Tag: NPDES

How E-Enterprise Figures in EPA’s 2017 Budget, Cont.

The U.S. Environmental Protection Agency (EPA) is modernizing its approach to environmental compliance and efficiency through a project called “E-Enterprise for the Environment.” Yesterday we reviewed EPA’s plans for E-Enterprise as outlined in the Agency’s 2017 budget pertaining to air quality, water quality, and inspections. Today we will look at EPA’s budgetary plans for compliance […]

No Changes for Proposed Reissuance of Pesticide General Permit

The EPA is proposing to reissue its hotly debated Pesticide General Permit (PGP) under authority of the CWA Section 402—the National Pollutant Discharge Elimination System (NPDES). The existing 5-year PGP expires midnight, October 31, 2016. According to the Agency, the proposed reissued PGP has the same conditions and requirements as the existing PGP. The proposal […]

Out with Paper, in with NPDES E-reporting

The New Year is customarily a symbol of a clean slate and new beginnings. This year, this notion rings especially true for all Clean Water Act National Pollution Discharge Elimination System (NPDES) permitholders. 2016 marks the year the U.S. Environmental Protection Agency (EPA) has eliminated paper-based reporting for all NPDES permittees. In proverbial terms, out […]

Exclusions to RCRA

Q. Does the addition of a spent material to wastewater treatment qualify for an exclusion to RCRA’s hazardous waste regulation?

E-Enterprise: Modernization or Just One More Program?

The U.S. Environmental Protection Agency (EPA) is in the process of trying to modernize its approach to environmental compliance and efficiency through a project called “E-Enterprise.” Today we will look at the basic premises of E-Enterprise and how it will affect the regulated community. Tomorrow we will review some of the comments the EPA has […]

Confusion about TSCA 8(e) Reporting

Recap: What Is Section 8(e)? TSCA Section 8(e) is a single short paragraph that has been the source of widespread confusion since TSCA became law in 1976.  Section 8(e) simply states that U.S. chemical manufacturers (including importers), processors, and distributors must notify the EPA within 30 days of obtaining information that reasonably supports the conclusion […]

Tips to Patch Your NPDES Permit Shield

NPDES permits establish allowable discharge limits or effluent limitations that include both concentration and volume of flow. Section 402(k) of the federal Clean Water Act (CWA) provides for what is known as a “permit shield.” This means that if you are in compliance with your NPDES permit, then you are deemed to be in compliance […]

Dings in Your NPDES Permit Shield

NPDES permits establish allowable discharge limits or effluent limitations that include both concentration and volume of flow. Section 402(k) of the federal Clean Water Act (CWA) provides for what is known as a “permit shield.” This means that if you are in compliance with your NPDES permit, you are deemed to be in compliance with […]

11 Tips for Qualifying Under the “No Exposure” Exclusion for Stormwater Associated with Industrial Activities

Under the conditional no-exposure exclusion (found at 40 CFR 122.26(g)), operators of industrial facilities subject to stormwater regulations have the opportunity to certify to a condition of “no exposure” if their industrial materials and operations are not exposed to stormwater. Note: This no-exposure exclusion does not apply to construction activities, which are addressed under the […]