the six criteria pollutants: oxides of nitrogen (NO_X), carbon monoxide (CO), sulfur dioxide (SO₂), volatile organic compounds (VOCs), and particulate matter with aerodynamic diameters of less than 10 and less than 2.5 microns in diameter (PM₁₀ and PM_2.5, respectively).

Emissions of hazardous air pollutants (HAPs) and emissions from mobile sources on your site are also required to be included. All reporting is done on the State & Local Emissions Inventory System (SLEIS), which is an online reporting program.

The best tips to arrive at April 15, 2024, cool, calm, and collected? Begin now to harvest 2023 production data, work with your operators to fill in any gaps, and know that the whole process will likely take you several weeks longer than you think. Another friendly tip: UDAQ has, historically, been very inflexible regarding leeway on the April 15^th deadline. If you need any help, Trinity is happy to offer its experienced services.

The TSCA CDR report is very different from the Statewide Triennial Emissions Inventory. First, it is required by the U.S. Environmental Protection Agency (EPA) under TSCA, not by the UDAQ under the Utah Administrative Code. Second, it focuses on materials that are produced (manufactured) in and/or imported to your facility. You will be responsible for reporting how many pounds of each listed chemical is imported to, manufactured by, used on, and exported from your site. Other pieces of the report include how many employees were exposed to each listed chemical on site, as well as consumer or commercial exposure, including whether it was used in children’s products.

Furthermore, the TSCA CDR report requires four years’ worth of data since the last report, i.e., all data from 2019 through 2023. This report helps the EPA to understand how much of each of the more than 86,000 listed chemicals is in the country and how to best regulate them, as opposed to determining how much of each type of criteria pollutant makes it into the atmosphere.

The uniqueness of TSCA CDR requires that you work not only with the members of your manufacturing team, but also with your sales and supply chain teams in order to determine where your chemicals came from and where they went. Although June 1 to September 30 sounds like a long reporting period, it is the same four-month span as is given for the Statewide Triennial Emissions Inventory. And, like the UDAQ, the EPA is not known for their flexibility on the TSCA CDR reporting deadline.

As recommended previously, the sooner that you can begin to collect data and put together your reports, the better off you will be. All reporting is done electronically, on EPA’s Central Data Exchange (CDX) website. We wish you a successful reporting season, and, as always, remind you that Trinity is always here to help.

If you would like to discuss the Triennial Emissions Inventory or TSCA CDR reporting and how it may impact your facility, please email Brian Mensinger in Trinity’s Salt Lake City office or call 385.433.3384.