Practical EHS Tips, News & Advice. Updated Daily.
There is much confusion concerning who an offeror is under the Pipeline and Hazardous Materials Safety Administrations (PHMSA) Hazardous Materials Regulations (HMRs). PHMSA has numerous interpretation letters that attempt to clarify this issue for individual scenarios. We found two letters we think are pertinent to help you determine whether you are an offeror under the […]
Used oil generators include all persons who produce used oil through commercial or industrial operations and vehicle services. The regulations exempt household “do-it-yourselfers,” farmers under certain conditions, vessels at sea or at port, and mixtures of used oil and diesel fuel under certain conditions. If used oil is mixed with hazardous waste, it must be managed […]
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 […]
A Look at Common Ski Area SPCC Violations Having an SPCC Plan that was not fully implemented. 40 CFR Section 112.3, states, “The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention, Control, and Countermeasure Plan … in accordance with 112.7 [General […]
Multiple Ski Areas Learn SPCC Compliance Lesson Over the past few years, the U.S. Environmental Protection Agency (EPA) has reached settlements with a number of ski areas in New England communities throughout Maine, New Hampshire, and Vermont. According to the EPA, the settlements “were reached under an expedited settlement program whereby EPA agreed to resolve […]
SPCC Violations Underscore Importance of Facility Response Plans In December 2014, the U.S. Environmental Protection Agency (EPA) announced a settlement with an Alaska-based oil field services company for multiple violations of the SPCC rule, including failure to submit an FRP. Under the SPCC regulations, there are two scenarios that require preparation and submission of […]
Tips for Assessing Applicability with the SPCC Rule Tip—Know the qualifying factors for coverage under the SPCC rule. The SPCC rule applies when the following are met at a facility*: The facility stores, transfers, uses, or consumes oil or oil products, such as diesel fuel, gasoline, lube oil, hydraulic oil, adjuvant oil, crop oil, […]
SPCC Inspection, Evaluation, and Testing—5 Specific Things Inspectors Are Looking For 1) Regular leak testing of tanks that are completely buried. Any completely buried tank that was installed on or after January 10, 1974, must be leak tested regularly “in accordance with industry standards or at a frequency sufficient to prevent leaks.” While there are […]
SPCC Inspection, Evaluation, and Testing—5 General Things Inspectors Are Looking For 1) A complete SPCC Plan that contains a description of “the scope and schedule of inspection, evaluation, and testing to be performed on bulk containers.” In its SPCC Guidance for Regional Inspectors, the EPA references the following sections of 40 CFR 112 that address […]
Highlights from OSWER Accomplishments 2013 Report The OSWER’s job is a big one encompassing diverse industries, practices and waste streams, as well as state and local regulatory agencies, emergency response agencies and organizations, and the public. Overall, however, the goal is to protect the environment and the public from contamination, whether from a spill, leak […]