Regulatory Updates and Reminders
As we kick off a new year, we want to provide a brief update of a few regulations and requirements and provide due dates for commonly required reports.
Tennessee:
The General Stormwater permit was renewed verbatim for a two year period until June 30, 2022. All requirements are still in effect.
The Hazardous Waste Generator Improvement Rules are expected to be effective in Summer 2021. This will revise the Tennessee regulations to include the EPA approved rules and retain state specific requirements. A redlined copy can be viewed here.
Mississippi:
The newGeneral Stormwater permit was issued on December 10, 2020. All permittees are required to reapply for coverage within six months of issuance (June 2021). The new permit also requires a review and update to the existing SWPPP.
Alabama:
As of December 21, 2020, stormwater NOIs are required to be submitted via eNOI system.
The general stormwater permit for hydroelectric facilities expires January 31, 2021.
Louisiana:
The multi-sector general stormwater permit expires May 8, 2021.Upon notification of reissuance or replacement of the permit, the permittee must comply with the requirements for obtaining coverage under the new permit to maintain authorization to discharge.
South Carolina:
The General Permit for Stormwater Discharges expires September 30, 2021. Facilities currently covered under the existing permit will automatically be covered under a new permit. A new NOI may be requested for the new permit.
North Carolina:
There are 21 general stormwater permits and seven expire in May 2021. These include Mining; Metal Fabrication; Apparel, Printing, Leather, Rubber & Miscellaneous; Food and Kindred; Transit & Transportation; Paints & Varnishes; Used Motor Vehicles; and Landfills.
EPA:
Civil Monetary Penalty Inflation Adjustment – EPA has adjusted the monetary penalties mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990 as amended through the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The adjustment affects penalties assessed on or after December 23, 2020.
After review of the air quality criteria and the national ambient air quality standards (NAAQS), EPA is retaining the current ozonestandards (effective December 31, 2020) and particulate standards (effective December 18, 2020), without revision.
The Iron and Steel Foundry MACT for area sources (Subpart ZZZZZ) and major sources (Subpart EEEEE) was revised to update requirements to the startup, shutdown, and malfunction (SSM) plans and to require electronic reporting of certain requiredperformance test reports, performance evaluation reports, and semiannual reports. The final rule became effective March 10, 2020; however, facilities will have until March 9, 2021 to comply with the SSM revisions and electronic reporting.
The PCWP MACT(Plywood and Composite Wood Products) was revised effective August 13, 2020 to eliminate the SSM exemption in the rule, require electronic reporting for notifications of compliance status, compliance test reports, and semiannual reports, require repeat emissions testing every 5 years, revise parameter monitoring requirements, and revise the non-HAP coating definition. The compliance date for sources that commencedconstruction or reconstruction on or before September 6, 2019, is August 13, 2021. Affected sources that commenced construction or reconstruction after September 6, 2019, are new sources and must be in compliance with the standard upon startup.
Important Due Dates
TSCA Report– January 29
Tier II Reports – March 1
Hazardous Waste Reports – March 1
Stormwater Reports – Virginia– January 10
Mississippi, Kentucky, and Alabama – January 28
Georgia and South Carolina – January 31
Tennessee – March 31
Conditional Major Compliance Certification Reports – Tennessee – March 31
Greenhouse Gas Reporting – March 31
TRI Form R reports – July 1
Please contact Shea Cofer for further information or questions.