Environmental rules and regulations include deadlines for submission of reports, plans, fees, training, inspections, and analytical testing. Some of these tasks need to be submitted to the U.S. EPA, some to the State Regulatory Agency, and some to both. Some tasks are only required to be kept on file. We hope that this list of deadlines will assist your facility in maintaining compliance.
Continue reading “Environmental Deadline List”

If your facility is a Large Quantity Generator (LQG), meaning it generated more than 2,200 lbs of hazardous waste and/or 2.2 lbs of acute hazardous waste per month during 2019, the upcoming deadline applies to you.

LQG are required to complete a Hazardous Waste Report (also called the Biennial Report) and a Hazardous Waste Reduction Plan for waste generated in 2019 by March 2, 2020.

Conversion Technology Inc. (CTI) is an environmental, health, and safety consulting firm with over 30 years experience covering the above reports and other aspects of permitting, and environmental, health, and safety regulatory compliance. If you need help preparing the waste reports, please contacts us at 770-263-6330 or cti@conversiontechnology.com.

On September 9, 2019, the US Environmental Protection Agency (EPA) released an Air Plan Approval that will grant approval of proposed changes to Georgia’s Nonattainment New Source Review (NNSR) permitting rules, proposed in Georgia’s July 2, 2018 SIP revision. The proposed changes have already been implemented by the Georgia Environmental Protection Division (GA EPD), and this Air Plan Approval is the EPA saying that it is okay for the GA EPD to continue implementation and begin enforcement. Continue reading “EPA Nonattainment New Source Review Updates – Georgia”

The prevention of stormwater contamination is a major concern that does not discriminate between, and is applicable to, all types of industry. Stormwater can be defined as storm water runoff (e.g. rain flow), snow melt runoff, and drainage. All industrial facilities have some form of stormwater discharge which has the potential to be impacted by pollutants from different types of industrial activities, such as pallets stored outside, forklift traffic between buildings, outdoor parts storage, etc. Due to this potential, all industrial facilities in the United States are required to comply with National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Regulations. Noncompliance with any of the Industrial Stormwater Regulations, such as the discharge of stormwater mixed with pollutants from processes or other industrial activity, is a violation of the Clean Water Act, which regulates the discharge of pollutants to waters of the United States.

Facilities are required to ensure that any stormwater discharging from their property is free from contaminants by conducting analytical sampling. Continue reading “Management and Prevention of Stormwater Benchmark Exceedances”

The Georgia Environmental Protection Division (EPD) continues to roll out features that require the use of the Georgia EPD Online System (GEOS), their online reporting portal. As more features and updates are added to this website, the EPD is taking a more active approach to reviewing the forms and reports that are being submitted. Lately, the biggest item under review seems to be Stormwater Annual Reports from 2017 and 2018. Special attention is being made to review the annual reports for completion of required tests (e.g. Smoke & Dye, stormwater benchmarks, etc.) and other actions. Continue reading “Georgia EPD to Increase Focus on Facility Online Submittals”

The Emission Inventory for Georgia facilities is due to the Georgia Environmental Protection Division (GAEPD) by June 30, 2019. This is for the mandatory reporting of facility emissions that occurred in calendar year 2018. This is part of the US Environmental Protection Agency’s (USEPA) National Emissions Inventory (NEI). The NEI is developed during three-year cycle reporting periods, where all Title V (or Part 70) permitted sources will be required to report at least every third year. The other two years only comprise larger sources with greater emission potentials. The 2017 emission inventory required all Title V sources to report. The 2018 inventory due this year, and the 2019 inventory that will be due in 2020, is for the larger Title V sources only. Continue reading “Air Emission Inventory Due End of June”

Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the Environmental Protection Agency (EPA) or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random and infrequent.

Continue reading “Staying in Compliance with Air Quality Regulations”

Industrial Stormwater Permitting requirements have been in place for over 20 years. Facilities that fall under one of eleven industry categories identified by the US Environmental Protection Agency (USEPA) and have material handling and storage, equipment maintenance and cleaning, and other activities exposed to stormwater are required to have a permit to discharge their stormwater runoff. Stormwater runoff is generated from rain and snowmelt events that flow over land or impervious surfaces, such as paved streets, parking lots, and building rooftops, and does not soak into the ground. The runoff picks up pollutants like trash, chemicals, oils, and dirt/sediment that can harm our rivers, streams, lakes, and coastal waters. Most often, industrial facilities are covered under General Permits issued by the State, but some facilities have individual permits. Continue reading “Industrial Stormwater Compliance – Increased Focus from Regulators”

After two rounds of public comments, the final version of Georgia’s General Multi-Sector Industrial Storm Water Permit (GAR050000) renewal has been issued. The permit will become effective on June 1, 2017. Covered industrial facilities will need to meet the following compliance deadlines:

All NOI’s and Annual Reports must now be submitted via Georgia EPD’s Online System (GEOS). Below are links to the final permit and to the GEOS website. If you have any questions or need assistance with submitting an NOI or updating or developing your SWPPP, please contact us.

New Georgia Multi-Sector Industrial Stormwater Permit – http://epd.georgia.gov/sites/epd.georgia.gov/files/related_files/site_page/FinalSigned2017IGP-20170306.pdf

GEOS Website – http://epd.georgia.gov/geos/

Georgia EPD’s NPDES Industrial Storm Water General Permits website – http://epd.georgia.gov/npdes-industrial-storm-water-general-permits

One environmental reporting requirement that is often overlooked, but enforced regularly by the Environmental Protection Agency (EPA), the Georgia Environmental Protection Division (GA EPD), and other state agencies is Tier II Reporting under the Superfund Amendments and Recovery Act (SARA).

If your facility stores any chemical or product on site that requires a Safety Data Sheet (SDS) (e.g. petroleum products, grains, paints, lead-acid batteries, liquid oxygen, etc.) in amounts over 10,000 pounds, your facility is required to notify the state, your local emergency planning committee, and the local fire department of these materials on an annual basis. Additionally, if you store any extremely hazardous substances (e.g. sulfuric acid) above its reportable quantity, usually 500 or 1,000 pounds, your facility is also required to report under the SARA Tier II requirements. The annual deadline to submit Tier II reports is March 1.

If you would like assistance determining whether or not your facility is required to report under the SARA Tier II requirements, or need assistance completing the reports, please give me a call at (770) 363-6330, x.113 or email me at jhaar@conversiontechnology.com.