REPORTING & COMPLIANCE DEADLINES
DUE JANUARY 30, 2008
TITLE V ANNUAL MONITORING REPORT AND COMPLIANCE CERTIFICATION
DUE FEBRUARY 1, 2008
POSTING OF OSHA 300 LOG SUMMARY
VAPOR DEGREASER ANNUAL REPORT
VAPOR DEGREASER EXCEEDANCE REPORT
DUE MARCH 1, 2008
HAZARDOUS WASTE GENERATOR REPORT
TIER II INVENTORY REPORT
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TITLE V ANNUAL MONITORING REPORT AND COMPLIANCE CERTIFICATION
DUE JANUARY 31, 2008
Companies that are permitted under the State of Connecticut’s Title V operating permit program are required to submit an Annual Monitoring Report and Compliance Certification to both the State of CT-DEP and the US-EPA prior to January 31st of each year. The Monitoring Report must include a 12-month rolling average of emissions for processes covered under the permit. The Compliance Certification is a checklist that must be completed verifying compliance with all conditions of the permit for the previous year. An individual within the organization that has signatory responsibility must sign the reports.
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POSTING OF OSHA 300 LOG – DUE FEBRUARY 1, 2008
Employers with more than 10 employees must maintain an OSHA 300 Log (Annual Injury and Illness Log), which documents work-related injuries and illnesses for the calendar year. At the end of the calendar year, a company must summarize the illnesses and injuries on Form 300A, which must be signed by a person in responsible authority at the company. The Form 300A must then be posted from
February 1 – April 30 in a place where it can be viewed by all employees. You will not receive any notice of this requirement from OSHA.
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VAPOR DEGREASER ANNUAL REPORT – DUE FEBRUARY 1, 2008
VAPOR DEGREASER EXCEEDANCE REPORT – DUE FEBRUARY 1, 2008
Companies that operate vapor degreasers that use specific solvents including Methylene Chloride, 1,1,1-Trichloroethane, Chloroform, Perchloroethylene, Trichloroethylene or Carbon Tetrachloride, are required under the National Emission Standards for Hazardous Air Pollutants (NESHAPS) to keep a running summary of the amount of the chlorinated solvent that has been used at the facility. On an annual basis, the company must submit a report to both the US-EPA and the CT-DEP on the amount of the chlorinated solvent that was used at the facility.
An Exceedance Report must also be submitted by February 1 of each year and every six months thereafter. The Exceedance Report provides information on operating parameter failure or the exceedance of an emission limit. The Exceedance Report must be filed even if there have not been any exceedances or failures of the operating parameters.
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HAZARDOUS WASTE GENERATOR REPORT – DUE MARCH 1, 2008
Every two years generators of hazardous wastes must file a completed Biennial Hazardous Waste Report with the CT-DEP. This report must be filed on or before March 1, 2008. This report must include information on the types of waste streams that were generated by the company in 2007, the generating operations, the amount of each waste stream that was generated, the transporter that transported the waste and the treatment, storage and disposal facility (TSDF) to which the waste was sent for disposal.
Small Quantity Generators and Conditionally Exempt Small Quantity Generators must complete only the ID form and indicate if their generator status is permanent or for this year only.
Each generator should receive a biennial report package, which includes the report form and the directions for completing the form. If your company does not receive the report package, a copy can be obtained by calling the CT-DEP at 860-424-3666.
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TIER II INVENTORY REPORT – DUE MARCH 1, 2008
Under SARA Title III, any company that notified the Local Emergency Planning Committee (LEPC) of the usage of an extremely hazardous substance above the threshold planning quantity or that they stored more than 10,000 lbs. of an OSHA-regulated substance on site at any given time, must file a Tier II Inventory Report on or before March 1, 2008. This form must be submitted to the LEPC, the local fire department and the State Emergency Response Commission at the CT-DEP. The package from the CT-DEP will include the mailing address for the LEPC.
If the company has filed a Tier II Inventory Report in the past, it should receive a copy of the form from the CT-DEP.