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Facility Management Plans for Hazardous Substances – Ensure You’re Compliant

New EPA Rule Requires Worst-Case Discharge Response Plans for Facilities Handling Hazardous Substances

Rule At-a-Glance

  • In March 2024, the Unted States Environmental Protection Agency (EPA) finalized a new rule requiring Facility Response Plans (FRPs) for worst-case scenario discharge of hazardous substances under the Clean Water Act (CWA).
  • Facilities may be required to submit FRPs if the regulatory requirements apply to the facility or at the discretion of an EPA Regional Administrator on a case-by-case basis. Covered facilities are being given until June 2027 to comply.
  • The EPA expects more than 5,400 facilities nationwide will meet the criteria to prepare, submit and implement an FRP.

ECT can help organizations assess their position and/or portfolio and develop a compliance plan that meets the updated facility response plan criteria as an efficient support resource to your internal team.

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Eric Schwiderson

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Rule Overview and Resources
According to the EPA, as climate change increases, so does the frequency and severity of extreme weather events which require more planning and preparedness for spill and release incidents of hazardous materials. This new CWA rule addresses releases from facilities that meet the criteria to implement an FRP. The US EPA rule took effect in March 2024 and gives covered facilities until June 2027 (3 years) to prepare, submit, and implement the FRP.

The CWA hazardous substance FRP requirements apply to facilities that:

  • Have a maximum onsite quantity of any CWA hazardous substance that meets or exceeds 1,000 times the Reportable Quantity; and
  • Are within 0.5-mile of navigable water or a conveyance to navigable water; and
  • Meet one or more of the following substantial harm criteria:
    • Ability to cause injury to fish, wildlife and sensitive environments.
    • Ability to adversely impact a public water system.
    • Ability to cause injury to public receptors.
    • Has had a reportable discharge of a CWA hazardous substance above the Reportable Quantity within the last five years that reached navigable water.

Compliance Resources

ECT’s Compliance & Sustainability team provides full-service FMP audit, plan preparation and implementation. Get ahead of the new compliance requirements – contact Eric Schwiderson to get started before the deadline!

About ECT
ECT provides experts on subjects that matter to address the complex environmental challenges and opportunities that face our clients and communities today. With professionals in more than 27 states, ECT specializes in natural resources, ecosystem restoration, remediation, water resource initiatives, and sustainability programs requiring cutting-edge technologies, effective permitting strategies, and responsive project management.

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