Practical EHS Tips, News & Advice. Updated Daily.
Q. I manage our filter cake waste as a hazardous secondary material (HSM) and notified the EPA and state environmental protection agency before managing the waste as a HSM. Are there any other reporting requirements after the initial notification?
Q: We currently have locations across the US that pay our employees for their lunch break. If an hourly employee leaves the premises, while on a “paid” lunch break, would the employer be liable if they were to get into an accident or incur an injury?
In 1971, the EPA and the Department of Transportation (DOT) issued a joint memorandum to clarify jurisdictional issues related to the regulation of facilities with the potential to discharge oil into the environment. Nearly 50 years later, there is still significant uncertainty about where one agency’s authority ends and the other’s begins.
Q. A company on my property has generated hazardous waste from past operations (subsurface cleanup) and I’m wondering if I must be identified as the legal owner and operator on the forms for the EPA ID Number and subsequent Biennial Reporting.
Q: On May 1, 2015, the U.S. Court of Appeals for the District of Columbia Circuit issued a decision on 40 CFR Part 63, Subpart ZZZZ vacating the 100-hour exemption for emergency generators participating in demand response from having to meet the more stringent emission limits, control device requirements, and/or work practice requirements applicable to […]
Q. Is installing a leachate collection system required by the EPA for a solid waste landfill? A. It is most likely that either the EPA or a state environmental agency will require a leachate collection system in a solid waste landfill.
Q. What are the requirements for PCBs handling and disposal? What are the appropriate EPA and state agency notification requirements when the PCBs at greater than 50 parts-per-million (ppm) are discovered in an aboveground storage tank (AST) storing Fuel #2 and located at the Petroleum Bulk Storage Facility? A. An aboveground storage tank (AST) storing […]
Q. We have a triple basin collection system on our city sewer line that allows solids and oils to separate out, leaving just the water to continue on to the city. We have the solids tested at a local lab, but I am having trouble finding a listing of thresholds or limits of metals/chemicals signifying […]
Q. If a facility uses 9,500 pounds (lb) of 1-bromopropane for reporting year 2016, should it be included in the Toxics Release Inventory (TRI) report? A. 1-bromopropane is on the list of chemicals required to be included in the 2016 Toxic Release Inventory (TRI) reports. However, the facility described in the question would not be […]
Q. Where can I find a list of thresholds for metal/chemicals to use to determine if the sludge-type waste from the triple basin collection system on our city sewer line is hazardous? A. From your question, we infer that you have already determined that your waste is not a listed hazardous waste and that you […]