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December 28, 2023
Environmental
(1) Facility requirements should be verified to confirm due(2) Varies by county.(3) EPA eliminated the de minimis exemption for Supplier Notification Requirements for chemicals of special concern (e.g., lead, mercury, dioxins, etc.)(4) VSQGs that for any one calendar month generate more than 220 pounds or accumulate on-site at any time more than 2,200 pounds of hazardous waste, must also submit an annual report.
Stormwater: Complete annual comprehensive inspection and routine facility inspections as needed. Conduct benchmark monitoring and visual monitoring quarterly at each outfall. Conduct training at least annually. Those required to submit Discharge Monitoring Report (DMR) forms must do so within 30 days of sampling.
Hazardous Waste: On even numbered years, SQG/LQG must submit an Annual Report using the Annual Report module in RCRAinfo. Activity in odd numbered years is reported using the Biennial Report module in RCRAinfo. SQG/LQG conduct weekly inspections. Verify hazardous waste generator status, review and update contingency plan annually.
Universal Waste: Conduct training annually. Confirm that storage times do not exceed one year.
Wastewater (NPDES/SDS): Discharge reports are required to be submitted at regular intervals, per permit requirements.
SPCC Plan: SPCC Plans must be updated every five years or whenever there is a change in oil storage or spill potential. Conduct and document routine inspections and annual training.
Air Permits/Emission Inventories: Emissions inventory are done for all Title V permits and then on occasion another permit level will require emission inventory reporting.
EPCRA TRI: Begin collecting data for RY2024 for reporting over 100 pounds of 189 specific PFAS chemicals (there is no de minimis exemption). See attached link for additional information: https://www.epa.gov/toxics-release-inventory-tri-program/basics-tri-reporting
KentuckyOhioMichiganWest Virginia
Project Environmental Engineer(317) 746-7896kendra.gutowski@terracon.com
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