Reporting Season

January through June every year is reporting season for environmental compliance people like myself. As annual reports go, the first is due on January 10th (a Michigan requirement), and the last is due July 1, with a bunch in between. So basically from January 2nd through the end of June most of industry's environmental peons are collecting, sorting, compiling, calculating, wading through, and sinking up to their chins in data. Different agencies and different states require pretty much the same data in different formats or for different purposes. I for example, report the amount of emissions generated from casting xx tons of iron in a given year. Some agencies want to know how many materials we have on site over 10,000 lbs, for emergency response purposes. Some agencies want to know how much air pollution was generated while we made xx tons of iron. Others want to know how much of all types of pollution was generated. Still others want to know only how much waste was generated. And others want to know how much water we sucked from the ground and how much we put back in. I also report that we're doing what our permits say we're supposed to be doing, or that we're not. I also have to create reports for nobody at all - files that sit in the file cabinets on the chance that an inspector will come by the facility and want to read them over, which does sometimes happen.

I generate a LOT of paper and I hate it. It is quite ironic that the environmental people at businesses create such incredible amounts of paper. Luckily, more and more agencies are converting to electronic or online report preparation and submission. In that case, the only paper actually required is usually just one signature page. That covers reports, but doesn't always cover your a$$. When an inspector shows up to view a report, we have to be able to show how we arrived at the numbers we've reported, and show backup documentation that supports them. Yep, more paper. Then, the electronic programs often don't let you copy last year's report and just change the production index, you actually have to enter all or most of the information again, which means you have to have a hard copy of last year's report. Yep, more paper.

Our environmental agencies, while getting better, are just as bureaucratic as any other government entity. They have an increasingly important job to do, so we should be fighting to streamline and improve the functioning of those agencies so more of the money can be channeled to the efforts that really matter.

Permitted to Pollute

I often get the impression that many people do not understand what an environmental permit is - and that's OK because few people ever deal with them. Well, permits and figuring out how to comply with them happens to bring home my bacon.

A permit is just a document issued by a regulatory agency. An environmental permit is the same, but the issuing agency has some authority over the air, water, or land. So an air permit is issued by an agency (usually the state) to a facility and describes how much of a list of pollutants that facility may emit, legally, into the air.

For example, your local dry cleaner has an air permit that may list VOCs (Volatile Organic Compounds - many solvents fall into this) and may give a limit of 2.0 pounds per hour. That means that your dry cleaner may legally release up to 2 pounds per hour of VOCs into the air, or up to 17,520 pounds per year (2 pounds/hour * 8760 hours/year). They have to demonstrate compliance with that limit by testing the stack once in a while.

Water permits work in much the same way - describing what that maximum concentration of a pollutant may be in the water they discharge to a body of water.

For more info on permits, let me know what specifically you're curious about and I'll send you the info. For general info, start at the US EPA.