As is currently written, the CWA Hazardous Substance FRP (HS FRP) requirements apply to the following facilities: Have a maximum onsite quantity of any CWA hazardous substance that meets or exceeds 1,000 times the Reportable Quantity (see 40 CFR 117.3); and Are within...
Environmental Compliance Services
Environmental Regulatory Implications of Recent Storage Tank Incidents
How Recent Storage Tank Failures Could Impact The Future of Environmental RegulationsRecent catastrophic events in the United States associated with storage tank failures at two facilities (Nippon Dynawave in Longview, WA; GKN Garden Grove, CA), have heightened...
New HFC Management Rule
Does your facility have cooling units or refrigeration equipment containing Hydrofluorocarbons (HFC)? Unless these units were relatively large (with a charge greater than 50 pounds), they were likely not regulated by the EPA. Until NOW………. The Environmental...
The Environmental Compliance Experts
EPA PROPOSES EXTENSION OF CWA HAZARDOUS SUBSTANCE FRP DEADLINE
The United States Environmental Protection Agency (USEPA) has made two key announcements regarding the Clean Water Act (CWA) Hazardous Substance Facility Reporting Plan (FRP) Rule. They are both considering amendments to elements of the rule while proposing a deadline...
Client Alert – USEPA to Reissue MSGP for Industrial Stormwater Discharges
WHAT IS THE MULTI-SECTOR GENERAL PERMIT (MSGP)? USEPA has released a proposed draft of its updated Multi-Sector General Permit (MSGP). The MSGP offers NPDES permit coverage to 29 different industry sectors for discharging industrial stormwater from their facilities....