Tag: EPA

Who Owns This UST?

Although it may seem obvious that if you ever owned or operated an underground storage tank (UST) that you are responsible for compliance or cleanup in case of a leak, the fact is that many USTs have long and complicated histories, and identifying the responsible party when, for example, the tank had multiple owners is […]

Biofuel Considerations: Safe Handling of Ethanol—For Your Tank

Ethanol is a renewable, domestically produced fuel that can be made from grains, such as corn or wheat, or from cellulose sources, such as prairie grass or agricultural, forestry, or municipal wastes. In the United States, ethanol is primarily made from corn. EPA’s Office of Underground Storage Tanks regulates tanks storing petroleum and biofuels. Under […]

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 […]

What’s in Store for Hazardous Waste Generators?

In the June 11, 2014, Federal Register (FR), the EPA published an Information Collection Request (updated in the October 14, 2014, FR) asking for public comment concerning the hazardous waste generator rules under the Resource Conservation and Recovery Act (RCRA). Specifically, the Agency asked that the comments address the following components of the generator rules: […]

Got Hazardous Waste? Can You Avoid Becoming an Episodic Generator?

Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). Note: It is critical to remember that most states have been delegated the authority to run […]

12 Changes in Store for EPA’s MSGP for Stormwater Associated with Industrial Activities

Twelve changes to the 2008 federal MSGP for stormwater discharges associated with industrial activity are included in EPA’s draft 2013 MSGP. Coverage under the 2008 MSGP, which expired September 29, 2013, is administratively extended until the 2013 permit is issued, provided facilities submit a Notice of Intent (NOI) to be covered by the new permit […]

SPCC: What Are Your Security Requirements

Standard SPCC plans must describe security procedures for their operation (excluding oil production facilities). The security requirements are meant to prevent oil discharges that result from vandalism or other unauthorized access to oil containers or equipment. Security procedures must include provisions to: Secure and control access to each facility’s handling, processing, or storage areas. Secure […]

SPCC: Tips for Tank Inspections

The following Table outlines the inspection requirements for tanks and associated piping at onshore nonproduction facilities that store petroleum and nonpetroleum oils—except animal fats and vegetable oils, which have their own set of inspection requirements. Note: The SPCC rule also contains integrity testing provisions for tanks, which are not included in this table.  In addition, […]

Go Beyond Compliance to Prevent AST Spills

The federal regulations you should consider when developing management practices for ASTs include: Clean Air Act (CAA) regulations for tank vapor control, air toxics, and pollution reduction The Emergency Planning and Community Right-to-Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance reporting requirements The Clean Water Act (CWA)-incorporated OPA that […]

Fertile Soil for Safety: OSHA, EPA, and Industry Address Fertilizer Safety

On April 17, 2013, fire broke out in a wooden warehouse at West Fertilizer Company in West, Texas. As the town’s volunteer fire department mobilized to respond, 30 tons of ammonium nitrate (AN) fertilizer in an adjacent wooden warehouse exploded. Fifteen people died, including 12 volunteer firefighters. An apartment building, many houses, and a nursing […]