Category: Special Topics in Environmental Management

LPG Odorants in Rail Tank Cars

But in what appears to be a regulatory lapse, the federal odorant standards overseen by the Department of Transportation’s Federal Railroad Administration (FRA) apply only to LPG rail shipments in cargo and portable tank containers; there is no comparable regulation for LPG transported in railroad tank cars.  In a safety advisory issued April 2012, the […]

DIY SPPC Plan Amendments

5-Year Review Owners and operators of regulated facilities must review SPCC plans at least every 5 years. As a result of such review, plans must be amended within 6 months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will […]

EPA and SPCC Plan Amendments

Discharges and Releases EPA may require the facility to amend its SPCC plan to adequately prevent and contain future oil discharges and releases. A regulated facility must notify the EPA regional administrator within 60 days if it has: Discharged more than 1,000 gallons (gal) of oil in a single event; or Experienced two spills of […]

Private Drinking Water Wells

Contaminants Groundwater that supplies wells can contain naturally occurring minerals (e.g., arsenic, boron, selenium, or radon).  Also, almost all private wells are in rural areas where agriculture occurs.  A wide variety of farming activities can affect groundwater that supplies wells.  These include the use of pesticides, overuse of fertilizers and animal manure, and discharges from […]

Equipment Leak Violations Inspectors are Looking For

Equipment Tagging is required for regulated equipment to distinguish it from non-regulated equipment. The Appendix sets the following penalties for failure to tag: $250 per valve, flange, connector, open-ended valve or line, sampling connection system, or instrumentation system; $1,000 per pump or agitator; and $5,000 per compressor, pressure relief device, surge control vessel, or bottoms […]

Equipment Leak Violations– Numerous and Costly

A related challenge is faced by government inspectors who must determine compliance with LDAR requirements under several Clean Air Act (CAA) programs and assess penalties in a rational fashion.  In September 2012, the EPA revised Appendix VI of its Stationary Source Civil Penalty Policy (General Policy), which advises inspectors on calculating settlement penalties for violations […]