Posts Tagged ‘EPA’

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…)

Getting the Most Out of Your Spill-Prevention Plan

Thursday, March 2nd, 2017

Creating a spill-prevention plan does more than just outline the methods for averting spills at a facility. It can help minimize other environmental, health and safety hazards and complement a variety of compliance strategies.

Like a multi-function knife, a well-prepared spill-prevention plan is a versatile tool that can be used for many purposes.

For example, EPA’s stormwater regulation and spill-prevention control and countermeasure regulation both have spill-prevention planning elements that can be served by a single well-designed spill-prevention plan.

On the safety side, managing chemicals and preventing spills can overlap with the facility’s hazard communication plan. And because spills are a risk factor for slips and falls, an effective spill-prevention plan can help reduce injuries and enhance the overall safety program. (more…)

Getting the Most Out of Your Spill-Prevention Plan

Tuesday, November 29th, 2016

Creating a spill-prevention plan does more than just outline the methods for averting spills at a facility. It can help minimize other environmental, health and safety hazards and complement a variety of compliance strategies.

Like a multi-function knife, a well-prepared spill-prevention plan is a versatile tool that can be used for many purposes.

For example, EPA’s stormwater regulation and spill-prevention control and countermeasure regulation both have spill-prevention planning elements that can be served by a single well-designed spill-prevention plan.  (more…)

Transporting Take-Back Drugs Made Easier

Tuesday, October 4th, 2016

Shipping certain pharmaceuticals is getting a bit easier now that the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has been issuing special permits for take-back drugs. We’ll review how PHMSA’s special permits work and take a look at DOT-SP 20255 for take-back drugs.

What are special permits?

Special permits allow a company or individual to package or ship a hazardous material in a manner that varies from the regulations, provided an equivalent level of safety is maintained.  The PHMSA may also grant variances from the hazardous materials regulations (HMR) if actions are taken in accordance with standards issued by competent international authorities, such as the International Maritime Dangerous Goods code or the International Civil Aviation Organization. (more…)

Feds Finalize Greenhouse Gas, Fuel Efficiency Standards for Heavy-Duty Trucks

Tuesday, October 4th, 2016

The EPA and the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) jointly finalized standards for medium- and heavy-duty vehicles that will improve fuel efficiency and cut carbon pollution, while bolstering energy security and spurring manufacturing innovation. The final phase two standards were called for by President Obama’s Climate Action Plan, and respond to the President’s directive in early 2014 to develop new standards that run into the next decade. (more…)

EPA Moves to Implement Chemical Reform Legislation

Tuesday, October 4th, 2016

A list of five mercury compounds that will be prohibited from export as of January 1, 2020 is the latest step taken by the Environmental Protection Agency (EPA) to implement the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which was signed into law in June.

The reform of the Toxic Substances Control Act (TSCA) gives the EPA a number of responsibilities that must be completed within a tight timeframe. On June 29, 2016, the agency outlined its plan for fulfilling that mandate. The plan included issuing the list of prohibited mercury compounds list (which it did on August 26, 2016), which will prevent the ability to convert these compounds to elemental mercury after export from the United States. (more…)

Facility Response Plans – Do You Need One?

Tuesday, September 6th, 2016

Facility Response Plans (FRPs) for oil facilities are a big part of compliance with federal Oil Pollution Prevention regulations. But determining whether or not you need one can be tricky.

If you are required to comply with the Spill Prevention, Control and Countermeasures (SPCC) rule defined under the federal Oil Pollution Prevention regulations, you may also have to address the regulation’s second set of requirements – the FRP rule. Or you may not. (more…)

Equipment Leak Violations – Numerous and Costly

Tuesday, September 6th, 2016

Controlling leaks of volatile organic compounds (VOCs) and hazardous air pollutants that may also be volatile (VHAPs) is a staggering job at petroleum refineries and chemical plants. In a guide on best practices for leak detection and repair (LDAR), the EPA noted that a typical refinery or chemical plant may have up to 60,000 connectors and 46,000 valves, each of which has the potential to leak into the atmosphere if not properly maintained. When these items are added to the hundreds of pumps, open-ended lines, sampling connectors, and pressure relief valves that may also leak, the challenge of designing and implementing a cost-effective LDAR program becomes clear. (more…)

EPA and SPCC Plan Amendments

Thursday, August 4th, 2016

SPCC plans require updating and amending to reflect changes in site conditions and operations. In addition, training, mock events, and paperwork updates should be included in reviews of your SPCC plan. Basically, there are two types of plan amendments, those that the facility operator performs within 6 months of a change that materially affects a facility’s potential for a discharge, and those that must be conducted as directed by the applicable EPA Regional Administrator (RA). Here’s what you need to know about amendments to the SPCC plan required by the RA.

Discharges and Releases

EPA may require the facility to amend its SPCC plan to adequately prevent and contain future oil discharges and releases. A regulated facility must notify the EPA regional administrator within 60 days if it has:

  • Discharged more than 1,000 gallons (gal) of oil in a single event; or
  • Experienced two spills of 42 gal or more within a 12-month period.

(more…)