Latest Compliance News
Chicago Non-attainment Area Changes
The Chicago nonattainment area has changed its status from moderate to serious. This means that by September 23, 2020, all facilities in the Chicago nonattainment area that have FESOP permits with permitted VOM or NOx emissions greater than 50 tons/yr, must revise their FESOPs to reduce their permitted VOM and/or NOx emissions to less than 50 tons/yr, or the facilities must change their permit to a Title V - Clean Air Act Permit. The Illinois EPA has issued letters to those facilities that are affected by the change.
Hazardous Waste Rule Changes
It is expected that sometime in 2017 more than 60 rule changes that impact the handling of hazardous wastes will become effective when the Illinois EPA adopts the US EPA's new rules. The major changes include the use of "type of hazard labels" on containers when waste is first placed in the container, re-notification requirements for SQG's, episodic waste generation allowances for SQG's and VSQG's, and quick reference guide requirements for emergency response and contingency plans.
Hazardous Waste Manifest Submittal
The Illinois legislature has eliminated a hazardous waste requirement. A copy of every hazardous waste manifest is no longer required to be submitted to the Illinois EPA, effective July 16, 2015.
Previously, Illinois required that the generator send a copy of every hazardous waste manifest to the agency. This was not a federal requirement, and was often overlooked by companies.
The generator is still required to maintain a copy of each manifest at their place of business. Illinois EPA waste inspectors will ask to see those copies, along with other required records.
Solvent Contaminated Wipes excluded as hazardous wastes
Illinois has adopted the new Federal regulations covering the management of solvent-contaminated wipes.
This excludes solvent-contaminated wipes from the definition of solid waste and hazardous waste under certain conditions. This is a loosening of the EPA regulation for wipes, which includes shop towels, paper towels, rags, and absorbent pads.
The generator will still have management requirements, and the waste will still be an Illinois Special Waste.
For additional information see our Special Notice for details.
Tier 2 Reporting Changes
The U.S. EPA has added new required elements to the form and made changes to other areas of the form.
The changes include:
- New reporting codes were added for chemical storage amounts;
- New sections were added for reporting pure chemicals and chemicals found in mixtures;
- Details must be provided to describe the storage container types and conditions;
- The facility must indicate whether it is subject to Section 313 TRI reporting, EPCRA Section 302 reporting, and Section 112(r) of the Clean Air Act reporting for the Risk Management Program.
NPDES Storm Water Permit Renewal
UPDATE 5/30/14: The General Industrial Storm Water Permit has technically expired in Illinois (April 30, 2014). However, the agency has not issued a new general permit, so the previous permit remains in force. Last time they issued the new permit one year late, and we would anticipate a similar delay this year.
NEWS: The renewal deadline for the General NPDES Storm Water Permit in Illinois is October 31, 2013. This will require a form to request continuing coverage. There will be new information required for this, and a current SWPPP must be submitted to the agency for the renewal to be accepted.
Complicated Regulations Impact Stationary Reciprocating Internal Combustion Engines
The U.S. EPA has passed regulations regarding stationary reciprocating internal combustion engines (RICE), including emergency and non-emergency generators.
This regulation covers almost all industrial facilities that have emergency generators – even facilities that are not required to have an air permit.
- For additional information about our services regarding RICE, please see our RICE Special Notice
Boiler MACT Rule Finalized by U.S. EPA
The U.S. EPA announced new limits for commercial boilers and incinerators..
Existing major source boilers subject to numerical emission limits will have until early 2016 to comply with the standards.
Existing area source boilers will have until March 21, 2014 to comply with these standards. For both boiler types, an additional year to comply may be requested.
Tougher Regulations for Chromium Electroplating & Chromium Anodizing
On September 19, 2012 the U.S. EPA adopted amendments to its air pollution regulations covering chromium electroplating, chromium anodizing tanks, and steel pickling facilities. For the chromium facilities, the air emission limits are lowered. A new stack test may be necessary to show compliance.
The changes also include housekeeping practices and electronic reporting.
Illinois Annual Non-Hazardous Waste Report Eliminated
As of July 2012, the Illinois Non-Hazardous Waste Annual report has been eliminated. No report will be due for 2012 year.
This annual report was required in the past for Non-Hazardous Wastes and for PCB Wastes that were sent out of Illinois.
New Illinois Rule for Solvent Cleaning Operations
The Illinois EPA has issued a new regulation addressing Solvent Cleaning Operations. The rule covers virtually any facility in the Chicago metro area that uses solvent cleaners containing Volatile Organic Materials (VOM), including cold cleaning (i.e. parts washers), vapor degreasing, wipe cleaning, spray gun cleaning, equipment cleaning, floor cleaning and tank cleaning.
SOLVENT CLEANING RULE CHANGES
On July 27, 2011, the Illinois EPA finalized many important changes to their recent Solvent Cleaning regulations (35 IAC 218.187). The original regulation is complicated and the changes are also complicated.
Streamlining of Illinois EPA Air Permitting Program
The Illinois Environmental Protection Agency (IEPA) recently initiated a new air permitting program for Smaller Sources. The program is called ROSS, which stands for the Registration of Smaller Sources. Under this program, facilities that currently have Lifetime Operating Permits and emit small amounts of air pollution are likely eligible to register as a “Smaller Source.”
POSITIVE IMPACT. The potential benefit of the ROSS Program to our clients that qualify as a Smaller Source is that they would no longer be required to
(1) have an Illinois air permit,
(2) complete the Annual Emission Report, and
(3) obtain a Construction Permit to add new equipment.
- For additional information about our services regarding ROSS, please see our ROSS Special Notice
- For additional information or a copy of the regulation see our Special Notice
New Deadline for Oil Spill Plan Implementation
The compliance dates for most industrial facilities to amend or prepare and implement their SPCC Plans has been extended to November 10, 2011. Also, the latest amendments to the rule issued December 5, 2008 became effective January 14, 2010.
Existing facilities must maintain their SPCC Plan in accordance with the regulations that were in place prior to August 2002.
Please see additional information under Spill Plans tab.
Air Emissions Regulations
The U.S. EPA has established many new regulations for MACT NESHAP categories.
In 2010 the Illinois EPA issued extensive revisions to the VOM regulations for industries in the Chicago area.
See our web page under Air Pollution Compliance for additional details.