Environmental Management Program

While many states have exemptions for parts washers, the exemptions often include surface area and VOC content restrictions. It is recommended that each unit is evaluated. [Certain solvents will be covered under the National Emission Standards for Hazardous Air Pollutants (NESHAP) and may include permitting, work practice, control, performance testing, and reporting requirements. Check with your state.]

Emergency generators alone will often not require permitting, but they are subject to federal emission standards. (Typically, exemptions apply only if generators comply with conditions laid out by the state.)

Once a permit is issued, facilities are responsible for becoming familiar with the requirements of their specific permit. Typically, air permits will include several conditions, and the facility must be able to demonstrate that it is operating within those conditions. Examples of common conditions or permit requirements include emissions limits, daily or monthly recordkeeping requirements, and reporting requirements.

To determine whether or not your facility meets Tier II reporting thresholds and is required to submit the annual Tier II report, you must use the best available information to calculate maximum storage amounts for hazardous materials. Common sources used to obtain this data include purchase and production records. (EHSs and their TPQs are listed in 40 CFR 355 Appendices A and B. Threshold levels for other hazardous chemicals are 10,000 pounds unless the hazardous chemical meets specific exemptions.)

In order to get your facility up to date and into compliance with these rules, it is recommended that back-filed reports be submitted for at least the previous three years for which reporting should have been submitted but was not. Back-filed reports can be submitted at the same time as the next upcoming deadline. (We also recommend contacting legal counsel.)

The process of determining whether your facility is a generator of hazardous waste begins with the identification of all of the waste streams generated at the facility. From here, each waste stream should be identified as hazardous or non-hazardous using a waste characterization process. Waste characterization may include generator knowledge of the waste stream, a review of safety data sheets, and/or analytical sampling, such as the Toxicity Characteristic Leaching Procedure (TCLP).

Yes, unless your facility is exempt based on SIC code. If your facility is not SIC code exempt, it must be covered either under your state's General Storm Water Permit or under a No Exposure Certification if there are no significant outdoor activities or materials at the facility.

In order to obtain coverage under your state's General Storm Water Permit, your facility must have developed and implemented a Storm Water Pollution Prevention Plan (SWPPP), including inspections, training, and the implementation of Best Management Practices. Additionally, sampling and recordkeeping will likely be required.

If your facility is discharging any type of process-related wastewater, a permit may be required. If the discharge is directly to a U.S. surface water, an NPDES permit will be required. If the discharge is indirect, to a sanitary sewer, it is recommended that the facility obtain documented permission from the receiving POTW for the quantity and type of wastewater being discharged. An NPDES permit may be required in some cases for indirect wastewater discharges.

No, oil storage inventories must be based on tank capacity. So even if you fill a tank only halfway, the total capacity of the tank must be included when determining SPCC applicability.

There is no minimum concentration requirement under the SPCC Rule, so even materials with low concentrations of oil-based products are also considered oil. This means that the capacity of the entire tank containing the mixture should be included in the oil storage inventory. As a general rule of thumb, if there is enough material to cause an oily film or sheen on the surface, the material should be considered oil. (Also, if you want to manage your used oil under the less stringent regulations at 40 CFR 279, you should not mix the used oil with other substances.)

Be polite and invite the inspector in; do not ask them to come back another time. Allow the inspector to guide the discussion, limit your responses to the questions asked, and keep facility tours to the requested areas. Respond truthfully and accurately to inspector questions, providing all requested information without offering any more information than necessary. Following the inspection, respond promptly to any follow-up correspondence and be sure to send any additional information that was requested.