Tag: EPA

What They’re Saying about WOTUS

What WOTUS Does Briefly, WOTUS redefines which waters are waters of the United States and, by doing so, decides whether your project will need a permit. According to the EPA, the rule does not alter existing exemptions from Clean Water Act (CWA) jurisdiction, including exemptions for normal farming, ranching, and silviculture activities. The major and most […]

Can Suppliers Help Your GHG Emission Reduction Efforts?

Suppliers, if you’re breathing a sigh of relief because so far the EPA has not targeted you to reduce your GHG emissions, don’t settle back just yet. Walmart, et al. may be doing the Agency’s job for it. Recap: Scope 3 emissions include indirect GHG emissions from sources not owned or directly controlled by the company […]

Cathodic Protection Maintenance and Testing Tips

Cathodic Protection Cathodic protection uses direct electrical current to mitigate corrosion. There are two types of systems for cathodic protection: Sacrificial anodes, which can be attached to a coated steel UST for corrosion protection. Sacrificial anodes are pieces of metal more electrically active than the steel UST. Because these anodes are more active, the corrosive current […]

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 […]

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 […]

Managing Refrigerants—It’s a SNAP!

Many refrigerants have been determined to be ozone-depleting substances (ODS) and have been targeted for phaseout under the Montreal Protocol. Chemicals used in the Refrigeration and Air-Conditioning industrial sector is one group for which the U.S. Environmental Protection Agency (EPA) has reviewed and identified substitutes under the Clean Air Act’s (CAA) Significant New Alternatives Policy […]

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 […]