Tag: Compliance

UST Amendments—What You Need to Know About O&M and Secondary Containment

According to the EPA, while information on sources and causes of releases show that releases from tanks are less common than they once were, releases from piping and spills and overfills associated with deliveries have emerged as more common problems. The Agency attributes the lack of proper operation and maintenance of UST systems as a […]

TRI—the Now and Future Things, con’t

As we mentioned in yesterday’s Advisor, the EPA is considering adding nonylphenol ethoxylates (NPEs) to the TRI list. At this point, that addition is not yet proposed. Here’s a look at the chemicals that the EPA has actually proposed for TRI listing. 1-Bromopropane (CAS 106-94-5) Last April, the EPA proposed that 1-bromopropane be added to […]

TRI—the Now and Future Things

A TRI Recap TRI reports are required to be submitted by facilities with 10 or more full-time employees, in specified Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS) codes, that manufacture, process, or otherwise use listed TRI chemicals in excess of the established thresholds.  The thresholds per calendar year are: 25,000 pounds (lb) per […]

10 Tips for LQGs for Inspecting Hazardous Waste Tanks

LQGs are those that generate either 1,000 kilograms (kg) or more of hazardous waste or more than 1 kg of acutely hazardous waste a month. Note: 1 kg = 2.2 pounds (lb) 100 kg = 220 lb 1,000 kg = 2,200 lb What’s a Tank? Although the answer may seem fairly obvious, there has been […]

$12 Million Worth of Lessons Learned from a Recent Enforcement

In this case, a foundry coke manufacturer in northern New York State will pay $2.75 million for alleged CAA, CWA, and EPCRA violations—and that is just the fine. ‘Citizen Scientists’ Complained A critical point in this case is that federal and state inspections came in response to local citizen complaints. The community even did their […]

Do Your Workers Know These Important Asbestos Safety Rules?

The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPA) have adopted regulations to protect workers from exposure to asbestos-containing materials, asbestos-containing building materials, and presumed asbestos-containing materials (PACMs). An Operations and Maintenance (O&M) program is a formulated plan of training, cleaning, work practices, and surveillance to maintain the ACM in […]

How Employers Can Promote Alternative Commuting Options

As an employer, you can promote shared transportation among your employees in several ways. Employer-sponsored vanpools. The employer buys or leases vans, but employee/drivers may be responsible for planning routes, recordkeeping, collecting fares, and maintaining the van. Drivers are often allowed to use the vans during nonworking hours. Vanpools/Buspools. Third-party firms operate vanpool fleets and […]

15 More BMPs for Storing Anhydrous Ammonia

BMPs for Storing Anhydrous Ammonia Good Housekeeping Maintain good housekeeping practices. Ensure good housekeeping procedures are followed in the compressor/recycle rooms and in the immediate vicinity of the evaporators. Accumulated supplies, equipment, and debris delay detection of equipment damage or ammonia leaks.  Maintain complete and accurate piping and instrumentation diagrams (P&IDs) of the ammonia refrigeration […]

Six Best Management Practices for Storing Anhydrous Ammonia

Anhydrous ammonia is ammonia gas—the anhydrous part means “without water.” It is colorless, but has a very pungent smell. It can be irritating at lower levels, but very damaging at higher levels. Exposure to anhydrous ammonia between 5 and 50 parts per million (ppm) can cause headaches, loss of the sense of smell, nausea, and […]

Why Is There So Much Confusion About TSCA 8(e) Reporting?

EAB Throws Out Huge TSCA Penalty Earlier this year, EPA’s Environmental Appeals Board (EAB) reversed a $2.5 million penalty against Elementis Chromium, Inc. for the company’s failure to report under TSCA Section 8(e) information contained in an occupational epidemiology study on hexavalent chromium. The study showed that occupational exposure to hexavalent chromium is associated with […]