Environmental News

How to Avoid 6 Expensive Spill Plan Mistakes

 Return

If a release of any kind could potentially pollute navigable waterways, then your facility and company need a Spill Prevention, Control and Countermeasures (SPCC) plan.  However, many facilities are not aware of what navigable waters include.  If there is potential for a release into wetlands, drainage ditches, intermittent streams and even storm-sewer connections, then you still need an SPCC plan.

Experts keep finding the same mistakes over and over again.  Most of the mistakes are due to lack of maintenance or monitoring containments.  Below are common mistakes that could lead to costly fines.

Here are the top 6 Expensive Spill Plan Mistakes to Avoid

  1. Part of an SPCC plan includes drawings of totes, tanks and drums.  Make sure to also include drawings of reservoirs, elevator rooms, oil-filled equipment and company-owned transformers.
  2. Inspect containment barriers and lining for cracks or tears.  Comprised containment areas make facilities noncompliant.
  3. Invest in pest control.  Make sure to monitor containment walls for chew marks or presence of pests.  Having holes in containment walls leave facilities vulnerable to spills.
  4. High quantities of edible oils need to be addressed and contained on site.  Tip: If food oils aren’t soluble, they need to be part of a spill plan.
  5. If you have above ground or underground tanks, you may not need an SPCC plan. However, it is best to always have documentation as to why you are not required to have a spill plan in the event you are visited by regulators.
  6. Always document employee training.  Some facilities train employees but do not have any documentation.  If a release happens, those facilities are asking for more fines without proof of training.

Learn More About What Inspectors Look for In SPCC Plans.

Have questions? SRP Environmental Consultants have extensive experience in producing and reviewing Spill Prevention Control and Countermeasures plans for companies of all sizes in different industries.   We have eight convenient locations in Charlotte, Dallas, Denver, Honolulu, Long Beach, Midland, Shreveport and Pittsburgh. Contact SRP today at (866) 222-4972.

Tier II Reports Are Due March 1st

 Return

Tier II Reports Are Due March 1st

It is that time of year again: Tier II Reporting Time.   Between OSHA and EPA regulations, companies have quite a few deadlines throughout the year.  SRP Safety and Environmental Consultants are here to help you keep everything organized and up-to-date.

Tier II, also known as Community Right to Know, Reports are due March 1st.

A Tier II is required by the Emergency Planning and Community Right to Know Act (EPCRA), sections 311 and 312.    Generally, if you have over 10,000 pounds of hazardous materials at any facility, you must submit a Tier II.  However, there are hazardous materials that have much lower thresholds.   Hazardous materials can be identified by obtaining information from a products’ Safety Data Sheet.

A Tier II Report includes information on all hazardous materials including amount stored on site, hazardous ratings, type of storage containers, etc.   This information is then passed on to state and local emergency departments including first responders and the fire department, as well as emergency planning committees.   This information is critical for first responders to know in the event a catastrophic event happened at your facility.  Knowing what is inside a facility and how to handle the hazardous materials can save many lives within the community.

Keep in mind that Tier II Reports are mandated at the state and local levels, therefore it is best to check State Reporting Requirement and Procedures.

Need Help Documenting Hazardous Materials?  Contact an SRP Environmental Consultant Today!  Call Us at 866.222.4972.

Established in 1996, SRP Environmental has become a premier turnkey consulting firm offering environmental, health and safety solutions to organizations in construction, manufacturing, agricultural, oil and gas, healthcare and property management industries.  SRP has seven convenient locations in Charlotte, Dallas, Denver, Honolulu, Midland, Shreveport and Pittsburgh to better serve their clients.

New Environmental Reg Affects Oil & Gas Sites

 Return

New Environmental Reg Affects Oil & Gas Sites:
What You Need to Know About Subpart OOOO(a)

A regulation went into effect September 18, 2015 and affects oil and gas facilities that were modified, reconstructed or constructed after that date.   Any equipment including pneumatic controllers, centrifugal compressors, reciprocating compressors, tanks, fittings and valves will require leak testing for methane and other VOC emissions.

What is Subpart OOOO (a)?

The EPA has determined the best system of emissions reduction for reducing greenhouse gas (GHG) emissions, including methane, and volatile organic compounds (VOC) from fugitive emission sources within oil and natural gas production, processing, transmission, and storage facilities.

What Are the Requirements?

Oil and gas facilities will need to

  • Develop a Monitoring Plan that specifies and includes
    • site diagrams,
    • list of devices and components to be tested,
    • components must be tagged to match diagram,
    • outlines the requirements and procedures.
  • Conduct semi-annual monitoring and equipment leak testing at well sites.
  • Conduct quarterly monitoring  at compressor stations.
  • Submit an annual monitoring report to applicable state agencies.

The regulation states that the leak testing and monitoring threshold level is 500 parts per million (ppm) .  There are two accepted methods of performing a leak test and monitoring components.  Monitoring can be performed using optical gas imaging technology to determine if any visible emissions are present.  Monitoring can also be conducted using EPA Method 21 and an FID-like device.  Note that repairs must be made within 30 days of finding fugitive emissions and a resurvey of the repaired component must be made within 30 days of the repair using OGI or Method 21 at the stated threshold level.

Oil and gas facilities must conduct initial fugitive emissions monitoring surveys for well sites and compressor stations by June 3, 2017 or 60 days from start-up (whichever is later).

Have more questions?  Contact an SRP Environmental Consultant for more information regarding Subpart OOOO (a).  SRP provides leak testing services, monitoring plan development, and environmental site audits for oil and gas sites across the US to ensure environmental and safety compliance.  Call SRP today at (866) 222-4927.

Clean Air Permit Changes Expected in November

 Return

Clean Air Permit Changes Expected In November

Two big changes are in motion for air quality compliance.   These changes affect facilities in all industries, and both small and large firms.  Higher fines are effective immediately, and making changes to your Startup, Shutdown and Maintenance policies to omit emission exemptions will be effective November 16, 2016.

Higher Fines from EPA. Violations of the Clean Air Act will now cost the company $44,539 per day of violation period.  That’s up from $37,500.  Expect increases each year, as the EPA is now able to implement higher fines in relation to the cost-of-living.  This is part of the new Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

Read More: EPA Increases Violation Fines: Makes Non-Compliance Riskier

Additionally, facilities can expect higher fines for exceeding smoke, soot and smog limits at the state enforcement level.

Remove Startup, Shutdown and Maintenance Clause in Air Plans.  This means that facilities will no long be able to claim a permit shield, or exemption, in the event an equipment breakdown, planned startup, or planned shutdown pushes the facility over the permit limits.

Smoke Stack Air PollutionThere are two crucial impacts on industry:

  1. Many facilities will incur hefty expenses by upgrading their equipment to reduce
    maintenance.
  2. Facilities are face a spike in emissions could go from being labeled a minor source to a major source.  Facilities will have to decide whether to include higher emissions in their permit or hope for the best.

States are Enforcing Changes to SSM.  States including Florida, Michigan, North Carolina, Kentucky, Indiana, Colorado, and Louisiana have updated their state Startup Shutdown and Maintenance policies.  If you are in Louisiana, don’t expect any leeway for sulfur dioxide or nitric acid emissions.  Colorado, however, will still provide exemptions for some facilities as long as they immediately report issues and minimize emissions from an SSM event.

While some states are listening to the EPA, nineteen states along with different industry groups are not.  They believe that any issues with equipment that lead to emissions should not be subject to fines.   These states and groups are challenging the EPA in court, but a decision won’t be made till after the November 16th compliance deadline set by the EPA.

Read More About What EPA Inspectors are Looking For Now

Do you have questions about environmental compliance?  Contact an SRP Environmental Consultant today.  We have seven convenient locations in Charlotte, Dallas, Denver, Honolulu, Midland, Shreveport and Pittsburgh.  Call us toll-free at 866.222.4972 or visit us online.

Source: Environmental Compliance Alert, August 15, 2016

2 Lead-Based Paint Rules Every Renovator and Property Manager Must Know

 Return

Once again, three companies made the news for violating lead-paint regulations set by the Environmental Protection Agency (EPA).   The companies were in violation of the Real Estate Notification and Disclosure Rule and the Renovation, Repair and Painting (RRP) rule.

One company failed to provide tenants in an apartment complex with lead paint disclosure information.  Additionally, this company violated three provisions of the RRP rule during renovation of the residential and commercial property in New Hampshire. The hired subcontractor involved violated several provisions of the RRP Rule during renovation, including failure to properly contain the work area.   Violation fines for both parties involved amount to $192,000 and up .

View Original Story at EPA.gov.Lead Based Paint

Lead exposure can affect almost every organ and system in children, pregnant women and adults.  Children under six years of age are more prone to lead-based paint effects which include behavioral problems, lower IQ, slowed growth, anemia and hearing problems.  Even small traces of lead can cause damaging health effects.  Lead exposure during pregnancy can reduce the growth of the fetus and cause premature birth.  Adults can also experience cardiovascular effects, high blood pressure, hypertension, and decreased kidney function, as well as reproductive issues.

To protect families and employees from lead exposure, it is imperative that renovators, property managers, sellers, and real estate agents follow two rules: the Renovation, Repair and Painting Rule and the Real Estate & Disclosure Rule.

What is the Renovation, Repair and Painting Rule?

The Renovation, Repair and Painting rule was implemented as a way to prevent lead-based paint exposure, primarily preventing exposure to children.   Renovators are required to complete an initial accredited training course when working with disturbed lead-paint surfaces.   Renovators must also be EPA-certfied to be able to work with lead-paint surfaces.  The rule also outlines proper lead safe work practices in order to contain and manage lead dust and chips.   Renovators and their employees must follow these guidelines.   Additionally, the rule mandates that records be kept to document work activities and compliance.

What is the Disclosure Rule?

Property owners and managers are required to provide potential tenants with information regarding lead-based paint risks and if the rental property contains lead-based paint.  Tenants should be given this information prior to signing a lease agreement in order for the tenants to make a well-informed decision.   This rule must be followed if the property was constructed before 1978.

The Disclosure Rule also affects home buyers and sellers. Sellers are required to provide the buyer with general information regarding lead paint hazards, known areas of lead-based paint, and provide a Disclosure of Information form noting that the seller has complied with notification requirements.

Property managers, renovators, sellers and real estate agents must provide the other interested party with a “Protect Your Family” Pamphlet provided by the EPA.  Visit the EPA website to download and save a copy.

If you suspect the presence of lead paint, contact a reputable consultant with experience in testing and monitoring for lead.  Feel free to contact an SRP consultant with any concerns.  Contact us at (318) 222-2364 or visit us online.  SRP has seven convenient locations in Charlotte, Dallas, Denver, Honolulu, Midland, Shreveport and Pittsburgh.

Recommended articles:
Asbestos Do’s and Don’ts for the Home and Office
What You Need TO know About Asbestos During Flood Restoration

EPA Increases Violation Fines: Makes Non-Compliance Riskier

 Return

EPA Increases Violation Fines: Makes Non-Compliance Riskier

The Environmental Protection Agency has received the ability to increase their violation fines in accordance with the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

Below is a quick reference guide to the fines you could be faced with for not being in environmental compliance.

Type of Violation  Current Civil Penalty New Civil Penalty
Emergency Planning & Community Right To Know Act $25,000 per day in violation $53,907 per day in violation
Clean Air Act $25,000 per violation $44,539 per violation
Clean Water Act $25,000 per violation $44,539 per violation
Resource Conservation and Recovery Act  $25,000 per violation  $56,467 – $70,117 per violation

Air, water, and hazardous waste violations receiving maximum penalties also got an increase by 78%.

Smoke Stack Air Pollution

  • Make sure state and local emergency responders have an inventoried list of hazardous chemicals in your facility, as well as the Safety Data Sheets. (EPCRA)
  • Immediately report all accidental releases of hazardous substances to the National Response Center, as well as state and local agencies. (CERCLA, EPCRA)
  • Submit Your Toxic Release Inventory report each year by July 1. (EPCRA)
  • Make Sure You Have an Updated Spill Prevention Control and Countermeasures Plan.
  • Obtain proper air pollution permits. (Clean Air Act, NPDES)
  • Obtain wastewater discharge permits prior to releasing into navigable waterways. (Clean Water Act)
  • Monitor Emissions Limits

Read More About NextGen Compliance

In July of 2016, SRP released information regarding OSHA penalty increases due to the Inflation Adjustment Act.  Safety compliance is also something to pay attention to in your facility.

Read More About OSHA Fine Increases

If you are concerned about environmental compliance within your facility or company, contact an SRP Environmental Consultant.  SRP  provides environmental compliance audits, annual reporting services, permitting assistance and risk evaluations .   Call SRP Today at (318) 222-2364 or visit us online to schedule a consultation.   We have seven convenient locations in Charlotte, Dallas, Denver, Honolulu, Midland, Shreveport and Pittsburgh.  Located elsewhere?  Let SRP come to you.

EPA Inspectors Are Looking for These 5 Things

 Return

Over the last 6 months or so, SRP has noticed major changes in EPA regulations.  Industry must now work harder than ever to eliminate the chance for pollutants to enter the environment and to stay in environmental compliance.

Here is a recap of 5 major changes that inspectors will be looking for.

  • Stormwater Runoff at Construction Sites.  The new Construction General Permit (CGP) won’t go into effect until March 2017, but it’s a good idea to start implementing new procedures to ensure compliance.   Common items found a construction site, like paint, caulk or debris, will be checked for hazardous chemicals.  Additionally, these items should not be able to be washed off site.  Dirt and debris piles will need to remain secure and covered if they won’t be used for more than two weeks.  Lastly, any construction activities performed on an acre or more are subject to stormwater permits.

Read More About the Construction General Permit

  • Risk Management Plans Are a Must.  Facilities EPA Inspectors Performing a Compliance Auditshould already have protocols in place in case of an accidental release, as well as policies in place to prevent hazardous chemical releases.  Key changes will be conducting a root-cause analysis after a chemical release, hiring a third-party audit, and coordinating with emergency responders on an annual basis.

Read More About Changes to Risk Management Programs

  • New Definition of Solid Waste.  EPA released a new revision of the Definition of Solid Waste (DSW) rule in order to provide protection against mismanagement of hazardous materials that are intended for recycling.  DSW omitted the transfer based exclusions and added a verified recycler exclusion: the “new provision requires that all hazardous materials recyclers operating under this provision have RCRA permits that address the materials, or obtain a variance prior to operating under the exclusion.” (EPA.gov)
  • Underground Storage Tank Compliance.  The EPA released new compliance regulations that took affect in April of 2016.  Tanks and piping must have secondary containment to hold leaks, overfills and spills.  Other requirements include mandatory yearly inspections and maintenance beginning in October of 2018.
  • Equipment Issues May Cause Higher Fines.  Now, 36 states have removed exemptions pertaining to the startup, shutdown and malfunction of equipment from their permits.  If a company exceeds air permit limits due to equipment issues, there will no longer be any leeway for violations.

There’s always new changes being proposed, which makes it difficult for companies to remain in compliance.  If you have questions about environmental compliance, contact an SRP Environmental Consultant today.  Call our headquarters at (318) 222-2364 or visit us online. We have seven convenient locations in Charlotte, Dallas, Denver, Honolulu, Midland, Shreveport and Pittsburgh.  Located elsewhere? Let SRP come to you.