Search Results for: SPCC

EPA Criminal Investigations: Ignorance Is No Excuse

If CID determines there was culpable conduct by a facility it will begin a criminal investigation. Here’s what they are looking for. Was Criminal Intent Present? Criminal intent is not necessarily a component of culpable conduct.  Therefore, in order to pursue prosecution EPA needs to determine if there was criminal intent. A “knowing” violation is […]

Most Misunderstood Regs: The Mercury ‘Beyond-the-Floor’ Standard

Under the CAA’s maximum achievable control technology (MACT) approach to reducing emissions of air toxics, the MACT floor must be at least as stringent as the average emission limitation achieved by the best performing 12 percent of existing sources in the category (for which EPA has emissions information) or the best performing 5 sources for […]

15 Tips for Developing and Implementing Your SWPPP

Permit coverage must be obtained by either the facility owner or the operator. These are frequently the same. However, if they are different, the responsibility to obtain coverage falls on the one who has day-to-day operational control at the facility. So if the owner does not have operational control, the operator bears the responsibility to […]