EPA Proposes Changes in New MSGP

June 22, 2020
By Brian Schefke

In March, the EPA released its final proposed version of the Multi-Sector General Permit (MSGP) that will replace the 2015 version currently in force. The MSGP authorizes stormwater discharges in areas where the EPA is the permitting authority, e.g., areas not covered by a state general permit. The comment period for the proposed permit ended June 1, and the EPA will issue the final permit later this year.

In response to a National Research Council study on improving the MSGP, the EPA has proposed a number of changes to the permit in the new version. The most substantial are summarized …

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Violations of the Clean Water Act in Washington in 2019

June 2, 2020
By Jenny Ma

Over the past several years, regulatory authorities and nonprofits have increased their watch over stormwater compliance. Freer Consulting routinely monitors records for the state of Washington from the Region 10 office of the Environmental Protection Agency for Notices of Intent (NOI) to Sue under the Clean Water Act. In 2019, the EPA received 21 NOIs for Washington businesses and individuals.

Of these 21 NOIs, the top five categories were:

  • Discharge without a permit: 11 – 52% of NOIs
  • Numeric effluent violations (e.g. facility is discharging with pH levels outside of permitted limits): 11 – 52% of NOIs
  • Failure to prepare
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King County Stormwater Violations Trend

May 8, 2020
By Jenny Ma

This year, a new permit for Industrial Stormwater General Permit (ISGP) for the state of Washington went into effect. Now is a great time to look at how permit holders in King County did over the 2015-2019 period regarding stormwater violations.

Data was collected from the Department of Ecology looking at all industrial stormwater violations reported in each year for King County during the 2015-2019 permit period.

Over the permit period, the top three violations have been benchmark exceedances, monitoring violations, and reporting violations.

  • Benchmark exceedances (e.g. a stormwater sample contained lead that was over the 64.6 µg/L limit) have
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Using ISO 14001 to Simplify GRESB Reporting

May 4, 2020
By Aaron Schlossman

Completing Global Real Estate Sustainability Benchmark (GRESB) reports is a complex, resource-intensive process for any business, whether it’s are establishing benchmarks for the first time or working towards well-specified goals. GRESB has successfully streamlined the reporting process, but data collection, management, and verification still pose obstacles during the annual reporting cycle.

GRESB complexity comes from the same source as its elegance. The thorough consolidation of external frameworks into one reporting tool, packaged into a seamless interface, takes much of the pain out of presenting data from your year. Often, we find that the remaining challenges stem from structuring operations to …

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COVID-19 and CLIA Expedited Certification

April 24, 2020
By Carrie Salters

With COVID-19 clinical laboratory testing continuing to ramp up throughout the United States and worldwide, Clinical Laboratory Improvement Amendments (CLIA) applications for registration are continuing to increase. In response to the pandemic, the federal government is taking unprecedented action to ensure laboratories in the United States wishing to test for COVID-19 are expedited through the CLIA certificate application process.

On March 26, 2020, the Department of Health & Human Services Centers for Medicare and Medicaid Services (CMS) Center for Clinical Standards and Quality/Survey & Certification Group issued a memorandum reference number QSO-20-21-CLIA regarding CLIA Laboratory Guidance During COVID-19 Public Health …

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