If you have any questions in regards to the above, please do not hesitate to contact our offices so that we may explain the amendments to the provisions of the Code in more detail. Our address is:
Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507. Our fax (787) 759-3108.
We welcome your questions and comments.
Juan Carlos Gómez Escarce
María L. González Hernández
Pedro J. Reyes Bibiloni
EPA PUBLISHES 2015 MSGP FOR STORMWATER DISCHARGES
On June 4, 2015, the U.S. Environmental Protection Agency (EPA) issued a revised National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit for stormwater discharges from industrial activities (the “2015 MSGP”). The 2015 MSGP replaces the 2008 MSGP which expired on September 29, 2013. Industrial activities with 2008 MSGP coverage must submit a Notice of Intent (NOI) on or before September 2, 2015 in order to get coverage under the 2015 MSGP.
Although similar to the 2008 MSGP, the 2015 MSGP also requires:
Prior to submitting the NOI, the facility must revise and update as needed the SWPPP to assure compliance with the 2015 MSGP.
If you any questions regarding the 2015 MSGP applicability or new requirements, please contact us.
EPA ANNOUNCES MORE STRINGENT UST REQUIREMENTS
On June 22, 2015, EPA announced that it had issued revised and more stringent underground storage tank (UST) requirements. An official publication of the revised rule has not been published in the Federal Register yet. EPA’s revision pursues to establish uniform release protection standards among states and territories, and establishes specific implementation deadlines for the revised requirements. In addition, these requirements modify EPA’s original 1988 UST regulation by closing regulatory gaps, adding new technologies, and focusing on properly operating and maintaining existing UST systems.
The revised requirements include:
Although the Puerto Rico Environmental Quality Board UST regulation addresses some of these regulatory changes, we encourage owners and operators of UST facilities to assess their compliance status with both federal and Commonwealth UST regulatory provisions. Should you need assistance or further clarification on the applicability of these rules, please contact us at your convenience.
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©2016 Fiddler, González & Rodríguez, P.S.C. This Watch has been prepared by Fiddler, González & Rodríguez, P.S.C. for informational purposes only and does not constitute legal advice. This information does not create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this without seeking advice from professional advisers. Fiddler, González & Rodríguez, P.S.C. and its members assume no responsibility to inform you of additional changes in law or any other legal issues related to the matters discussed in this publication.
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