Posts Tagged ‘Environmental’

What Confuses Everybody About Secondary Containment

Wednesday, September 20th, 2017

What are the specific requirements for secondary containment of oil containers at SPCC-regulated facilities?

The entire containment system, including the walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs (40 CFR 112.7(c)).

Exceptions apply to qualified oil-filled operational equipment and flowlines and intrafacility gathering lines at oil production facilities.

Here’s more on simplifying secondary containment requirements. (more…)

Setting environmental objectives and targets for ISO 14001 Compliance

Wednesday, September 20th, 2017

Setting environmental objectives and targets for ISO 14001 Compliance 

What is an Objective? What is a Target?

Environmental objectives are goals that you would like to meet in the future.
Targets are the means for providing verifiable evidence that you have actually met the objective.  For example, your environmental objective may be to reduce the generation of hazardous wastes.  Your may then set your target at 20 percent reduction within 12 months.  In the parlance of ISO 14001, objectives are “documents” whereas targets are “records.”  Documents can be modified while records cannot.  For example, you can modify your objectives, but you cannot change having missed your targets. (more…)

EPA Seeks Elimination of $28 Million Monitoring Requirement

Friday, August 18th, 2017

A requirement to place wireless continuous monitors on containers at off-site waste and recovery operations (OSWROs) to detect leaks from pressure relief devices (PRDs) would be eliminated under an EPA proposal (August 7, 2017, FR).

The proposal responds to an industry petition for reconsideration of the requirement, which is included in the Agency’s 2015 residual Risk and Technology Review (RTR) of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for OSWROs. Jointly submitted by the American Chemistry Council and Eastman Chemical Company, the petition argued that the transitory nature of containers at OSWRO sites would make the installation of continuous monitoring devices technically impossible. Moreover, the petitioners said other federal regulations cover leak detection of OSWRO containers, and therefore, the RTR requirement is redundant. (more…)

Changes in Refrigerant Regulation – Are You Prepared

Friday, August 18th, 2017

The regulation of refrigeration and air-conditioning equipment is changing.  The universe of regulated refrigerants is expanding, commonly used refrigerants are being phased out, and revised refrigerant regulations are being phased in.  Is your facility prepared to cope with the changes in order to avoid penalties and enforcement actions?

The Changes

Refrigerant regulations originally addressed only ozone-depleting substances (ODSs) used as refrigerants.  However, revisions to the regulations, effective January 1, 2017, revised the definition of “refrigerant.”  The effect of this change was to extend the refrigerant regulations for ODS refrigerants to non-ozone-depleting substitute refrigerants. The change was primarily meant to address hydrofluorocarbons (HFCs), which have a very high global warming potential, but it does apply to any substitute refrigerant, other than the few that are specifically listed as exempt, and greatly expands the universe of regulated refrigerants. (more…)

11 Rules for Safe Handling of Hazardous Materials

Friday, August 18th, 2017

Do your employees know how to handle hazardous materials safely? Here are 11 basic rules all employees who handle hazardous materials should know and follow.

These 11 rules are presented in no particular order. They are all top priorities for chemical handlers. However, feel free to rearrange them in whatever order you think is best for your workplace, your workers, and your material hazards.

You’ll undoubtedly have other safety rules to add to the list. Better yet, present the list in a safety meeting and get employees involved in helping you add to the list. This will create a sense of ownership over your safe chemical handling rules.  (more…)

Updated ASTM AAI Standard Referenced by EPA

Wednesday, July 5th, 2017

In a direct final rule, the EPA is allowing the use of an updated nongovernmental consensus standard—American Society for Testing and Materials (ASTM) E2247-16, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property—to meet the All Appropriate Inquiries (AAI) requirement applicable to purchases of forestland and rural property. (more…)

Judge Rules Corps Must Revise the Dakota Pipeline EIS

Wednesday, July 5th, 2017

Operation of the Dakota Access Pipeline (DAPL) hit a potential roadblock when a federal district judge ruled that the Army Corps of Engineers (Corps) had approved the project without adequately considering the rights of the Sioux tribe living on the Standing Rock Reservation, which spans the North Dakota/South Dakota border near Lake Oahe. The pipeline runs under Lake Oahe but does not enter the Standing Rock Reservation. Nonetheless, in a ruling issued June 14, 2017, Judge James E. Boasberg of the U.S. District Court for the D.C. District said that the Environmental Impact Statement (EIS) the Corps issued for the project was incomplete.

“Although the Corps substantially complied with [the National Environmental Policy Act] in many areas, the Court agrees that it did not adequately consider the impacts of an oil spill on fishing rights, hunting rights, or environmental justice, or the degree to which the pipeline’s effects are likely to be highly controversial,” wrote Boasberg.” To remedy those violations, the Corps will have to reconsider those sections of its environmental analysis upon remand by the Court.” (more…)

HazMat Packages – When Is Secure Really Secure?

Wednesday, July 5th, 2017

The top hazardous materials (hazmat) transportation violation uncovered by Department of Transportation (DOT) roadside inspectors since 2013 is unsecured packages in vehicles, accounting for nearly 10% of hazmat violations. You may think your hazmat package is secure in the vehicle, but the important question is whether the DOT roadside inspector thinks so. We’ll take a look at a couple of scenarios where a roadside inspector may disagree or agree with the way you secured your hazmat.

Pallet Problems

Say you’re loading and securing a number of pallets for a hazmat shipment. You have four drums loaded on each pallet, and you have shrink-wrapped the drums to the pallet. In addition, you have placed heavy cardboard on top of each set of four drums banded to a pallet. (more…)

14 AGs File a Motion to Intervene in O&G Methane Case

Wednesday, July 5th, 2017

The case against EPA’s effort to freeze the Agency’s June 2016 New Source Performance Standards (NSPS) imposing air pollution controls the oil and natural gas (O&G) industry expanded when the attorneys general (AGs) of 14 states and the city of Chicago filed a motion to intervene on behalf of the plaintiffs, five environmental groups.

“State Intervenors have unique interests in the outcome of this case that may not be adequately represented by Petitioners, and State Intervenors are uniquely situated to explain the burdens and harms of staying the 2016 Rule on those State interests,” say the AGs in their motion. (more…)

What You Don’t Know About RCRA’s Waste Analysis Requirements

Wednesday, May 24th, 2017

“According to the EPA, a “cornerstone” of the RCRA hazardous waste program is the ability of regulated entities to properly identify which hazardous waste(s) they are generating. As a result, the EPA issued regulations that compel large quantity generators (LQGs) and small quantity generators (SQGs) of hazardous waste to develop and implement a waste analysis plan (WAP) to classify the hazardous waste and ensure that it is managed properly.”

In addition, owners and operators of RCRA-permitted transfer, storage, and disposal facilities (TSDFs) may also be required to develop and use WAPs if the generator does not provide the TSDF with a complete and up-to-date waste analysis. (more…)