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On November 2, 2020, a final rule addressing the Clean Water Act National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule (eRule) was published by the EPA in the Federal Register.
In a lengthy interpretive statement, the EPA takes the position that a pollutant discharged from a point source, which reaches a water of the United States via a hydrologic connection provided by groundwater, is not subject to permitting under the Clean Water Act’s (CWA) National Pollutant Discharge Elimination System (NPDES).
Opposing opinions by three U.S. appeals courts (two issued by the same circuit on the same day) have led to a decision by the U.S. Supreme Court to address the core Clean Water Act (CWA) question—Is a point source discharging pollutants to navigable water via a groundwater pathway the functional equivalent of a direct discharge […]
Q. Does changing the frequency of inspections from weekly to monthly for oil storage facilities that receive infrequent fuel deliveries (one per year or less) constitute a technical change that requires a professional engineer (PE)?