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EPCRA, Wastewater, and Air…Oh my!

Posted By Amy Harvell on December 04, 2014

Feeling like you just want to close your eyes and click your heels during the reporting season?  You are not the only one. The more regulations implemented means the more paper work for your community or facility.


For some of you, this will be your first Annual Notification for your air permit and for others, completing your Annual Report for your Pretreatment Program is commonplace. But make them all due around the same time and you may feel like a house dropped on you. This blog serves as a friendly reminder of annual reporting requirements.

EPCRA Reporting

Even though your site might be part of a municipality, that doesn’t mean that you don’t have to report to other municipal agencies.  The Emergency Planning and Community Right-To-Know Act (EPCRA) was passed to mitigate concerns regarding environmental and safety hazards posed by the storage and handling of hazardous chemicals.  

EPCRA is separated into these sections:

  • Emergency Planning and Notification for extremely hazardous chemicals (due within 30 days of storing an extremely hazardous substance).

  • Emergency Release Reporting for accidental releases of a hazardous substance outside the property boundaries (report immediately).

  • Material Safety Data Sheets or a list of reportable chemicals stored or handled in a certain quantity (due within 90 days of receiving a new chemical).

  • Hazardous Chemical Notification and Inventory Reporting (i.e. Tier II Reporting) for hazardous substances stored in excess of 10,000 pounds and extremely hazardous substances stored in excess of 500 pounds (due annually on March 1).

  • Toxic Chemical Release Inventory Reporting on chemical releases to the air, water, and as a waste from a facility (due annually on July 1).

Refer to our blog “Hazardous Chemicals: Local Responders Need to Know!” for detailed information on each report and helpful hints on how to complete the calculations and reports.

Air Reporting

Those of you who have an air permit or received one last year are required to:

  1. submit the Annual Notification by March 1 for permit Registrations and Minor Source Operating Permits (MSOP) or

  2. submit the Annual Compliance Certification by July 1 for Federally Enforceable State Operating Permits (FESOP) and Title V Permits.  

The reporting form is provided in the issued air permit. The reports identify if the source was in or out of compliance with the permit for the previous year. Remember to maintain your permit compliance documentation for at least 5 years.

Wastewater Reporting

Pretreatment Program Annual Report:

An annual report is required to be submitted by the Wastewater Operator each year by April 1 to the IDEM Pretreatment Group. The Pretreatment Group developed a general form for non-delegated communities that can be used for the report and downloaded here. The information below is recommended for the report content:

  • Copies of the completed Industrial User Surveys

  • Summary of the industrial user survey results

  • Description of industrial facility changes, including operations and the volume or nature of the discharge

  • Synopsis of the previous year’s compliance status

  • Summary of the pretreatment inspection conducted, including any deficiencies or violations

  • Report the previous year’s enforcement actions

  • Evaluation of the pretreatment program

Annual Biosolids Report

Biosolids are solid materials generated from treating wastewater and are used in agriculture, landscaping, and to promote plant growth and soil regeneration. See EPA 503 (Biosolids) Reporting Requirements due February 19 for more information on the report.

Wait! – Don’t Forget…

Below is a list of other important compliance dates:

  • Compost Annual Report due January 1

  • Annual Manifest and Biennial Hazardous Waste Report due March 1

  • Annual Water Withdrawal Report (plants >100,00 gallons/day) due March 31

  • Wastewater and Water Treatment Plant Operator Certification renewal due June 30

  • Municipal Separate Storm Sewer (MS4) Annual Report due March 2016 (maybe depending on IDEM issuance of the regulations)

To find additional compliance due dates, refer to IDEM’s Compliance and Technical Assistance Program.

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