Category: Environmental Permitting

Cyanotoxins Dominate Proposed Contaminant List

The EPA has proposed 30 chemical contaminants/groups for its 4th Unregulated Contaminant Monitoring Rule (UCMR 4). The Safe Drinking Water Act (SDWA) specifies that the UCMR must list no more than 30 contaminants or groups—called the contaminant candidate list (CCL)—and that the EPA must produce a revised list every 5 years. Also, as required by […]

Turpentine Storage

Q. Is turpentine covered under Spill Prevention, Control, and Countermeasure (SPCC) and what are the spill containment requirements for AST of turpentine?

The TSCA Reform Bills Have Passed Through the Senate

Senate passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (S. 697) last week is a historic moment in U.S. environmental law. But a great deal of work remains to be done before the objective of the bill—comprehensive reform of the outdated and widely ineffective Toxic Substances Control Act (TSCA)—is complete. […]

MATS Implementation to Continue

In a brief order, the U.S. Court of Appeals for the D.C. Circuit has allowed the EPA to continue implementing its Mercury and Air Toxics Standards (MATS) for fossil-fuel power plants while the Agency works on finalizing a proposed determination that consideration of cost does not alter EPA’s previous determination that it is appropriate to […]

WOTUS, WOTUS Everywhere, and Not a Drop in the Senate!

After failing the day before to collect the votes needed to approve a bill to force the EPA and Army Corps of Engineers (EPA/Corps) to rewrite their embattled June 29, 2015, Clean Water Rule (also called WOTUS for waters of the United States), Senate opponents of the rule gained the simple majority needed to pass […]

How to Avoid RMP

Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]

RMP under Scrutiny

The EPA recently issued an updated request for information (RFI) seeking public comment on updating its Risk Management Program regulations, and a notice of proposed rulemaking is being prepared.  In the original RFI, the Agency noted that it is looking for specific feedback on whether the list of Risk Management Program (RMP)-regulated substances should be […]