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Twelve changes to the 2008 federal MSGP for stormwater discharges associated with industrial activity are included in EPA’s draft 2013 MSGP. Coverage under the 2008 MSGP, which expired September 29, 2013, is administratively extended until the 2013 permit is issued, provided facilities submit a Notice of Intent (NOI) to be covered by the new permit […]
Under the conditional no-exposure exclusion (found at 40 CFR 122.26(g)), operators of industrial facilities subject to stormwater regulations have the opportunity to certify to a condition of “no exposure” if their industrial materials and operations are not exposed to stormwater. Note: This no-exposure exclusion does not apply to construction activities, which are addressed under the […]
Standard SPCC plans must describe security procedures for their operation (excluding oil production facilities). The security requirements are meant to prevent oil discharges that result from vandalism or other unauthorized access to oil containers or equipment. Security procedures must include provisions to: Secure and control access to each facility’s handling, processing, or storage areas. Secure […]
The following Table outlines the inspection requirements for tanks and associated piping at onshore nonproduction facilities that store petroleum and nonpetroleum oils—except animal fats and vegetable oils, which have their own set of inspection requirements. Note: The SPCC rule also contains integrity testing provisions for tanks, which are not included in this table. In addition, […]
10 Tips for Communicating an Environmental Crisis Accept responsibility for real and perceived environmental risks at your facility. The time to develop a public relations program is not after the incident happens. Facilities should already have a plan that addresses crisis communication. Companies that isolate themselves in times of crisis will be blamed by a […]
Civil Penalties With a few exceptions, most violations of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) hazardous materials regulations (HMRs) carry a civil penalty of up to $75,000 per day per violation for knowingly violating one of the HMRs. If the violation results in death, serious illness, or severe injury to any person or […]
There is much confusion concerning who an offeror is under the Pipeline and Hazardous Materials Safety Administrations (PHMSA) Hazardous Materials Regulations (HMRs). PHMSA has numerous interpretation letters that attempt to clarify this issue for individual scenarios. We found two letters we think are pertinent to help you determine whether you are an offeror under the […]
Used oil generators include all persons who produce used oil through commercial or industrial operations and vehicle services. The regulations exempt household “do-it-yourselfers,” farmers under certain conditions, vessels at sea or at port, and mixtures of used oil and diesel fuel under certain conditions. If used oil is mixed with hazardous waste, it must be managed […]
The federal regulations you should consider when developing management practices for ASTs include: Clean Air Act (CAA) regulations for tank vapor control, air toxics, and pollution reduction The Emergency Planning and Community Right-to-Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance reporting requirements The Clean Water Act (CWA)-incorporated OPA that […]
TRI is designed to provide citizens with information about chemicals being used, processed, manufactured, or released from facilities in their communities. The basic premise of TRI is that citizens have a right to know about toxic chemicals that are handled or released in their community. Meaning of “Release” under TRI Under the Emergency Planning and […]