The beginning of the year is always the busiest time for environmental reporting for Illinois sources. The following is a summary of major environmental reports due in the first few months of the year.

Semi-Annual Monitoring Reports

Many of the Clean Air Act Permit Program (CAAPP) permits issued within the past several years have updated due dates for Semi-Annual Monitoring Reports (SAMR). The most common deadlines are now January 31 and July 31 as opposed to the previous deadlines of March 1 and September 1. Be sure to check the deadlines in your facility's CAAPP permit as soon as possible to avoid a Notice of Violation (NOV) from the Illinois Environmental Protection Agency (Illinois EPA). Also, many CAAPP permits provide additional clarity on what constitutes required monitoring to be included in the report, which may include monitoring, testing, recordkeeping and reporting requirements.

Hazardous Waste Reports

This year, Illinois is using the EPA's federal Biennial Report System for entities required to report hazardous waste generation or management information. Individuals that submit reports to Illinois EPA on behalf of the regulated companies will need to be registered through RCRAInfo to enter data or submit the report.

Illinois EPA also highly recommends that each company required to submit the Illinois Annual Hazardous Waste Report has one company officer or manager designated as the “Site Manager role” in RCRAInfo.

The generator fee of $500 remains in effect for anyone that was a Large Quantity Generator (LQG) in one or more months during the year. The fee and report will be due on March 1, 2020.

More info regarding the transition to RCRAInfo can be found on the Illinois EPA's website.

Tier II Report

Tier II Emergency and Hazardous Chemical Inventory Report must be submitted by March 1, 2020. The Illinois Emergency Management Agency (IEMA) requires that all applicable facilities submit the Tier II report electronically via the Tier II ManagerTM (IEMA's online filing system).

Additional information on the Illinois Tier II reporting can be found on the IEMA website.

Greenhouse Gas Reporting

The Greenhouse Gas (GHG) Emissions Report, which is to be submitted per the requirements of the Mandatory Reporting Rule (MRR), is due for electronic submittal using EPA's electronic Greenhouse Gas Reporting Tool (e-GGRT) on or before March 31, 2020. More information for GHG reporters can be found on EPA's website.

If you have any questions or would like our support during this reporting season, please contact Trinity's Illinois office at (630) 495-1470 or our Missouri office at (636) 530-4600.