Practical EHS Tips, News & Advice. Updated Daily.
No one looks forward to the day when the regulatory authority arrives at your facility for an inspection. Will he or she find issues of noncompliance? Will an enforcement action or penalty be forthcoming? But remember, the ultimate goal of the inspector is not to write up a notice of violation but to ensure your […]
The EPA has issued new guidance describing measures and other considerations federal agencies should adopt when fulfilling their roles in the Clean Water Act’s (CWA) Section 401 state certification process, particularly in relation to federal permitting of infrastructure projects. Specific topics addressed in the guidance are timelines for review and action on Section 401 certifications, […]
Not long ago, the standard practice for environmental reporting included filling out ready-made forms by pen followed by mailing or faxing the document to the respective federal or state agency. As the digital age progresses, and regulators are favoring online reporting (i.e., electronic reporting, or e-reporting), the “old-fashioned” method of using a pen and paper […]
Outreach. A CBP3 requires timely communication on progress, feedback, and forward planning. Key outreach points a municipality must consider include: Effective and well-documented transparency and participation; Opportunities for stakeholders, property owners, businesses, and institutions to become partners in planning and implementation; Access for stakeholders to all relevant documents, plans, meetings, and reports; Measurement and evaluation […]
Two Conditions Under Which You May Not Need a Permit The U.S. Environmental Protection Agency (EPA) or your state may waive applicable requirements in a permit for a stormwater discharge from construction activities that disturb fewer than 5 acres. The intent of the waivers is to waive only sites that are highly unlikely to have […]
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 […]
The EPA claims that there are sufficient regulatory reasons for TSDFs to be in contact with local authorities concerning emergency procedures. The Agency points to 40 CFR 264.30 to 264.37 and 40 CFR 265.30 to 265.37, the requirements that TSDFs develop preparedness and prevention plans, and specifically 40 CFR 264.37 and 40 CFR 265.37, where […]
Sufficiently Sensitive Testing Methods Rule—The Definitions One of the most subjective aspects of testing methods is the term “sufficiently sensitive.” To establish what is meant by the term, the Environmental Protection Agency (EPA) has defined it in two sections of the regulations: 40 CFR 122.21(e), which covers application completeness, and in 40 CFR 122.44(i)(I)(iv), which […]
Sufficiently Sensitive Testing Methods Rule—The Rationale Under the Clean Water Act’s (CWA) NPDES program, the EPA established and required “sufficiently sensitive” analytical methods be used by permit applicants and for “analysis of pollutants or pollutant parameters under an NPDES permit.” These “generally approved” methods under 40 CFR Part 136 and 40 CFR Chapter I, […]
Shipyard CWA Settlement an Educational Experience for Many Following an inspection in 2012, the U.S. Environmental Protection Agency (EPA) determined that up until the summer of 2011, a Gloucester, Massachusetts, shipyard had directly discharged process waters from its boat-washing operations into Smith Cove, which opens into Gloucester Harbor. The discharges contained mixed wastes, including paint […]