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In terms of SPCC regulations, are there any broader or stricter views of the definition, for example, of navigable waterway? The definition of “navigable waterways” has not been expressly addressed in the new rule revisions. EPA has always held a very broad definition of what navigable waterways meant. I’ve seen very few facilities that could […]
Under the new rules (the amendments passed in 2010), what are the excess volume requirements for secondary containment? Under the new rules, there was a lot of debate about this in past versions of SPCC rules and past SPCC enforcements. Basically, the rule says you must have secondary containment equal to the amount of oil […]
Air permits are divided into construction permits and operating permits. Construction permits are usually required when building a new facility or installing and/or modifying a process or piece of equipment. The construction permit defines the air pollution source, establishes emissions limits and indentifies the equipment and/or controls to meet those limits. Applicants must apply for […]
Legal Editor Amanda Czepiel says that in the beginning of 2012, we will see EPA issue the 2012 Stormwater Construction General Permit (CGP). It will include a number of changes due to the implementation of the Construction and Development Rule, as well as changes to the appearance of the permit, new requirements for site inspections, […]
In this Environmental Daily Advisor transcript, Advisor editor Kelly Lagana talks with Amanda Czepiel about required training for EPA’s Spill Prevention, Control, and Countermeasure (SPCC). Amanda Czepiel is legal editor for BLR’s environmental compliance products.
BLR® Legal Editor, Tim Fagan, tells us that in 2012, EPA will continue to regulate air emissions from the largest sources of pollution, as the Cross-State Air Pollution Rule controlling NOx and SO2 from power plants will go into effect (pending resolution of the D.C. appeals court stay of the rule); the utility MACT controlling […]
Does the calculation of total oil storage volume include all oil contained in drums and totes and all oil contained in storage tanks and all contained in process tanks? In other words, are we adding it all up? Yes. I would say “yes,” again, with a caveat that if you have it in containers less […]
Will a PE certification be required if active secondary containment measures are utilized instead of permanent measures? In general, the answer is “no,” but there are a couple of caveats. For secondary containment for permanent storage containers, such as bulk storage containers like tanks, you do have to have permanent secondary containment for those kinds […]
Like many other EHS plans, the SWPPP is a living document that should be reviewed and updated on a regular basis. Whenever you find the need to change a procedure that is described in your SWPPP or to modify a control measure described in the plan, you must update the SWPPP to reflect those changes. […]
This team is responsible for assisting the facility manager in developing the facility’s SWPPP as well as implementing and maintaining stormwater control measures. The team will be taking corrective action where necessary to address permit violations or to improve the performance of control measures, and modifying the SWPPP to reflect changes made to the control […]