Tag: EHS

4 Tips for Making Friends with EPA’s Citizen Cops

Let’s face it. If someone in your community has a complaint about your facility, you would much rather hear from them than having the EPA alerted first. It’s all about communication. We’ve discussed some of these ideas before, but some of them bear repeating. These tips can help you in developing an open relationship with […]

When Your Neighbors Complain to EPA

When the EPA publishes a press release about an enforcement case, the release will likely contain a statement about how the Agency came to uncover the violations. Sometimes a routine inspection, sometimes a surprise inspection, but often you will find that the inspection was prompted by a citizen complaint. In essence, your neighbors are tattling […]

RCRA Violations: Lessons Learned

Civil Penalties With a few exceptions, most violations of RCRA’s hazardous waste regulations carry a civil penalty of up to $37,500 per day per violation and the possible suspension or revocation of the violator’s permit. Criminal Penalties Knowing violations of hazardous waste rules can result in fines of up to $50,000 per day per violation […]

Tips to Patch Your NPDES Permit Shield

NPDES permits establish allowable discharge limits or effluent limitations that include both concentration and volume of flow. Section 402(k) of the federal Clean Water Act (CWA) provides for what is known as a “permit shield.” This means that if you are in compliance with your NPDES permit, then you are deemed to be in compliance […]

4 Extra Chemical Reporting Tips for Waste Facilities

The EPA claims that there are sufficient regulatory reasons for TSDFs to be in contact with local authorities concerning emergency procedures. The Agency points to 40 CFR 264.30 to 264.37 and 40 CFR 265.30 to 265.37, the requirements that TSDFs develop preparedness and prevention plans, and specifically 40 CFR 264.37 and 40 CFR 265.37, where […]

Focus on 4 to Guard against Refrigeration Leaks

Owners of equipment with charges of more than 50 pounds (lb) of refrigerant are required to repair leaks in the equipment when the leak rates exceed a certain percentage of the charge over a 12-month period. For commercial and industrial process refrigeration, the leak rate requiring repair is 35 percent or more of the charge […]

E-pinion: Should We Continue to Celebrate Earth Day?

Some of us remember what it was like before the first Earth Day, and all of us have been exposed to the lore. For example: Visible smog enveloping our major cities. Native-American chieftains crying in canoes afloat burning rivers. Brown sludge and odor emanating from industrial complexes—some residents of communities with such facilities referring to […]

Four Tips for Choosing a Recycler for Your Hazardous Waste Secondary Materials

As a generator of HSM, you ultimately decide whether the material is safely managed. The decision to send your HSMs to an off-site recycling business should be followed by a careful review of the qualifications of available recyclers. Improper management can increase liability of the originating company (remember RCRA’s “cradle-to-grave” mandate). Environmental managers investigating recycling […]

Four Factors for Recycling Hazardous Waste Secondary Materials Without Shame—I mean Sham

New Definition of ‘Sham Recycling’ Sham recycling refers to claims by a hazardous waste generator that the waste is being recycled when it is in fact being discarded. A new definition at 40 CFR 261.2(g) codifies EPA’s concept of sham recycling: “A hazardous secondary material found to be sham recycled is considered discarded and a […]

Recent Trends in Environmental Jobs

Environmental Engineers Environmental engineers design, plan, or perform engineering duties in the prevention, control, and remediation of environmental hazards. Work may include waste treatment, site remediation, or pollution control technology. Table 1 outlines median salaries for environmental engineers from 2010 to 2014, nationwide, and for the states with the highest and lowest median salary. Note: […]