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EPA Reporting Requirements

January 13th, 2017

Tier II Reports (aka: Community Right-to-Know Reports) Due March 1st

iemaEach year, facilities with hazardous chemicals on hand must submit Tier II (Community Right-to-Know) forms by March 1st for the previous calendar year.  The Illinois Emergency Management Agency (IEMA) requires submission electronically using their Tier II Manager program.  Printed copies must also be submitted to the facility’s Local Emergency Planning Committee (LEPC) and fire department.

Submission of Tier II form is required under Section 312 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). The purpose of this form is to provide State, local officials, and the public with specific information on potential hazards. This includes the locations, as well as the amount, of hazardous chemicals present at your facility during the previous calendar year.

Tier II reports must include:

  • Details of the types and quantities of chemicals stored on site, above reporting thresholds.  Most chemicals have a minimum reporting threshold of 10,000 pounds. Extremely Hazardous Substances (EHSs) must be reported above 1 – 500 pounds, depending on the substance. Any quantity of phosphorus, for example, must be reported on the Tier II forms.
  • Type and location of storage container
  • A detailed site plan that meets minimum mapping requirements
  • Electronic Safety Data Sheets (SDSs)
  • Emergency contact information

If you need assistance completing your facility’s Tier II report, contact Gabriel’s Consulting Department at 773-486-2123 or WaterDept[at]gabenv.com.

August 3rd, 2016

Inaugural Liquid Hazardous Waste Annual Reporting Form due for Cook County on September 1st

Last year, Cook County passed the Liquid Hazardous Waste Ordinance which requires cook county sealfacilities in suburban Cook County to report their annual liquid hazardous waste generation and submit a corresponding fee.  The inaugural Liquid Hazardous Waste Annual report for the period January 1, 2016 and June 30, 2016 is due September 1, 2016.

Any facilities with less than 420 gallons of liquid hazardous waste in this time period still need to complete the form by the deadline but no fee will be assessed.  All facilities with greater than 420 gallons of liquid hazardous waste must include a $0.02/gallon fee with their report.

All liquid hazardous waste generated from July 1, 2016 – December 31, 2016 will be reported on a separate form due March 1, 2017.

For all liquid hazardous waste generated each year after 2016, the reporting period is January – December, and the annual report and fee is due March 1st of the following year.

Failure to submit this form on time may result in fines up to $10,000 for each offense.

If you need assistance completing this form, contact Gabriel’s Water Department at 773-486-2123 or waterdept[at]gabenv.com, or Steve Sawyer, CHMM, at 773-486-2123 or ssawyer[at]gabenv.com.

May 25th, 2016

EPA to update Hazardous Waste Generator regulations

U.S. EPA is currently reviewing comments to its proposed rule to update Hazardous Waste Generator regulations.  Most of these epa_logo2regulations are over 30 years old from when the Resource Conservation and Recovery Act (RCRA) hazardous waste amendments originally became law in 1984.  Today there are an estimated 353,300 – 544,300 facilities that generate hazardous waste across the U.S.  14,300 are classified as Large-Quantity Generators (LQGs) which generate 99% of the total hazardous waste produced each year.

The proposed rule includes provisions to:

  • Reorganize hazardous waste generator rules to make them easier to understand
  • Clarify provisions to improve compliance
  • Provide greater flexibility to generators
  • Strengthen environmental protection by closing important gaps where necessary

EPA states that these updated regulations will provide both economic and environmental benefits.  They anticipate this rulemaking will be finalized in 2016 and will be effective at the federal level six months after promulgation.

More information and specifics can be found on the EPA’s Hazardous Waste Generators webpage.

May 4th, 2016

EPA launches new Superfund database

EPA has launched the ‘Superfund Enterprise Management Systemepa_logo2 (SEMS) as a replacement database for the retired ‘Comprehensive Environmental Response, Compensation, and Liability Information System’ (CERCLIS) database.

SEMS contains sites that are either proposed to be, or are on, the National Priorities List (NPL) as well as sites that are in the screening and assessment phase for possible inclusion on the NPL. EPA’s Superfund program is responsible for cleaning up some of the nation’s most contaminated land and responding to environmental emergencies, oil spills and natural disasters.

Gabriel reviews nearby Superfund and NPL sites when conducting Phase I Environmental Site Assessments.  Our regulatory database search provider has updated their databases to include SEMS information.  Gabriel’s Phase I reports will now include SEMS data instead of CERCLIS data.

If you have questions about how Gabriel uses SEMS information in our Phase Is, contact Natalie Neuman at 773-486-2123 or nneuman[at]gabenv.com.

October 1st, 2015

Midwest Environmental Compliance Conference

MECC-rotate-gif

 

The first annual Midwest Environmental Compliance Conference (MECC) will be held October 29-30th at the Chicago Marriott O’Hare and will focus on EPA’s Region 5 (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin, and 35 tribes).

MECC events are hosted by state business and manufacturing associations and supported by U.S. EPA and State Agencies. These Midwestern environmental conferences:

  • Provide an insider perspective on key regional issues
  • Offer valuable, up-to-date information on rapidly-changing areas of regulation and law
  • Create a forum for valuable networking with regulators, clients and potential clients/customers
  • Foster meaningful, professional conversation with federal, state and local regulators
  • Deliver great speakers and thought leaders with unique insights, real experience, and a seasoned perspective
  • Provide an environmental “boot camp” training opportunity for those relatively new to environmental compliance and permitting or new to a particular environmental medium

 

Chicago’s conference will include sessions featuring administrators from U.S. EPA and state environmental agencies, including Illinois Environmental Protection Agency (IEPA), Indiana Department of Environmental Management (IDEM), and Wisconsin Department of Natural Resources (WDNR).

Some of the conference sessions will discuss:

  • U.S. EPA Regional Priorities
  • Emerging Water Issues
  • Hot Topics in Remediation and Waste Materials Management
  • Regional Air Issues Roundtable
  • Compliance Auditing

More information, the conference schedule, and registration can be found at mecconference.com.

September 16th, 2015

EPA issues new UST regulations for the first time in more than 25 years

U.S. Environmental Protection Agency (EPA) has updated its underground storage tank (UST) regulations for the first time since 1988.epa_logo2

Changes include:

  • Adding secondary containment requirements for new and replaced tanks and piping
  • Adding operator training requirements
  • Adding periodic operation and maintenance requirements for UST systems
  • Adding requirements to ensure UST system compatibility before storing certain biofuel blends
  • Removing past deferrals for emergency generator tanks, airport hydrant systems, and field-constructed tanks
  • Updating codes of practice
  • Making editorial and technical corrections

These changes will be effective October 13, 2015.

EPA estimates that these updated regulations will result in fewer releases of petroleum into the surrounding soil and groundwater, leading to savings for UST owners for avoiding environmental remediation, vapor investigation, and product loss.  Overall, after taking the costs for compliance into account, EPA estimates the net cost savings to UST owners across the U.S. to be more than $160 million annually.

Since the State of Illinois is not part of the EPA’s SPA (State Program Approval), UST owners in Illinois must meet the federal requirements in addition to the Illinois requirements.

In Illinois, the Office of the State Fire Marshal (OSFM) regulates USTs.  According to the Division of Petroleum & Chemical Safety, Illinois has already implemented many of these requirements with the 2010 rewrite of tank regulations and 2012 Part 176 Subpart F Operator Training addition.

Some of the bigger changes in Illinois will be:

  • 30-day walk through inspections instead of the current quarterly inspections
  • 3-year containment testing for sumps and spill buckets
  • 3-year inspection of overfill equipment
  • Elimination of ball float valves in vent lines as flow restriction devices for new tanks

Most of these changes above have a 3 year implementation requirement, so Illinois will update its rules by 10/13/18 to include these revisions.  The ball float valve elimination is effective 10/13/15, but only for new tanks.  Existing devices may remain as long as they are working.

“For the most part, there will be little if any noticeable adjustment needed to be made by retailers in the short term,” said Fred M. Schneller, Division Manager of Petroleum & Chemical Safety.  OSFM continues to review the new regulations and will issue guidance to tank owners/operators in the coming months.

For more information on the EPA’s changes, visit the EPA’s “2015 Revised Underground Storage Tank Regulations” website.

If you have questions about the implementation of these regulations in Illinois, phone/email contact information for the Office of the State Fire Marshal can be found on their website.

March 19th, 2015

‘Difficult to Manage Waste Streams’ Conference

air and waste management association logo

Join Gabriel at the the Air & Waste Management Association – Lake Michigan State Section (A&WMA-LMSS) for their annual waste conference – “Difficult to Manage Waste Streams.”

During this conference, you will learn the latest information concerning waste management issues, including regulatory updates from Region 5 States.

This conference is designed for everyone in the waste industry with a special emphasis on regulatory matters and how to implement innovative solutions and proven methodologies for working with waste.  Prominent leaders from government, industry, law and consulting will provide attendees with information and insights on a wide range of topics.  Attendees will also have the opportunity to network and meet with other professionals who share similar interests.

Gabriel’s Special Projects Manager Judy Freeman will be speaking on ‘Food Waste – Problems, Approaches, & Technologies’.

 

Thursday, April 30th, 2015

8:00 am – 5:00 pm

Hyatt Lounge at McDonald’s Campus

2815 Jorie Blvd, Oak Brook, IL 60523

 

For more information, visit the lmawma.org or download the conference brochure (Waste2015).

June 11th, 2014

Form A or Form R – Due July 1st

Form A or Form R (Toxic Chemical Release Inventory (TRI) reporting requirements) are due July 1st each year for all facilities that store or release toxic chemicals above reporting epa_logo2thresholds.

Facilities are required to report to the TRI Program if it meets ALL of these three threshold criteria:

  • The facility is included in a TRI-covered North American Industry Classification System (NAICS) code (see the TRI NAICS code webpage or Table I of the current Reporting Forms and Instructions for a complete list); and
  • The facility has 10 or more full-time employee equivalents (i.e., a total of 20,000 hours or greater; see 40 CFR 372.3); and
  • The facility manufactures (defined to include importing), processes or otherwise uses any EPCRA Section 313 chemical in quantities greater than the established threshold in the course of a calendar year.

EPA’s TRI website has a Threshold Screening Tool to help you determine if your facility is required to report TRI data.

If you need assistance completing your Form A or Form R, or have questions about the TRI program, contact Brigid McHale at bmchale[at]gabenv.com or 773-486-2123.