Practical EHS Tips, News & Advice. Updated Daily.
Here’s the answer. Manifest procedures for shipments of containers that do not meet the EPA definition of “empty” (as defined in 40 CFR 261.7) are addressed in the federal regulations at 40 CFR 263.21(b) and 40 CFR 264/265.72. Container residues, which are residues that exceed the quantity limitations for an “empty container,” are considered a […]
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 […]
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 […]
In November 2011, EPA closed public comment on a rule concerning the disposal of coal combustion residuals from electricity-producing facilities, first proposed in 2010. EPA is considering two possible options for the management of coal ash. Under the first proposal, EPA would list these residuals as special wastes subject to regulation under Subtitle C of […]
Secondary containment requirements for new and replaced tanks and piping Operator training requirements Periodic operation and maintenance requirements for UST systems New release prevention and detection technologies The amendments will also remove certain deferrals; update codes of practice; and update state program approval requirements to incorporate these new changes.
EMS Document Control You have to keep all your EMS-related documents controlled and up to date. Here’s what’s required: All EMS documents must be carefully controlled and be easily accessible to persons who need them. They must be periodically reviewed, revised, and approved by management. Obsolete documents must be promptly removed. For example, there is […]
If a compliance officer has cited your facility, ask for suggestions to correct the problems found. Request a copy of the inspection form and the final report when prepared. Prepare your own inspection report. Acknowledge findings of the inspector and confirm promised operation changes in writing, including a list of all cited violations and corrective […]