Spring has sprung more compliance and permitting activity. On March 14, the EPA issued a final rule incorporating revised American Society for Testing and Materials (ASTM) International standard practices for the Phase I Environmental Site Assessment (ESA) process. ASTM International is a recognized standards developing organization.

Phase I ESAs are a form of environmental due diligence for property transactions. The revisions aim to produce more detailed and consistent Phase I reports. This rule is effective May 13, 2022.

A week after the EPA’s move, on March 21, the Securities and Exchange Commission (SEC) proposed enhancements and standardization of climate-related disclosures in publicly traded company registration statements and annual reports. The public comment period is open until May 20, 2022.

This month, we highlight the following in our Compliance News:

Ask an Expert: Land application

Join our land application specialists Jessica Joyner and Jamie Olivarez as they share key details about the benefits of incorporating land application into your operations and expansion plans. Read “Ask an Expert”

Hazardous chemical compliance

An EPA enforcement alert reminds “chemical warehouse and distribution facilities that they must ensure that their chemicals are managed safely, securely, and in compliance with the federal laws enforced by EPA, Occupational Safety and Health Administration (OSHA), and Department of Homeland Security (DHS).”

2020 TRI national analysis released

The EPA’s TRI (Toxics Release Inventory) data analysis revealed a 10% decline in environmental releases of TRI chemicals by program-covered facilities between 2019 and 2020.

Clean Manufacturing Initiative launched

The Biden administration announced plans to support clean manufacturing initiatives, including the creation of the Buy Clean Task Force, to source low-carbon materials in federal purchasing and new trade policies to incentivize manufacturers of low-carbon aluminum and steel.

Ask an Expert: What are the benefits of land application in operations expansion?

In this month’s feature, BC’s Jessica Joyner and Jamie Olivarez share key details about the benefits of incorporating land application into your operations and expansion plans..

Question: We are looking to expand our operations and want to explore land application opportunities. What are the first steps?

Answer: Ask an Expert Jessica Joyner and Jamie OlivarezExpansion is a great time to explore the possibility of land application as you are already thinking about design and permitting.

Land application is the process of applying organic wastes to improve soil quality by serving as a source of nutrients. This process can reduce the amount of water being discharged into waterways or to nearby water treatment plants while also providing nutrient-rich irrigation.

Taking the extra time to explore land application options now will allow you to consider and execute the necessary design, treatment, studies, and more as required. As your business grows and wastewater quality and quantity changes, land application requirements may change as well. Here’s a quick rundown of things to consider:

How do we know if we are a good candidate for including land application in our wastewater plans?

Producers with good wastewater treatment up front are often good candidates. Some wastewater characteristics to consider are: organic components, odor, and biochemical oxygen demand.

What are the benefits to us as the producer?

Addressing industrial process water discharge through land application can be beneficial compared to discharge directly to the local publicly owned treatment works, which are often times expensive or not technically feasible in rural, agricultural areas. Additionally, utilizing wastewater in this manner can reduce your reliance on local freshwater sources as well as commercial fertilizers.

We do not have the need to utilize the wastewater ourselves. What are our other options when it comes to land application?

There are often opportunities to utilize your wastewater or a form of it such as compost after solidification with nearby partners such as farmers, agricultural companies, golf courses, and the like.

When it comes to compliance and permitting, what do we need to keep in mind?

Permitting at all levels (local, state, and federal) may be required. New permitting may be required whether you are working with your existing operations or looking to expand. In addition, various compliance efforts, such as land application management plans, annual reporting, and groundwater monitoring, will need to be maintained throughout.

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.

Jessica Joyner is a Project Manager for Brown and Caldwell in Idaho with 22 years of experience in environmental and safety programs.

Jamie Olivarez is a Principal Scientist for Brown and Caldwell in California with 15 years of experience in the management of municipal and industrial treatment solids and wastewaters.

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