New EPA CWA HS WCD Rule - Sneak Peak - Initial Insights
John K. Carroll III
Associate Managing Director at Witt O'Brien's, LLC, Part of the Ambipar Group
Today’s article departs from my usual explanation and insight into a particular rule component.
This coming Wednesday, April 10, I will be presenting on a panel at the Clean Waterways conference on the “Welcome and Keynote Session” on the Environmental Protection Agency's (EPA) Final Rulemaking on Clean Water Act (CWA) Hazardous Substance (HS) Facility Response Plans (FRP) rule.
This new rule brings in a host of new facilities that had previously been exempt from the Oil Pollution Act of 1990 (OPA90) rule under EPA’s jurisdiction. It expands OPA90 from just being for oil to covering 296 HSs (click here for the full list). Under the new rule, companies with reportable quantities of HSs on site after applying the new multiplier of 1,000x will be required to develop an FRP. Like every rule, there are exemptions, and some are clear while some are murky.
Below is a sneak peek of the approved EPA outreach presentation for public use, along with a copy of my slide deck for the upcoming Clean Waterways conference. I will devote several articles to this new rule in the upcoming months.
You can also learn more at our upcoming free compliance workshop on April 17 (see below). I’ll be providing a short presentation summarizing my Clean Waterways experience and key insights from the conference.
Helpful links:
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RSVP for our April 17th FREE USCG In-Person/Webinar
The workshop will cover compliance with the USCG's FSP, FRP, and DOM regulations. We will also briefly overview the EPA's new CWA HS rule.
Presenters include two former Coasties, now #wittobriens compliance consultants: Joe Graun and Eric Pugh. We will also have two USCG representatives from the USCG Sector Houston-Gavleston.
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Witt O’Brien’s has spent a lot of time reviewing the new rule and developing a program to assist our industry partners with compliance. If you need assistance, my contact information is noted below.
For a complete listing of archived articles and compliance insights, click here. Past articles cover training requirements, clarification of additional unclear elements within the above rules, and more.
We are here to help solve your compliance questions and challenges. If you need compliance assistance or have questions, please email John K. Carroll III ([email protected]), Associate Managing Director – Compliance Services, or call +1 954-625-9373.
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Witt O’Brien’s:
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Senior Manager, HSE – Emergency Response and Security Management at Plains All American
7 个月John, Thank you for the information and you provided a great presentation at Clean Waters. Looking forward to learning more about this!