The first half of the year is always the busiest time for environmental reporting for Indiana sources. Following is a summary of major environmental reports to which many sources are subject to help ensure that no reports are missed or become last minute rushes during 2018.
Quarterly Monitoring Reports
Quarterly deviation and monitoring reports are due for sources with Title V permits and Federally Enforceable State Operating Permits (FESOP) by January 30, April 30, July 30, and October 30 of each year. The reporting forms attached to each source's permit should be used. However, it is also important to check the permit terms to ensure that all information required to be included in this report is submitted, even if a form is not attached to the permit.
Hazardous Waste Reports
Indiana RCRA Hazardous Waste Reports for Large Quantity Generators (LQGs), Small Quantity Generators (SQG), and Treatment, Storage, Disposal Facilities (TSD) are due on March 1, 2018. The instructions for submitting the report can be found on Indiana's Land Quality website.
Tier II Report
Tier II Emergency and Hazardous Chemical Inventory Report must be submitted by March 1, 2018. The Indiana Emergency Response Commission (IERC) requires that all applicable facilities submit the Tier II report electronically via the Tier II ManagerTM (IERC's online filing system).
USEPA issued revisions to 40 CFR Part 370 that will affect Tier II reporting under Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA)\SARA Title III. These revisions are intended to better align EPCRA\SARA Title III reporting with the revised OSHA Hazard Communication Standard (HCS) and facilitate safer management of hazardous materials.
USEPA has adopted the same categories for physical and health hazards established for the Safety Data Sheets (SDS) for Tier II Reporting. Specifically, the categories for reporting physical and health hazards in the 2017 Tier II have been expanded from five (5) to twenty-four (24), which is consistent with HCS categories. Current Safety Data Sheets (SDSs) should provide the information needed to update the physical and health hazard information for the next Tier II report.
This change is in effect for reporting year 2017. Additional information on the Indiana Tier II reporting can be found on the IERC 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 USEPA's electronic Greenhouse Gas Reporting Tool (e-GGRT) on or before March 31, 2018. More information for GHG reporters can be found on USEPA's MRR website.
Annual Compliance Certification
Annual Compliance Certification reports are due for sources with Title V permits and Federally Enforceable State Operating Permits (FESOP) by April 15th or July 1st of each year, see individual air permit for applicable due dates. The Annual Compliance Certification should summarize any deviations from permit conditions that occurred in the previous calendar year and also list corrective actions taken to correct the deviations.
Toxics Release Inventory
Sources required to file a Toxics Release Inventory (TRI) report must submit reports electronically to US EPA's CDX site by July 1, 2018. Applicability for TRI reporting is determined based on 1) industry sector (based on NAICS code), 2) the source employing 10 or more full-time employees, and 3) manufacturing, processing, or otherwise using a TRI-listed chemical in quantities above threshold levels in the prior calendar year. More information can be found on USEPA's TRI website.
Air Emission Statements
Air Emission Statements (AES) are due for sources with Title V permits, that emit actual emissions of NOx and VOC of 25 tons per year or more and are located in Lake, Porter, or LaPorte counties, or that emit actual emissions of lead of 5 tons per year or more. The frequency of reporting is based on the facility-wide potential to emit for various pollutants and should be documented in Section C of each facility's air operating permit. AES are due by July 1, 2018 and can be submitted electronically through IDEM's Emission Inventory Tracking System (EMITS).
Trinity Consultants has worked with numerous companies to develop and submit these reports. Please feel free to contact the local Indianapolis office at (317) 451-8100 with any questions or for assistance in preparing any of these reports.