We at Braun Intertec, somewhat affectionately, refer to the time period of January 1 – July 1 as “Reporting Season” due to the myriad of compliance deadlines all crammed into that timeframe. As you will recall, it all begins on March 1 with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting and Annual Waste Summary (AWS) reporting deadline. Shortly after is the March 31 deadline for Air Emissions Inventory Reporting (AEIR) and the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) annual reporting. As you would expect, there are a number of pitfalls that you will want to avoid when completing your reporting. Here are a few to get you started:
Pitfall #1: Quality of Information
Not all information is created equal and not all information is good information. When gathering data, it is important to be specific as to what you are needing from your plant manager, operator, other data sources. And then, when you receive the information, it is important to review it promptly so you don’t accidentally paint yourself in a corner and have to scramble for more accurate data at the last minute.
Pitfall #2: Incomplete Information
A good example of incomplete information is your waste manifest documentation. As much as you may try to stay on top of your waste shipments, it is possible to miss one (or more). This is why it is so important to keep up with this data throughout the year and use all the tools available to you. These tools include your waste vendor’s website, spreadsheet tracking, and monthly data checks.
Pitfall #3: STEERS and netDMR Access!
Probably more so this year than in previous years, it is important to know what accounts you have to have access to in order to report. This year, SWP3 Discharge Monitoring Reports that are required to be submitted to the TCEQ are required to be submitted through the TCEQ’s netDMR website and Tier IIs reports are submitted to the TCEQ through the State of Texas Environmental Electronic Reporting System (STEERS) online software. If you already have a STEERS account for your AWS or AEIR, you will have to gain access to the Tier II program and sign your STEERS Participation Agreement (SPA). This registration is easy to do if you have a valid Class C Texas Driver’s License, but not so easy – and much more time sensitive since it can take up to three weeks for approval – if you do not as you have to submit a paper SPA.
Ultimately, you should confirm your access to the various programs early so that you do not have issues accessing the program or the data within the program when the deadline comes around. We hope this list of pitfalls will assist you as you prepare for your environmental reporting.
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