About the Expert
Liz Wilson is Compliance and Permitting National Practice Leader for Brown and Caldwell. She is based in New Hampshire and has 19 years of environmental consulting and industry experience.
National Regulatory Dates
The new year ushered in seven more PFAS on the Toxic Release Inventory (TRI) list for Reporting Year 2024, bringing the total number of reportable PFAS to 196, the EPA said in a recent announcement.
The enhanced reporting will help the EPA and the public to better understand and address the impacts of PFAS on human health and the environment. As you look ahead to TRI Reporting Year 2024, remember:
- Facilities in designated industry sectors and federal facilities that manufacture, process, or otherwise use these PFAS at or above 100 pounds must report their releases and waste management to the EPA.
- The de minimis exemption, Form A Certification, and range reporting are no longer available for TRI reporting of PFAS.
- The de minimis exemption is unavailable for supplier notification purposes (for PFAS and all other chemicals of special concern).
BC’s PFAS and Compliance and Permitting Teams are actively working on these evolving reporting requirements and regulations. Reach out for guidance here.
In other environmental updates, we highlight the following in our Compliance News:
Stricter oil and gas methane regulations
The EPA’s final rule aims to reduce methane and other harmful air pollution from oil and gas operations by setting new standards for new, modified, and existing sources. It’s likely just the start.
Fugitive forecast
Increased focus on methane emissions reduction, coupled with more tools available to detect it, has prompted new research efforts around detection and quantification. This increasing body of knowledge has revealed linkages between methane emissions and priorities such as:
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- Health and safety
- Biogas utilization
- Climate action plans
- Public data and awareness
- Energy and carbon reduction goals
Equity and social justice
As our awareness grows regarding the various sources and importance of methane and inadvertent releases of it, so too do pressures to quantify and abate this “fugitive” methane from existing facilities.
BC is working to help facilities — primarily in the wastewater sector — better understand fugitive methane sources and amounts in order to develop mitigation strategies. BC’s team is committed to not only understanding the extent of a fugitive methane issue, but also determining how to best deploy limited resources to mitigate it. Reach out here for assistance.
EPCRA and General Duty Clause enforcement
Recent settlements — requiring payment of penalties and compliance with Toxic Release Inventory reporting and Clean Air Act review requirements — further protect communities, employees, first responders, and the environment from accidental hazardous exposure through raised awareness.
Compliance tip: RCRA containers
Understanding when a container is considered “empty” under the Resource Conservation and Recovery Act (RCRA) regulations can help you comply with hazardous waste regulations and avoid violations.
BC Insider: Thermal drying of biosolids to make the most out of less waste
In this evolving and uncertain market, facilities are looking at upstream solids improvements and downstream technologies to process the biosolids into other valuable products. By making the most out of less waste, thermal drying does both. Learn more about in the latest edition of BC Insider.