Tag: regulations
Post-Closure Requirements for Waste-In-Place TSDFs
Post-Closure Requirements for Waste-In-Place TSDFs When a TSDF cannot “clean close,” or completely decontaminate equipment, structures, and soils before closure, the Environmental Protection Agency (EPA) has established specific post-closure requirements under 40 CFR Part 264/265, Subpart G. These requirements were developed for land disposal units (LDUs), such as landfills, land treatment units, and surface impoundments […]
TSDF Closure: Know the Basics Before You Begin
TSDF Closure: Know the Basics Before You Begin The Resource Conservation and Recovery Act (RCRA) regulates the closure of TSDFs under 40 CFR Part 264/265, Subpart G Closure and Post-Closure, with Part 264 regulating permitted facilities and 265 covering interim status facilities. Regardless, both sets of regulations are divided into two sections that are intended […]
Section 112(r) Violators On EPA’s Hit List
CAA Section 112(r) Violators on EPA’s Hit List Protecting communities from hazardous chemical releases is a priority of the Environmental Protection Agency (EPA), and the requirements of the CAA Section 112(r) is at the center of many related violations. In announcements made in January and March, the EPA highlighted how several companies violated the GDC, […]
New Rules for Restricted-Use Pesticides in Indian Country
Restricted use pesticides can only be sold to or used by specially certified applicators or by someone under the direct supervision of a certified applicator. Although several states and Tribes have implemented their own certification plans, most state plans are not valid in Indian country, leaving a gap in protection of people and the environment. […]
Clearing Up Confusion About EPCRA Responsibility
Defining responsibility for EPCRA compliance on a site can often lead to questions that apply only to that particular situation or event. One such situation is that of chemicals brought on a site by contractors hired to perform work and where reporting responsibility lies—with the facility owner/operator or with the contractor. According to the Environmental […]
Clearing Up Confusion About EPCRA Exemptions
One of the most confusing exemptions under EPCRA is that for “routine agricultural use” (Section 311(e)(5)) under Sections 311 and 312, which cover Safety Data Sheet (SDS) reporting and Tier I/Tier II Inventory reporting, respectively. According to the Environmental Protection Agency (EPA), the exemption is “designed to eliminate the reporting of fertilizers, pesticides, and other […]
Contractor Compliance with the Lead-Based Paint Regulations
In February 2014 alone, the EPA announced enforcement actions against 37 contractors and training providers nationwide for failure to comply with requirements of the Lead-Based Paint RRP Rule. The RRP Rule requires that contractors that work on pre-1978 dwellings and child-occupied facilities be trained and certified to use lead-safe work practices. In February 2014 alone, […]
Asbestos Regulation: A Cross-Cutting Issue, Part 2
Hardly a month goes by without the EPA publishing enforcement actions against companies and individuals that have run afoul of the many regulations related to asbestos. Although most involve violations related to lack of training, lack of public notification, and other abatement-specific failures, many also cite violations of regulations protecting air and water. The Clean […]
