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Regulatory Alert – March 2017

btn-downloadalertAegis Environmental, Inc. extends this brief update of pertinent news and regulatory compliance requirements:

 

Air Quality

EPA Updates to Air Quality Modeling

In December 2016, EPA published significant updates to the Appendix W Guideline on Air Quality Models.  These include updates to AERMOD, updating NO2 chemistry, replacing CALINE3 with AERMOD for mobile source applications, providing techniques for secondary chemical formation of fine particle and ozone pollution and publishing ozone modeling guidelines.  For more information, contact Jessica Gunter at jgunter@aegisenv.com.

 

DOEE Updates to Air Regulations

In Washington D.C., the Department of Energy and Environment has published proposed regulations to include: revisions to Title V fees, addition of a synthetic minor permitting program, establishment of general construction and operating permit fees, and general updates and administrative corrections.  They are accepting comments through Friday, March 24, 2017.  For more information, contact Kelly Bonds at kbonds@aegisenv.com.

 

Water Quality

Virginia 401 Certification Action

The Norfolk District of the Army Corps of Engineers recently reissued its Regional Nationwide Permits, which went into effect March 19 and will remain in effect through March 2022.  DEQ has changed a condition to the certification for Nationwide Permit 3 (Maintenance), which is that the Certification does not apply to maintenance done on intake structures.  This is significant to those concerned about upcoming 316(b) requirements and maintenance activities affecting the grandfathered status of surface water withdrawals.  For more information, contact David Sayre at dsayre@aegisenv.com.

 

EPA Updates Stormwater Requirements at Construction Sites

On February 26, 2017, EPA published an update to the requirements for managing stormwater runoff at construction sites.  Some important changes in these updates served to:

  • streamline the permit
  • clarify types of authorized discharges while explicitly prohibiting non-stormwater discharge of external building washdown waters containing hazardous substances such as paint or chalk containing PCBs
  • clarify effluent limitations and when erosion control is required
  • require posting of EPA contact information for obtaining a copy of the SWPPP
  • change the stabilization deadlines to be phased based on size of area disturbed

For more information, contact Jessica Gunter at jgunter@aegisenv.com.

 

Hazardous Waste

Tier II Reporting

Tier II reporting of hazardous materials or extremely hazardous substances onsite, was due to the EPA, the state, and the local planning offices and fire departments on March 1st.  Should you need assistance preparing your Tier II submittal contact Jessica Gunter, jgunter@aegisenv.com, immediately and Aegis can assist.

 

Changes to HW Generator Requirements

Updates to the HW Generator Requirements, including important changes to hazardous waste determinations, episodic generation, labeling, and enforcement were published to the Federal Register late November 2016.  One of the most controversial changes includes a change to the policy such that any items of noncompliance (even as small as labeling problems) would eliminate the generator “conditions for exemption” and effectively make the facility subject to full RCRA permit regulations, making continuous compliance of even greater importance than before.  These changes will go effective May 30, 2017.  For questions or assistance, please contact Sandy Morse, smorse@aegisenv.com.

 

Multi-Media and Other General Interest

New EPA Administrator

Scott Pruitt was confirmed as the newest EPA Administrator on February 17, 2017.  Administrator Pruitt most recently served as the Attorney General for Oklahoma, and served for eight years in the Oklahoma State Senate prior to that.  For more information, visit the EPA website https://www.epa.gov/aboutepa/epas-administrator.

 

Proposed Changes to the EPA

The White House Office of Management and Budget has proposed changes to the EPA which include cutting staff numbers by 19%, and eliminating several programs, such as climate change initiatives, and including very substantial cuts to the Chesapeake Bay clean-up program.  It is not certain which of the proposed changes will make it to the final budget.

 

Department of Commerce Requesting Input

The Department of Commerce is seeking information on “the impact of federal permitting requirements on the construction and expansion of domestic manufacturing facilities and on regulations that adversely impact domestic manufacturers.” Comments must be received by March 31, 2017.  To see the Federal Register request and how to respond click here: https://www.gpo.gov/fdsys/pkg/FR-2017-03-07/pdf/2017-04516.pdf.  For more information, please contact Ginger Ellis at gellis@aegisenv.com.