ENV-06-163 Regulatory Reporting Requirements for the Petroleum Industry

Description:

The U.S. petroleum refining industry has now had several years of experience with reporting under various environmental rules and regulations. Reporting is a required element of nearly every federal, state, or local environmental standard. The major routine environmental reporting requirements at a refinery include Title V compliance certification reports, annual air emissions inventory reports, various air compliance reports related to federal and state standards, the Emergency Planning and Community Right-to-Know Act 312 and 313 annual reports, annual National Pollutant Discharge Elimination System (NPDES) reports, annual waste reports, Storm Water Pollution Prevention Plans, and Spill Prevention, Control, and Countermeasure Plans. Usually, on-site environmental staff do the environmental reporting, but in some cases a company circulates standard, or template, documents to ensure the consistency of its submittals. Reporting requirements are sometimes at a regular interval, such as quarterly, semiannually, or annually, but may be as needed, such as release reporting. Some standards allow the reporting for related rules to be included in the same report (such as consolidated reporting of tank inspections under 40 CFR 60 Subpart Kb), but most standards require separate reporting by rule. Environmental reporting is a key and important element in any refinery environmental compliance program. This paper is an update of a paper presented by Berglund et al. at the 1997 National Petrochemical and Refiners Association (NPRA) environmental conference (Berglund, Mollhagen, and Zavros 1997, NPRA paper number ENV-97-18). The 1997 text is used as the basis of this paper, and updates are provided, as appropriate.