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The EPA claims that there are sufficient regulatory reasons for TSDFs to be in contact with local authorities concerning emergency procedures. The Agency points to 40 CFR 264.30 to 264.37 and 40 CFR 265.30 to 265.37, the requirements that TSDFs develop preparedness and prevention plans, and specifically 40 CFR 264.37 and 40 CFR 265.37, where […]
An “EMS” is a framework that helps you achieve your organization’s environmental goals through consistent control of operations. The assumption is that this increased control will improve your organization’s environmental performance. The EMS itself does not dictate a level of environmental performance that must be achieved; each company’s EMS is tailored to the company’s business […]
When you think of RCRA, you think of manifests, “cradle to grave” hazardous waste management, transportation, container management, and endless hours of recordkeeping. However, one important aspect of RCRA for EHS managers is training. There are specific training requirements for personnel at hazardous waste TSDFs and large quantity generators (LQGs). Small quantity generators (SQGs) are […]
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 […]
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 […]
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: […]
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 […]
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, […]
Civil Penalties With a few exceptions, most violations of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) hazardous materials regulations (HMRs) carry a civil penalty of up to $75,000 per day per violation for knowingly violating one of the HMRs. If the violation results in death, serious illness, or severe injury to any person or […]
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 […]