Practical EHS Tips, News & Advice. Updated Daily.
The 2015 Definition of Solid Waste Final Rule (2015 Final Rule) does not significantly affect the recycling exemption from full RCRA Subtitle C regulation found at 40 CFR 266.70 for precious metals being reclaimed in accordance with the 40 CFR 266.70 provisions.
President Obama introduced EPA’s Clean Power Plan (CPP) for existing power plants by calling it, “The single most important step America has ever taken in the fight against global climate change.” Once published, the CPP triggered a flood of reactions from ardent supporters, opponents, and those who say they must study the plan before taking […]
If you were unable to participate in Damien Schiff, Esq’s webinar titled, The Clean Water Act Rule: What a New Definition of “Waters of the United States” Means for Your Operations, you’re not entirely out of luck. This recap provides a summary of Schiff’s, a seasoned environmental and land use attorney with Alston & Bird […]
Since 1988, the UST regulations required that tanks be made of or lined with materials that are compatible with the substance stored. Since that time, many new biofuel blends have come on the market. The 2015 UST amendments add new compatibility notification, demonstration of compatibility, and recordkeeping requirements concerning certain biofuels. Notification. UST owners and […]
No longer deferred The 1988 UST regulations deferred several types of USTs from regulations. Under the 2015 amendments, three types of tanks were removed from the referral list and must comply with the 2015 UST regulations. USTs for emergency power generators. The new UST amendments removes the deferral for USTs solely to store fuel for […]
An oil production company operating in Big Horn County, Wyoming was recently fined for the discharge of approximately 162 barrels of oil into a tributary of a major river. The discharge came from a leak in a pipeline at its pumping facility. The facility is on an onshore oil gathering, pumping, and storage station that […]
There is much confusion surrounding the applicability of SPCC requirements. A question that recently came across the desk of one environmental expert involved oil in flavorings. The person asked if flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine SPCC applicability if they are stored […]
Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]
The EPA recently issued an updated request for information (RFI) seeking public comment on updating its Risk Management Program regulations, and a notice of proposed rulemaking is being prepared. In the original RFI, the Agency noted that it is looking for specific feedback on whether the list of Risk Management Program (RMP)-regulated substances should be […]
Outreach. A CBP3 requires timely communication on progress, feedback, and forward planning. Key outreach points a municipality must consider include: Effective and well-documented transparency and participation; Opportunities for stakeholders, property owners, businesses, and institutions to become partners in planning and implementation; Access for stakeholders to all relevant documents, plans, meetings, and reports; Measurement and evaluation […]