Staying in compliance and ensuring the proper management of wastewater discharges from industrial facilities can be challenging. The possible impediments that a facility can face are dependent on several factors such as the location of the facility, existing infrastructure, and the facility’s financial forecast. One of the most important first steps to maintaining wastewater compliance involves properly identifying the different wastewater streams at a facility. Wastewater discharges generally fall into one of two categories, Domestic and Industrial. Domestic wastewater discharges come from bathrooms, kitchens, and hand-washing stations and can be characterized as wastewater from personal usage. Industrial wastewater discharges come from industrial and commercial sources and may contain pollutants at levels that could impact water quality and/or interfere with Publicly Owned Treatment Works (POTW). Industrial discharges are usually generated from different types of industrial processes and are typically segregated from domestic discharges as described above. Continue reading “Management of Wastewater Discharges from Industrial Facilities”

Every year, federal regulations require that all state agencies responsible for regulating air pollution collect emissions data from certain facilities in order to compile an Emission Inventory (EI). In Georgia, emissions data for Calendar Year 2021 are due by June 30, 2022. All Title V facilities whose potential to emit (PTE) emissions is equal to or exceeds the following thresholds in Calendar Year 2021 are required to submit emissions data: Continue reading “Georgia Emission Inventories for Calendar Year 2021”

The U.S. Environmental Protection Agency (EPA) has created the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986. This act was created by Congress through Title III of the Superfund Amendments and Reauthorization Act (SARA) to help communities plan for and manage chemical emergencies. This act implemented several reporting requirements on most industrial facilities throughout the U.S. These reporting requirements are most commonly known as SARA Reporting. In this article, we will discuss the most common of the SARA Reports and Notifications and what your facility may need to do about each of them. These Reports include: Sections 302, 303, 304, 311, 312, and 313.

Continue reading “How to Stay in Compliance with SARA Title III Regulations”

What is the General Stormwater Permit?

Most facilities that conduct industrial activity exposed to stormwater are familiar with the NPDES Industrial Storm Water General Permit and are aware that it is issued by the Georgia Environmental Protection Division (EPD). The current General Stormwater Permit was issued in March 2017 and will continue through May 2022. This is the earliest effective date for reissuance of the permit. Facilities with a permit are authorized to discharge stormwater associated with industrial activity to the waters of the state of Georgia in accordance with the limitations, monitoring requirements and other conditions set forth in the permit.

What is the Storm Water Pollution Prevention Plan? Continue reading “Staying in Compliance with Your General Stormwater Permit”

With the release of the EPA’s 2021 Stormwater Multisector General Permit (MSGP), the GA EPD, like many other states, is planning to adopt significant changes from the 2021 EPA MSGP to their Industrial General Permit (IGP) in May of 2022. These changes will apply to most if not all industry sectors covered under the current 2017 IGP. The EPD has confirmed the following as the “most significant changes” that have been added to the draft permit: Continue reading “Georgia Set To Release New General Stormwater Permit in 2022”

With the release of the 2012 Industrial General Stormwater Permit (IGP) the Georgia Environmental Protection Division (EPD) introduced the Smoke and Dye Testing requirement for any facility with sinks and floor drains in industrial areas that were installed prior to 2006. This requirement was rolled over into the 2017 IGP when it was released in June 2017 that all applicable permittees should conduct the Smoke and Dye Testing prior to the end of the permit cycle which is schedule to be May 30, 2022.
Continue reading “What is a Smoke & Dye Test and Why is it Required?”

All industrial facilities have a vested interest in operating in the most environmentally responsible and safe manner possible. This is because operating in this manner carries with it the lowest risk of interruption to production. Whether that interruption is in the form of a hazardous material release, regulatory violation, injury, lawsuit, or negative publicity, this is a situation that no facility wants to find themselves in. Reducing the potential for environmental pollution and improving worker safety might seem secondary to production, but serious injuries and regulatory violations can have significant implications which can range from heavy fines to shutting down operations entirely. All industrial facilities should, at the very least, take the time to consider whether they are currently running the risk of being impacted by these types of issues.

Continue reading “The Necessity of Environmental and Safety Compliance Reviews”

One of the easiest ways for an EPA or state inspector to find violations is to compare your current operating equipment and emissions with the permitted equipment and emissions. If you do not keep your Air Quality Permit up to date, you run the risk of an inspector finding serious violations – which come with serious monetary fines. This applies to your facility whether your permit is a Title V, Synthetic Minor, or even True Minor operating permit.

If you operate under a Title V Air Quality Permit, you are required to renew your permit every 5 years, and likely have an annual inspection conducted by the EPA or state. With these measures in place, chances are your Air Quality Permit is staying up to date. However, anytime your facility installs new operating equipment or removes/decommissions old operating equipment you should reassess your air emissions. Continue reading “Is My Facility Fully Covered by My Air Quality Permit?”

On July 26, 2019, the Environmental Protection Agency (EPA) proposed revisions that would allow an operating facility to be reclassified from a major source of hazardous air pollutants under Section 112 of the Clean Air Act to an area source, thus removing the policy commonly known as “once in, always in”. This revision could take a lot of pressure for capital investments and permitting off of facilities that are eligible.

Continue reading “EPA Allows Reclassification from A Major Source of Hazardous Air Pollutants (HAP) to An Area Source”