Tag: reporting

UST Amendments—What You Need to Know If Your UST Was Previously Deferred

No longer deferred The 1988 UST regulations deferred several types of USTs from regulations. Under the 2015 amendments, three types of tanks were removed from the referral list and must comply with the 2015 UST regulations. USTs for emergency power generators. The new UST amendments removes the deferral for USTs solely to store fuel for […]

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 […]

8 Issues Your City or Town May Look for in Partnering for Stormwater Control

What Is a CBP3? The EPA has been promoting CBP3 programs to help municipalities meet their stormwater management program needs. A traditional P3 is a performance-based contract between the public sector and the private sector to arrange financing, delivery, and typically long-term operations and maintenance of public infrastructure. The CBP3 includes many features of the […]

EPA Wants to Protect Honey Bees: Who’s Affected?

Along the way, you can take a look at some fun facts and trivia about bees, provided by Pennsylvania Apiculture Inc., the nonprofit that runs National Honey Bee Day. Label Requirements Registrants of certain pesticides that have been deemed harmful to bees are required to include instructions on the labels to applicators on minimizing exposure […]

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 […]

Can Suppliers Help Your GHG Emission Reduction Efforts?

Suppliers, if you’re breathing a sigh of relief because so far the EPA has not targeted you to reduce your GHG emissions, don’t settle back just yet. Walmart, et al. may be doing the Agency’s job for it. Recap: Scope 3 emissions include indirect GHG emissions from sources not owned or directly controlled by the company […]

Not Just the Big Guys—Where Do GHG Emissions Come From?

Today we will discuss how the EPA categorizes GHG emissions and why its approach doesn’t affect just large sources. Tomorrow we will look at how large companies are doing EPA’s job and finding some success in reducing overall GHG emissions by leaning on smaller companies such as their vendors. ‘Scope’ It Out! The GHG emissions […]

TRI Reporting Tips

BLR Legal Editor Tim Fagan offers tips on the process for submitting your Toxics Release Inventory (TRI) reports this year.