A few notable environmental events occur in October. On Oct. 10, we observed the fourth annual Imagine a Day Without Water. IADWW is a nationwide day of education and advocacy about the value of water led by the .

On Oct. 26, my colleague Sharon Stecker and I will present strategies to better align with management and leadership opportunities at the  during the National Association for Environmental Management  in Louisville, Ky.

During the past month, water has continued to make its way through our court system. For instance, the Southern District of Texas  of the Clean Water Rule, or Waters of the United States (WOTUS), in Texas, Louisiana and Mississippi.

Meanwhile, California challenged the proposed rollback of  from vehicles, and the EPA published a  to establish a fee schedule for certain activities under the Toxic Substances Control Act (TSCA).

What really caught my eye were these articles:

EPA’s OIG says RCRA state authorizations are lagging

The EPA’s Office of Inspector General is reporting a  in states’ implementation of the Resource Conversation and Recovery Act. Between 1980 and 2015, the OIG notes that the EPA has put 335 federal rules into effect to implement the RCRA hazardous waste provisions on the state level. However, the OIG perceives an inconsistency in states’ adopting these rules and applying to the EPA for federal authorization.

With an average 7.7 years for state rules to be authorized by the EPA, the gap may be a combination of EPA’s lack of tracking controls and a delay in state reporting.

EPA wants to end substitute refrigerant requirements

In an effort to deregulate the 2016 update to Section 608 of the Clean Air Act, the EPA recently proposed an amendment to the rule regarding the leak repair and maintenance requirements for  in stationary refrigeration and air conditioning equipment. The EPA is requesting comments on whether the 2016 rule’s extension to refrigerant substitutes should be withdrawn in full.

Are you prepared for industrial stormwater monitoring?

Time to revisit your  practices. As several states’ deadlines for discharge monitoring reports (DMRs) get closer, take time to review strategies before the rain starts to fall. Failing to plan can lead to costly violations for facilities operating under industrial storm water permits.

About the experts

Meghan Krishnayya, Indianapolis, is the Compliance & Permitting Service Line Director for Brown and Caldwell, with expertise in environmental regulatory program strategy development and implementation.

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