RY2024 Multimedia Compliance Reporting Tips And Tricks

Reporting Year 2024 (RY2024) Season has officially begun! There are a variety of federal and state reports due in the first half of 2025 that require data collection, analysis, and data entry. It can be overwhelming to keep track of all the different reporting websites, submittal instructions, due dates, and program updates for each year. Below is a list of tips and tricks for different reporting programs for RY2024, with a special focus on North Carolina and South Carolina.

U.S. Environmetal Protection Agency Central Data Exchange

Many federal reports are submitted through the U.S. Environmetal Protection Agency (U.S. EPA) Central Data Exchange (CDX) website. One important update that became effective August 2, 2024, when using CDX, Login.gov is the new access. The new login process allows a safe and secure sign-in. Existing users will be automatically routed upon logging in to CDX to begin the process of obtaining a Login.gov if they have not already done so.

Ensure well in advance that the certifying or designated official for your report(s) is set up in CDX, has access and can view reports, and understands their responsibilities with submitting the report.

Air Emissions Inventory Reporting

Air emissions reporting requirements and deadlines vary by state and size of facility. Make sure you know your facility’s obligations on how often to report, when to report, what pollutants to report, and how to report. Some facilities report actual air emissions of each pollutant that is over a certain threshold every year, some facilities are required to enter allowable emissions for pollutants that have specific permit limits, while some facilities may only be required to report actual air emissions when it is time to renew the air permit. You should read your state’s emissions inventory instructions to understand if there are emissions units that are exempt from reporting and how the inventory is submitted and certified (e.g., online system or paper submittal). Here are some tips for reporting in the Carolinas that could apply to other states as well.

North Carolina Air Emissions Inventory Reporting in Air Emissions Reporting On-Line

Emissions inventory notification letters or emails for each Title V facility required to do an annual emissions inventory due by June 30 will normally be mailed from the appropriate regional office in late January each year. The notification letters will include the North Carolina Air Emissions Inventory (AEI) Reporting in Air Emissions Reporting On-Line (AERO) User ID and PIN. While there are no major updates to AERO for RY2024, it is important to remember a few key items when working in AERO:

• The AERO Certification Statement page needs to be signed using blue ink.
• Be mindful when working in AERO not to unintentionally submit a report while completing the validation.
• North Carolina AEIs are due June 30^th, 2025, for facilities required to do an annual emissions inventory.

South Carolina Air Emissions Inventory Reporting in the State and Local Emissions Inventory System (SLEIS)

South Carolina facilities are required to submit their emissions inventory (the Point Source Data Report) in South Carolina Air Emissions Inventory Reporting in the State and Local Emissions Inventory System (SLEIS).

A facility is required to submit an emissions inventory annually if they are a Type A Source. Title V sources with potential annual emissions greater than or equal to the emissions thresholds provided by South Carolina Department of Environmental Services’ (SC DES) are listed here. If your facility is not a newly permitted facility or is a Title V facility with potential annual emissions less than the Type A thresholds, an emissions inventory must be submitted every three years beginning with calendar year 2014 data.

Any newly permitted and constructed Title V sources that have obtained or are in the process of obtaining their Title V permit must submit an initial emissions inventory for the first partial calendar year of operation and the first full calendar year of operation.

If an existing source is determined subject to the Title V Operating Permit Program, and/or in a nonattainment area (NAA), an emissions inventory must be submitted to the Department for the previous calendar year within 90 days and the source must determine the schedule for future inventories based on Regulation 61-62.1.

If you are working with a facility for which you have not previously entered a report, you must request access to the facility in SLEIS by e-mailing ei_submittals@des.sc.gov. Access is granted based on the preparer’s role within the ePermitting system (SC DES) online platform for permitting and reporting), so make sure you have access in ePermitting as well.

SLEIS offers a spreadsheet template that can be downloaded from the ePermitting portal, completed, and used to upload emissions data instead of hard entering the data. If you are entering data manually, when possible, utilize emissions factors that you know will be consistent year by year within the system (e.g., AP-42). This will trim down the amount of time spent entering total emissions because only a throughput will be needed for future reports. Also, if an emissions unit did not operate for the whole reporting year, be sure to mark its operational status as “Did not operate.”

Greenhouse Gas Reporting

You should understand whether your facility is required to submit greenhouse gas (GHG) reports to U.S. EPA or to your state under a regulatory program. One important update for RY2024 GHG reporting is the update to the 40 CFR Part 98, Subpart A, Table A-1 Global Warming Potentials (GWPs) outlined in the table below. GWPs should be updated in your calculations to reflect the revised GWPs from the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report (AR5). More information on GHG Reporting can be found in a previous 4 The Record Article, Final Amendments to Greenhouse Gas Reporting Regulations.

Other Air-Related Reporting

Know how to submit reports required by air quality regulations or your air quality permit. Your state may have a certain way it wants to receive reports, and U.S. EPA may have another mechanism. Make sure you submit to both agencies, if required. For example, Clean Air Act (CAA) compliance reports, certifications, and notifications for facilities in U.S. EPA Region IV must be submitted electronically to U.S. EPA Region IV (e.g., Annual Title V Certifications, 502(b)(10) notifications, etc.). U.S. EPA Region IV is no longer accepting paper submittals and your state’s system does not transmit your reports to U.S. EPA. Documents can be submitted electronically via email at EPA_R4_CAA_Reports@epa.gov or in the Compliance and Emissions Data Reporting Interface (CEDRI). For a list of reporting requirements and procedures by state, click here.

Emergency Planning and Community Right-to-Know Act (EPCRA)

Tier II Reporting

Tier II reports are required for any regulated facility that stores or handles more than 10,000 pounds of a hazardous chemical. A Tier II report is also required for a regulated facility that stores or handles any extremely hazardous substance (EHS) more than 500 pounds or its threshold planning quantity (TPQ), whichever is lower. The Consolidated Lists of Lists includes chemicals subject to Tier II reporting as well as other compliance reporting and can be found here. It is important to check the list every year for updates for the current reporting period.

Before you begin work on a Tier II report, make sure you have any new or updated safety data sheets (SDSs) for any chemicals stored at the facility. If you work on Tier II reports for multiple states, be mindful of which reporting program your State uses (e.g., North Carolina and South Carolina both use E-Plan). Make sure to log in well in advance of starting data entry to ensure you have full access to each facility you need.

Tier II reports are due March 1, 2025, which is a Saturday, so make sure to submit your report by Friday, February 28^th!

Toxic Release Inventory (TRI) Reporting

TRI Reports are due July 1. If a facility meets the employee, industry sector, and chemical threshold criteria, it must report to the TRI Program. For more details about the reporting criteria, refer to the TRI Reporting Forms and Instructions page.

Prior to starting your annual TRI report this year, review the Reporting Changes for RY2024. A few noteworthy changes for RY2024 include the addition of seven new per- and polyfluoroalkyl substances (PFAS) and the de minimis levels for some cobalt and antimony compounds, which are changing from 1.0% to 0.1%, among others.

Similarly to other reporting programs, it’s important to make sure you have logged into the reporting website, TRIMEweb, and assigned the appropriate Certifying Official well in advance of the deadline and confirmed with the individual that they have access and authority to submit the report.

While completing the TRI report, all applicable releases need to be quantified appropriately and accurately. It is important to ensure that the air emissions reported on the Facility AEI match the air emissions reported on the TRI. The TRI breaks out the emissions into stack/point and fugitive emissions, which may not always match the AEI depending on how the emissions are broken out. If this is the case for your facility, there is a designated location within TRIMEweb that allows you to make comments on any discrepancies. You can also use this comment section to provide explanations if you have a significant percentage change in releases from the prior year that may eliminate future questions from U.S. EPA during their review.

As you are preparing your annual reports check out our webpage for topical items such as webinars and articles. ALL4 can assist with your compliance reporting needs and help you navigate your state-specific requirements for completion and submittal. Please reach out to Lindsay Salvador at lsalvador@all4inc.com for assistance with your annual compliance reporting!