At Farallon, our Permits and Regulatory Compliance Team helps business and landowner clients protect their assets, meet regulatory obligations, and satisfy permitting requirements. We assist our clients with their current or anticipated needs, whether by completing permit applications, evaluating current operations, preparing spill plans, responding to regulatory Notices of Violation, or supporting their legal counsel.
In this environmental compliance realm, the start of the new year means reporting season. As you get going on the new calendar, mark your site's important dates to pay attention to in the first half of the year.
OREGON
February
- 2/15/23: Industrial stormwater DMRs due
- 2/15/23: Many annual air reports/semi-annual compliance certifications due
March
- 3/1/23: Oregon Fire Marshal Hazardous Substance Information Survey due
- 3/1/23: Annual hazardous waste reports due
- 3/31/23: Greenhouse gas reporting due
May
- 5/15/23: Industrial stormwater DMRs due
July
- 7/1/23: Toxic Release Inventory ("Form R") reporting due
WASHINGTON
January
- 1/15/23: Industrial Waste Discharge reporting/self monitoring for King County jurisdiction
February
Annual Emissions inventory reporting for minor sources
- 2/1/23: Olympic Region Clean Air Agency: 30 days after the receipt of the notice which typically goes out at the beginning of the new year
- 2/15/23: Industrial stormwater DMRs due
- 2/21/23: Spokane Regional Clean Air Agency jurisdiction
March
- 3/1/23: Environmental Planning and Community Right to Know Act: Tier Two reports
- 3/1/23: Annual hazardous waste reports due
Annual Emissions inventory reporting for minor sources
- 3/1/23: Yakima Clean Air Agency jurisdiction
- 3/15/23: Southwest Clean Air Agency jurisdiction
April
Annual Emissions inventory reporting for minor sources
- 4/15/23: Washington Department of Ecology jurisdiction
- 4/15/23: Northwest Clean Air Agency jurisdiction
- 4/30/23: Benton County Clean Air Agency jurisdiction
May
- 5/15/23: Industrial stormwater DMRs due
- 5/15/23: Industrial stormwater Annual Report due
June
- 6/30/23: Puget Sound Clean Air Agency: 30 days after getting notice that an inventory is being requested.
July
- 7/1/23: Toxic Release Inventory reporting due
- 7/15/23: Industrial Waste Discharge reporting/self-monitoring for King County jurisdiction
CALFORNIA
January
Air
- 1/31/23: Sac Metro Air District Annual Report
- 1/31/23 to 3/1/23: Semi-annual monitoring/compliance reports
February
Air
- 2/1/23: California Greenhouse Gas Emission Inventory Program (registration deadline for Electric Power Entities)
March
Air
- 3/1/23: Santa Barbara Air Pollution Control District due March 1 (usage and/or emissions depending on source or permit requirements)
- 3/1/23: CARB Refrigerant Management Program (RMP)
- 3/15/23: Sac Metro Air District Annual Report if facility is part of Emission Inventory Program
- 3/31/23: Federal Greenhouse Gas Reporting Program
Hazardous Materials and Hazardous Waste
- 3/1/23: California and Federal hazardous waste reports for Large Quantity Generators and Treatment, Storage, and Disposal Facilities (TSDFs): Biennial reporting through DTSC satisfies the federal reporting requirement. Reports are due in even calendar years for the previous odd calendar year of data.
- 3/1/23: Hazardous Materials Business Plan (HMBP). Note that some regulatory bodies (CUPAs) have deadlines that are not synchronized with the 3/1 deadline (i.e., are 12 months from the previous filing). Contact your CUPA for your specific regulatory deadline.
April
Air
- 4/10/23: CARB California Greenhouse Gas Emission Inventory Program reporting deadline for facilities not subject to abbreviated reporting.
May
Air
- 5/1/23: South Coast Air Quality Management District –Annual Emissions Reporting (AER)
June
Air
- 6/1/23: CARB California Greenhouse Gas Emission Inventory Program reporting deadline for Electric Power Entities and for facilities subject to abbreviated reporting.
July
Multimedia
- 7/1/23: EPA Toxic Release Inventory (TRI) Reporting deadline
Water
- 7/15/23: SMARTS - annual report for stormwater discharges associated with industrial activities
- 7/15/23: SMARTS - Annual Comprehensive Facility Compliance Evaluation (ACFCE)
- Quarterly stormwater sample, upload results to SMARTS within 30 days of sampling event
- Some facilities may qualify for a reduction in sampling frequency
August
Air
- 8/10/23: CARB California Greenhouse Gas Emission Inventory Program verification statements due
Additional deadlines with custom due dates
Air - Toxic Emissions Inventory Plan and Report (TEIP & TEIR)
- Various due dates determined by each of the 35 California air districts. District will contact the business to create a TEIP and then submit a TEIR based on the District-approved TEIP
- Quadrennial updates required (Farallon can assist!)
Air - CARB Diesel Offroad Online Reporting System (DOORS)
- Required for facilities where the California-wide fleet of off-road diesel equipment or large spark engine forklifts/scrubbers/sweepers powered by gasoline, diesel, propane, LPG, CNG, etc. with 25 or more horsepower is comprised of greater than 3 pieces of equipment. Requires initial reporting and labeling and annual reporting (and, in some cases, phase outs of equipment)
- Provides a reduction in fleet average emissions for electric equipment, so reporting such equipment is encouraged.
Water - Spill Prevention, Control, and Countermeasures (SPCC)
- Complete a review and evaluation of current SPCC Plan every 5 years
- Plans must be amended within 6 months of changes in facility personnel, design, construction, operation, or maintenance that affects the potential for discharge
- Training on the SPCC Plan must be performed within 30 days of being assigned duties pertaining to handling oil-containing equipment and annually thereafter
Waste - DTSC Annual Electronic Verification Questionnaire
- Verification of hazardous waste manifest counts due 30 days from date of notification to file from DTSC