Thursday, February 22, 2018

Most Common Mistakes In Tank Secondary Containment

Common Problems With Secondary Containment

Missing Secondary Containment

Fuel Tank Without Containment Or Proper Support

Fuel Tank Without Containment Or Proper Support



Fuel Loading Area Without Drainage Control

Fuel Loading Area Without Secondary Containment



Leaking Used Oil Storage tank Observed During Phase I Facility Inspection

Leaking Used Oil Storage AST Observed During

Facility Inspection



Inadequate Volume Containment

Phase I Environmental Inspection Finds Leaking Tanks And Pumps In Refueling Area

Environmental Inspection Finds Leaking Tanks

And Pumps In Refueling Area



Wrong Material

Bulk Fuel Storage With Hay Bale Secondary Containment Observed During SPCC Audit

Bulk Fuel Storage With Hay Bale

Secondary Containment



Missing or Inadequate Maintenance

Broken Secondary Containment Wall Identified During SWPPP inspection

Cracked Secondary Containment Wall Identified

During SPCC Inspection





Damaged Oil Storage Containment



This photo shows an example of a Leaking Waste Solvent Hazardous Waste Tank identified during a hazardous waste inspection

Leaking Waste Solvent Hazardous Waste Tank





 


Caltha LLP | Your Stormwater Permit, 
SWPPP and Spill Plan Partner

Wednesday, February 21, 2018

New Hazardous Waste Rule Effective In North Carolina

The Hazardous Waste Generator Improvement Rule amended the Federal RCRA rules and enacted several important changes in how hazardous waste is managed. The Federal Rule was finalized in November 26, 2016 and became effective in a few States (Iowa, Alaska) on May 30, 2017. For all other States where implementation of RCRA had been delegated to State agencies, the Hazardous Waste Generator Improvement Rule did not become effective until States formally amended State rules to include these new provisions. Because some elements of the Hazardous Waste Generator Improvement Rule were less stringent that the existing RCRA rules, States had the option to include or exclude those portions when adopting their own State laws. For those portions of the Hazardous Waste Generator Improvement Rule that were more stringent than the existing RCRA rules, States were required to accept Federal rules in order to maintain an approved RCRA program.

Click here for a summary of the Hazardous Waste Generator Improvement Rule.


This photo shows an example of a Leaking Waste Solvent Hazardous Waste Tank identified during a hazardous waste inspection
Leaking Waste Solvent Hazardous Waste Tank



In 2017, The North Carolina  Department of Environmental Quality put a hold on all State rulemaking in order to go through a formal rulemaking process to incorporate the Hazardous Waste Generator Improvement Rule. That process was concluded in 2017. The State of North Carolina has finalized the updated hazardous waste rules which become effective on March 1, 2018.

Click here for more North Carolina regulatory updates and Caltha project examples from North Carolina.


 
Caltha LLP | Your EH&S Compliance, Auditing 
and EMS/SMS Partner

Tuesday, February 20, 2018

Five Avoidable Hazardous Waste Compliance Violations

EPA, State and local agencies regularly inspect hazardous waste generators to determine compliance with the hazardous waste regulations and laws. Listed below are some of the most common hazardous waste rule violations observed by inspectors during compliance inspections along with some tips for how to avoid those violations.


1. Waste Evaluation

Violation: Disposing of unevaluated or inadequately evaluated products or materials used at your site as nonhazardous waste.

You can use generator knowledge to assume your waste is hazardous, but you may need to test your waste for certain characteristics or properties such as heavy metals, flashpoint, pH and VOCs, to show it is nonhazardous.

Industrial Waste Disposal Burn Pit Observed During RCRA Audit Inspection
Industrial Waste Disposal Burn Pit Observed During Inspection



Abandoned Chemical Products Stored In Lieu Of Disposal
Abandoned Chemical Products Stored In Lieu Of Disposal


2. Labeling

Violation: Missing or illegible waste description, generator information, accumulation start dates and other required information.

Hazardous waste containers must be labeled with the words “Hazardous Waste,” a description of the waste and the accumulation start date.

Mislabeled Mercury Waste Drum Identified During waste Audit
Mislabeled Mercury Waste Drum Identified During RCRA Audit

3. Open Container

Violation: Though funnel is covered, it is not designed with a closure device to withhold contents if overturned.

Container must be closed and have a closure device that is designed to withhold contents if container is overturned.


RCRA Audit Finds Improper Flammable Hazardous Waste Storage And Labeling
Waste Audit Finds Improper Flammable Waste Storage And Labeling


4. Universal Waste Lamp and Battery Management

Violation: Lamps (intact or broken) and regulated batteries are not stored in appropriate containers.


5. Record keeping

Violation: Evaluation records not kept at the licensed site or made easily available for inspection.

Violation: Missing or incomplete SQG or LQG training records for hazardous waste personnel.

Leaking Hazardous Waste Drums Discovered During Facility Phase 1 Environmental Inspection
Leaking Waste Drums Discovered During Facility Inspection

Rule On Reporting Mercury And Mercury Added Products

The Lautenberg Act TSCA amendments established reporting deadline(s) and information requirements periodic update and publication of the inventory of mercury supply, use, and trade in the United States. As required under TSCA, the reporting requirements would apply to any person who manufactures mercury or mercury-added products, or otherwise intentionally uses mercury in a manufacturing process.

Mislabeled Mercury Waste Drum Identified During waste Audit
Mislabeled Mercury Waste Drum
Identified During RCRA Audit


On October 26, 2017, EPA issued a proposed rule to implement TSCA section 8(b)(10)(D), which requires EPA to issue a final rule no later than 2 years after the enactment of the Lautenberg Act TSCA amendments that establishes reporting deadline(s) and information requirements. As required under TSCA, the reporting requirements would apply to any person who manufactures mercury or mercury-added products, or otherwise intentionally uses mercury in a manufacturing process.EPA published the first inventory in March 2017. Based on the information collected, TSCA further directs EPA to identify any manufacturing processes or products that intentionally add mercury and recommend actions to achieve further reductions in mercury use.

EPA proposed reporting requirements in the Federal Register of October 26, 2017  to assist in the preparation of an “inventory of mercury supply, use, and trade in the United States.” Subsequently the deadline for the comment period was extended  to January 11, 2018. The final rule is anticipated to be published by July 1, 2018.



 
Caltha LLP | Your EH&S Compliance, 
Auditing and EMS/SMS Partner

Monday, February 19, 2018

Compliance Audit For Atlanta Chemical Packaging Plant

Caltha LLP Project Summary

Project: Multi-media Environmental Compliance Audit
Client: Chemical Repackaging Plant
Location(s): Georgia

Key Elements: Compliance audit

Overview: Caltha preformed a multimedia compliance audits for this chemical mixing and repackaging operation located near Atlanta, Georgia. The scope of the audit included Federal, State, County and City requirements in addition to company policies and industry standards applicable to the operations environmental aspects. Regulatory programs addressed in the audit included:

OSHA
Hazard Communication

EPCRA
EPCRA 311-312,
EPCRA 313

Hazardous and Solid Waste Management
Federal RCRA rules
State waste rules
Universal waste rules

Clean Air Act
Federal air emission rules
Federal NESHAP standards
Federal RMP rule
Site air emission permit
State air emission rules

Clean Water Act
Authorized/Unauthorized Discharges
Stormwater Discharge NEC compliance
SPCC Rule Compliance
Spill Notification and Reporting
Federal Industrial pretreatment rules
Industrial discharger permit

TSCA
Current registration
Inventory Update Rule IUR Reporting
Chemical Data Rule CDR Reporting

Tanks
Aboveground tank rules
Underground tank rules

Aboveground Product Vessels
Aboveground Product Vessels


For more information on Caltha LLP services, go to the Caltha Contact Page


 
Caltha LLP | Your EHS Compliance, Auditing 
and EMS/SMS Partner

Risk Management Plan Requirements Delayed

In January 2017, EPA published amendments to the Risk Management Program (RMP) Rule 40 CFR Part 68. The amendments included requirements for:
  • Root cause analysis as part of an incident investigation;
  • Independent third-party compliance audits following a release event reportable under RMP or when an agency requires it based on site conditions;
  • Inclusion of a safer technology and alternatives analysis as part of the process hazard analysis for processes in North American Industry Classification System (NAICS) codes 322, 324, and 325 (manufacturing of Paper, Petroleum and Coal Products, and Chemicals);
  • Emergency response enhancements such as annual coordination with local emergency response agencies, annual testing of emergency notification procedures, and full field exercises at least every 10 years for responding facilities; and
  • Measures to increase availability of chemical hazard information to the public.

Aboveground Product Vessels
Aboveground Product Vessels



Following publication of the amendments, EPA received several petitions for reconsideration and request for stay of the amendments. On June 9, 2017, the EPA Administrator signed a final rule to delay the effective date of the RMP rule amendments until February 19, 2019.





Caltha LLP | Your Safety and Health Compliance
Management Partner

Thursday, February 15, 2018

New EPA Hazardous Waste Form 8700

US EPA has updated the standard form waste generators use to obtain a facility EPA ID number and provide notification and updates to regulated waste activities at their location.

Mislabeled Mercury Waste Drum Identified During waste Audit
Mislabeled Mercury Waste Drum Identified
During RCRA Audit

What Is Waste Notification Form Used For?

EPA Form 8700-12 is the document used to obtain an EPA ID number, which is a 12-character number used by states and EPA to track hazardous waste activities. This form is also used to update changes in site information (e.g., changes in site contact information, types of hazardous waste managed, cessation of regulated activity at a site, etc.). With the exception of very small quantity generators (VSQGs), a generator of hazardous waste must obtain an EPA ID number before it can manage (i.e., treat, store, dispose, transport, or offer for transportation) hazardous waste, and generators (other than VSQGs) must use hazardous waste transporters and treatment, storage, and disposal facilities with EPA ID numbers.


Abandoned Chemical Products Stored In Lieu Of Disposal
Abandoned Chemical Products Stored
In Lieu Of Disposal

What Is Required In New Waste Notification Form?

The Notification of RCRA Subtitle C Activities, EPA Form 8700-12 (i.e., the Site ID form) has been modified. Several additional data fields that support the various new notifications required by the November 28, 2016, hazardous waste generator improvements rule  and the import-export rule.



Caltha LLP | Your EH&S Compliance, 
Auditing and EMS/SMS Partner