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She points out that mandated by a 2009 court decision, EPA’s National Pollutant Discharge Elimination System (NPDES) Pesticide General Permit (PGP) went into effect for point source discharges from pesticide application to U.S. waters. The PGP is believed to be the first permitting requirement of its type many small farmers will face in 2012. State-issued […]
Both small and large quantity handlers of universal waste must comply with an accumulation time limit of 1 year for storing universal wastes. A permit is not required. The accumulation period is measured from the time the waste is either generated (the date it becomes a waste) or received from another universal waste handler. Universal […]
The goal of EPA‘s universal waste rule (40 CFR 273) is to reduce the amount of hazardous waste items in the municipal solid waste wastestream and encourage recycling and proper disposal of certain common or widely generated hazardous wastes. Wastes regulated under the universal waste rules include: Batteries Pesticides Thermostats Fluorescent and high-intensity discharge lamps […]
BLR® Legal Editor, Tim Fagan, tells us that in 2012, EPA will continue to regulate air emissions from the largest sources of pollution, as the Cross-State Air Pollution Rule controlling NOx and SO2 from power plants will go into effect (pending resolution of the D.C. appeals court stay of the rule); the utility MACT controlling […]
By Elizabeth Dickinson, J.D. BLR Legal Editor Referred to by the U.S. Environmental Protection Agency (EPA) as the Hazardous Waste Report (EPA Form 8700-13 A/B), and by those in the environmental management field as the Biennial Report, the report must be submitted by March 1 of every even-numbered year with information of the facility’s hazardous […]
Educating the Educators Community college Maine: EPA Region 1 RCRA violation: During a compliance evaluation conducted by EPA regional staff, EPA’s inspectors identified multiple RCRA violations and state Hazardous Waste Management Rules, which govern the safe storage and handling of hazardous wastes. Penalty: $238,000 fine Third Time’s a Fine! Fuel company Baltimore, Maryland: EPA Region […]
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 […]
EPA’s Criminal Enforcement Division (CID) has changed priorities in recent years and has been seeking prosecution of individual defendants as high up the corporate hierarchy as there is evidence. For this the Agency offers one simple reason–corporate managers will think twice about deliberately breaking the law if they understand that they face jail time and […]
Like many other EHS plans, the SWPPP is a living document that should be reviewed and updated on a regular basis. Whenever you find the need to change a procedure that is described in your SWPPP or to modify a control measure described in the plan, you must update the SWPPP to reflect those changes. […]
This team is responsible for assisting the facility manager in developing the facility’s SWPPP as well as implementing and maintaining stormwater control measures. The team will be taking corrective action where necessary to address permit violations or to improve the performance of control measures, and modifying the SWPPP to reflect changes made to the control […]