Tag: Environmental Compliance

Will You Be WOTUSed?

Who Gets WOTUSed? Do the waterbodies near where you want to either develop or expand meet the new definition of waters of the United States (WOTUS), requiring you to get a permit? Here are some things to consider. You Need to Get a Permit if the Water … Is currently in use, was used at […]

Are You Paying for a Growing World Population?

In 1989, the Governing Council of the United Nations Development Program recommended observing July 11 as World Population Day. The reason given was to focus attention on the urgency and importance of population issues in the context of overall development plans and programs and the need to find solutions for these issues. The world population […]

Refrigerants—Cold Lessons Learned

A refrigerant formulator was recently fined $300,000 by the EPA and the Department of Justice for violations of SNAP regulations. First, let’s look at what the pertinent regulations say, then at what the company allegedly did, and finally what the fix will be. Note: Under SNAP, a “producer” is any person who manufactures, formulates, or […]

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 […]

$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 […]