SALES AND MARKETING DIRECTOR 20 plus years in Health, Safety and Environment Management.
Environmental Consultant. Recent graduate from the University of Kansas with a bachelors in Environmental Studies
Midwest Training and Consulting Services
Provide computer technology to provide an efficient and time saving measures related to organizational environmental compliance.
Provide on and off-site development and implementation to organizations with Environmental Compliance Regulatory Programs.
Provide organizations with a business resource in relation to Federal, State and local environmental regulatory requirements.
MTCS has become the leading provider of Spill Prevention Countermeasure and Control Plans (SPCC) and in the last twelve years we have completed over 800 SPCC plans. Our clients have been federal, county and city organizations as well as many private and public companies.
We have completed SPCC Plans in 25 states, including Kansas, Missouri, Nebraska and Iowa, Arkansas and Oklahoma.
Our staff has just completed the Steel Tank Institute (STI) SP-001 tank inspector course so that we can assist our clients with integrity testing requirements of the EPA. We have completed over 600 steel tank inspections. We have started assisting organizations with annual steel tank inspections using the STI guidelines.
Stormwater Pollution Prevention Plans (SWPPP) have a recent increase in government compliance attention and we have recently completed many for manufacturing and transportation activities.
Emergency Planning and Community Right to Know (EPCRA) Tier II and Form R. We have completed over 175 reports for the 2018 calendar year.
Environmental Activites and types of Organizations
Local City and County Organizations: 36
Airport Operations: 20
Ready Mix and Aggregate Producers: 21 with 71 locations.
Power Plants and Electrical Cooperatives: 14
Petroleum Marketers Convenience Association Members and oil, fuel distributors: 40
Transportation Organizations: 10
Truck and Equipment Activities: 9 states
Manufacturing Organizations: 41
Agricultural Cooperatives and Farms: 16
Construction Organizations: 7
Clients we served in 2018: 90 with over 292 locations in over 26 states.
Online tracking system with your permit documents
Environmental Inspections-available for you to use.
Divided into monthly topics to ensure compliance
Our Clients Include:
Some pretty amazing folks
Midwest Training and Consulting Services offers the comprehensive capabilities and deep industry knowledge necessary to help you solve the most complex issues of your organization. Since opening our doors in 2000, we’re proud to say that each year we have a bigger list of returning and new clients. Scroll down to see our clients,
Want to experience the expertise of Midwest Training and Consulting Services for yourself? Give us a call today and let’s discuss what we can do for you.
Our Amazing Clients
1 Stop, Parker, Kansas – Environmental – (SPCC Plan)
A&E Custom Fabricating, Kansas City Kansas – Training and Environmental Assistance
Advanced Aviation, New Century, KS – Environmental (SPCC and Stormwater Plans)
AG Partners – Iowa – Integrity Testing – 3 locations
AG Service, Assaria, Kansas – SPCC Plan
Alex Masson, Linwood, KS – Environmental (SPCC Plan and Five Year Review)
Allen County, Kansas – Public Works – Environmental (SPCC Plan) and Storm Water Plans
Alliance AG, Haviland KS – Environmental (SPCC Plan)
Andale Ready Mix – Wichita, Kansas – Environmental – SPCC Plan (3), TIER II/ FORM R
Aplus Trucking – Wichita, Kansas – Environmental – SPCC Plan, TIER II and SWP Plan
Arrow Forklift, Lenexa, KS – Environmental Services (EPCRA TIER II and FORM R)
Arrow Stage Lines, Kansas City, Missouri – Environmental Review
Atchison County, Kansas – Public Works – Environmental (SPCC Plan and Five Year Review)
AV Energy, Dodge City – Environmental Services (13 locations)
Bayer Construction, Manhattan, KS – Integrity Testing of Tanks and 4- SPCC Plans
Beaver Lake Concrete, Rogers, AR – SWP Plan and TIER II Report
Bennett Rogers Pipe, Kansas City, KS – Safety and Environmental Assistance
Blish-Mize, Atchison, KS – Environmental (SPCC Plan and Five Year Review)
Brittain Machine – Wichita, Kansas – SPCC Plan, TIER II and FORM R
Broderson Manufacturing, Lenexa, Kansas (Environmental Assistance)
Builder’s Choice, Topeka, Kansas (7 Locations) (SPCC Plans) and Integrity Testing
Burd and Fletcher, KCMO – Community Right to Know TIER II
Butterfly Aviation, Goodland, Kansas (SPCC Plan, SWP Plan, and Integrity Testing)
Capital Concrete, Topeka, Kansas – Stormwater Plan
Capital City Oil, Topeka, Kansas – Integrity Testing for Four Locations
Castagno Oil, Girard and Pittsburg, Kansas – Environmental – (SPCC Plans)
CENEX – Blackwater – Centerview, MO – SPCC Plan
Central States Thermo King (CSTK) – SPCC Plans for 3 Locations (KS, MO, and OK)
Central Valley AG, York, NE – 18 SPCC Plans and Tank Inspections in locations in Iowa, Kansas and Nebraska
Chandler Oil, Chanute (3 locations) and Fredonia, Kansas (SPCC Plans)
Cherokee Public Works, Kansas– Environmental (SPCC Plan)
Cheyenne County, Kansas Road and Bridge – SPCC Plans (2) and Integrity Testing
Chuck Henry Sales – Solomon, Ks – SPCC Plan and Integrity Testing
City of Abilene, Kansas – Environmental (SPCC Plans Airport, Wastewater, and PW)
City of Belleville, Kansas – SPCC Plans for Power Plant and Airport
City of Branson, Missouri – SPCC Plan Training Class
City of Burlington, Kansas – Power Plant, Environmental SPCC Plan
City of Emporia, Kansas – Environmental (SPCC Plan and SWPPP for Airport and Waste Water, Streets – SPCC Plan)
City of Fort Scott, Kansas – Airport, Streets and Wastewater Facility (SPCC Plan and Stormwater Plan)
City of Girard, Kansas – Power Plant and Substations- Environmental (SPCC Plan)
City of Glasco, Kansas – SPCC Plan
City of Horton, Kansas – Power Plant – Environmental (SPCC Plan)
City of Iola, Kansas – Environmental (Two Power Plants and Substations- SPCC Plan and Streets)
City of Jamestown, Kansas – SPCC Plan
City of Manhattan, Kansas – Airport – Environmental – SPCC Plan and SWP PLAN
City of Neodesha, KS – Environmental (SPCC Plan and Integrity Testing)
City of Osage, KS – Power Plant – Integrity Testing of Steel Tanks
City of Ottawa, KS – Airport – SPCC Plan
City of Sabatha (3 locations), Sabatha, Kansas – Environmental – (SPCC Plan) and tank inspections
Clay County Public Works, Kansas – SPCC Plan
Clymore Trucking – Independence, Missouri – SPCC Plan
Coffey County Airport – Environmental (SPCC Plan)
Concrete Enterprises – Hutchinson, Kansas – Form R Reporting
Concrete Materials – Merriam, Kansas – Form R Reporting
Concrete Supply of Topeka (Environmental Assistance – 5 SPCC PLANS)
Council Bluffs Airport – Council Bluffs, IA – SPCC Plan and EPCRA TIER II Report
Cox Machine – Wichita, KS – SPCC Plan and SWPP Plans (2 locations)
Crop Productions Services – Westboro, MO – SPCC Plan
Crop Services Center– Abilene, KS – SPCC Plan in Two Locations
CS Carey, Kansas City, Kansas – SPCC Plan
Custom Truck One Source (Kansas City, Missouri) – MO – 4 Locations, TX – 3 Locations, GA, SD, OK, CO, WI, OH, VA, NJ, NH, NY
D & S Convenience Stop – 2 locations (Ellsworth, Kansas) SPCC PLAN and 5 year review
Dailey AG – Oskaloosa, KS – SPCC Plan
Day and Zimmerman, Parsons, KS – Integrity Testing
Dayton Superior – Kansas City, Kansas – SPCC Plan and Five year review
Dieker Oil Company – Cottonwoods Falls, KS – Environmental (SPCC Plan)
Dodge City Concrete – Dodge City and Garden City – Environmental Assistance
Dodge City Waste Water (CH2M), Dodge City, KS – Environmental (SPCC Plan and TIER II)
Doniphan Electric – Troy, Kansas – SPCC Plan
Dossett Farm – McPherson, KS, Environmental (SPCC Plan)
Double Check Company – Environmental (SPCC Plans – 5 clients – KTA, Twin Valley Electric, Cities – Aurora)
Eakin Enterprises, Hays, Larned and Great Bend – SPCC Plans for locations
Earp Distribution, Kansas City, Kansas – SPCC PLAN and SWP Plan
Ebert Construction, Wamego, Kansas – SPCC Plan and Integrity Testing
Ellis County – Hays, KS – Integrity Testing
Evans Equipment – Concordia, MO, Environmental -SPCC Plan and CAA Permits, and Integrity Testing
Evans Oil – Lawson, MO – SPCC Plan
Farmway Union Cooperative (Hartington, NE) – SPCC Plan and Integrity Testing
Finney County – Garden City, KS – Integrity Testing
Fischer Concrete Services, Sedalia, MO – TRI Inventory- Form R
Fleet Fuels – KCMO, Tank Inspections in Kansas
Foley Equipment – Wichita, Ks – (KCMO and Topeka) – SPCC PLAN
Freestate Electric Cooperative – Topeka, KS – SPCC Plan and Tank Inspections
GARMIN INTERNATIONAL – New Century, KS – Airport – SPCC PLAN
Gas and Snack – Seneca, Mo – Integrity Testing two locations
Genysis Works – Blue Springs, MO – SPCC Plans
Gier Oil (Eagle Stop – Eldon – 43 Locations – Environmental Assistance, 13 SPCC Plans, 8 SWPP Plans
GFL Environmental, SPCC Plans in AR, LA, MO
Gove County – PW, SPCC Plan
Graham County – PW – Hill City, KS –SPCC Plan
Great Plains Aerial, Colby, KS – SPCC Plan
HAAG & Decker Oil – Environmental (SPCC Plan) and Integrity Testing– 3 locations
Hamm Quarries – Perry, Kansas – SPCC PLANS (4) – Integrity Testing of Steel Tanks
Harrington Oil – Frankfort, KS – SPCC Plan
Harshman Construction – SPCC Plan for Rock Quarries (15 locations)
Heartland Aviation – SPCC Plan and Integrity Testing of Tanks
Heartland Rural Electric COOP – SPCC Plan for 6 locations
Hirt Farm (DAVLAN) – Environmental ( SPCC PLAN)
Hutto Grain – Galena, KS – SPCC Plan
Independence Ready Mix – SPCC Plan and Integrity Testing
IPL – (Plastic Enterprises) – Lees Summit, SPCC Plan and TIER II Report
Iron Mountain – KCMO – SPCC PLAN AND AIR PERMITTING
Jackson County, Kansas – Road and Bridge – SPCC Plans and Integrity Testing
Jefferson – Leavenworth Electric Co. – Environmental (SPCC Plan) and Integrity Testing
Jefferson County, Kansas – Environmental (SPCC Plans) and integrity testing – 2 locations
JL Houston – Safety and Environmental Program Assistance and SPCC Plan
Jones Oil – Lyons, KS – SPCC Plan
Joplin Concrete, Joplin, MO – Air Permit, TIER II and Form R Reporting
Kansas Electric Power Cooperative (17 Members) – SPCC Plans
Kansas Sand and Concrete – Environmental (SPCC Plans and Five Year Review)
Kansas City Aviation Center (JOCO Executive Airport & Spirit of St Louis) – Environmental and SPCC Plan
Kaw Valley Aviation, Topeka, Kansas – SPCC Plan and SWP Plan
King Construction, Oskaloosa, Kansas – Environmental Assistance (SPCC Plan)
Kirk Brown, Russell, Kansas – SPCC Plan
Kay Concrete, Monett, Kansas – TIER II and Form R Preparation
Kramer Oil, Frankfort, Kansas – SPCC Plan
Lake Perry Marina, Perry, Kansas – Integrity Testing
Lancaster Oil, Lancaster, KS – SPCC Plan (including Five Year Review) and Integrity Testing
Langley Recycling – Topeka, KS – Integrity Testing
Leavenworth Asphalt, Leavenworth, KS – Integrity Testing
Leavenworth County, Kansas – Environmental (SPCC Plan) Public Works and Quarry and Integrity Testing
Lincoln County – Lincoln, KS – SPCC Plan (2)
Little Blue Valley Sewer District, Independence, MO – Safety Assistance and SPCC Plan
Logan County R&B, Winona, Kansas – SPCC Plan and Integrity Testing
Marlatt Construction Company, Atchison, KS – Environmental (SPCC Plan and Five Year Review)
McAllister Transportation, Marion and West Memphis, Ark – Environmental (SPCC Plan and SWP Plan)
MC Aviation – Colby, KS – SPCC Plan
Mears Fertilizer – El Dorado, Kansas – 2 – SPCC Plans
Metropolitan Topeka Aviation Administration (MTAA), Topeka, Kansas – Environmental (SPCC Plan)
Miami County, Kansas – Road and Bridge and Airport, Environmental (SPCC Plans) and Integrity Testing
Midway Ford Truck Center – KCMO, SPCC Plan
Mid South Steel Products, Cape Girardeau, MO – Safety Program And Environmental Assistance
Midwest Energy – Hays, Kansas, Environmental (SPCC Plans and Five Year)
Mies Transportation- Colwich, Kansas – Two SPCC Plans
Million Air – Spirit of St Louis Airport – Safety and Environmental Assistance and SPCC Plan
Million Air – Topeka Airport – SPCC Plan and Integrity Testing
MJ Murphy Oil Company – Environmental (SPCC Plan and Five Year Reviews and Stormwater Plans) – 5 locations
MO’s Stop and Shop – Linn, KS – Environmental (SPCC Plan)
Montgomery County, Kansas (Road and Bridge) – SPCC Plan and Five Year Review
Midwest Ready Mix – Sabetha, Ks – Stormwater Permit and Plans
Miller/Old Castle, Kansas City, Missouri – Water Permit Samples and Storm water Plans
Missouri Western State University, St Joseph, MO – SPCC Plan and Integrity Testing
Monarch Cement, Humboldt, Kansas – Phase 1 and SPCC Plan
Monarch Cement of Iowa, Des Moines, IA – TIER II Reporting
Mueller Construction, Coffeyville, KS – SPCC Plan, Integrity Testing, and TIER II Report
Mutton Creek Marina – Stockton Lake, Missouri – SPCC Plan
Multivac – KCMO, Safety and Industrial Hygiene Assistance
Myers Farms, Colby, KS – SPCC Plan
National Weather Forecast, Wichita, Ks – Indoor Air Quality
NCS, Shawnee Kansas – OSHA compliance assistance
Nebraska Machinery Company – Omaha, Ne – Assisting 19 facilities in 3 states, SPCC Plans, Integrity Testing and Other Environmental Assistance
Neosho County, Kansas – Public Works – SPCC Plan
NGL Propane – Nortonville, Kansas – Environmental Site Assessment (ESA)
Norfolk Iron and Metal – Norfolk, NE, Emporia, Ks, Greeley, CO and Durant, IA – SPCC Plan and Integrity Testing, Stormwater Permit and Plans, and Community Right to Know Reporting
Novation IQ – Lenexa, KS, Environmental Reporting (TIER II and Stormwater Permit and Plan)
O’Riley Oil Company, Hopkin, MO – Environmental (SPCC Plan) and Integrity Testing
Orleans Marina – Stockton, MO – SPCC Plan
P & J Mart, Howard, Kansas – Environmental (SPCC Plan and Integrity Testing)
Parallel Farms, Whiting, Ks – Integrity Testing
Pawnee County R&B, Kansas – SPCC Plan
Peterson Manufacturing – Grandview, MO and Nashville, AR- Environmental (SPCC Plans)
Penny’s Concrete – Environmental for 27 locations including (15- SPCC Plans), SWPP Plans and EPCRA Reports
Platte Clay Electric Cooperative – Kearney, MO – SPCC Plan
Prairie Band, Holton, KS – SPCC Plan and Integrity Testing Tanks
Prairie Land Electric, Norton, KS – Integrity Testing
Ramsey Oil – Hutchinson, KS – 5 Locations – SPCC Plans – KS AND OK
Rawlins County, Atwood, KS – SPCC PLANS (3)
REAdy Farm, Bethany, MO – SPCC Plan
Renuel Fuel, KCMO – Integrity Testing
Republic County, KS – Highway Dept – SPCC Plan
Revere Plastics, Popular Bluff, MO – SPCC Plan
Rimpull Corporation, Olathe, KS – Safety and Environmental Assistance
Roadbuilders Machinery, Kansas City, Kansas – (SPCC PLAN – five locations – KS, MO and NEB) and EPCRA TIER II reports
Robbie Manufacturing, Lenexa, KS – OSHA Programs and Industrial Hygiene (Noise and Air Sampling)
Robison Oil – Abilene, KS – SPCC Plan and Integrity Testing
Rodgers Oil – Gridley, KS – Environmental (SPCC Plan)
ROM Corporation – Belton, MO – Safety and Environmental Assistance
Saline County, KS Highway Dept, Salina, Ks – SPCC Plan and Integrity Testing
Savage Services – Environmental (SPCC Plans in AR, CA-2, CO, IL-2, IN-3, KS-2, KY-`,LA-2, MD-2, MI-2, MN-1,ND-3,NV-1, OH-5, PA-4, TX-3, UT-5, VA-2,WV and Integrity Testing, Stormwater Plans and TIER II Reporting
Schock Transfer – Kansas City, KS – SPCC Plan and Five Year Review
Schreiner Energy – Olpe, KS – Environmental (SPCC Plan)
Schnoover Oil Company – Mound City, MO – Environmental (SPCC Plans)
Sherman County, KS Public Works, Goodland, KS – (SPCC Plans)
Sho Me Electric, Marshfield, MO – SPCC Plans – (4) and Integrity Testing
Skymark – Kansas City, KS and Findlay, OH- Environmental Assistance (Air Permit), SPCC Plans for KC and Findlay, OH and Safety Assistance
Southwest Butler Quarry – Augusta, Kansas – SPCC Plan and TIER II
Spencer Farms – Westphalia, Kansas – SPCC PLAN
Springfield Ready Mix – Springfield, MO – Community Right to Know, TIER II
Spring Hill Oil – Spring Hill, KS – SPCC Plan and Integrity Testing
Springfield Underground – Springfield and Joplin, MO – Integrity Testing
Stafford County, Kansas – Public Works – SPCC and Integrity Testing
Theis Dozier, Spivey, Kansas – SPCC Plan
Twin Creek, Inc., Kingston, MO (SPCC PLAN and 5 year review and Integrity Testing
Unitech, Lees Summit, MO – Environmental, Industrial Hygiene, and Safety Assistance
VERTEX Plastics – Kearney, MO – Safety and Environmental Assistance
Victory Electric – Dodge City, KS, Environmental Assistance (SPCC Plan and Five Year Review)
VP Racing – Manhattan, KS – SPCC Plan
Wanklyn Oil – Frankfort, KS – Integrity Testing and SPCC Plan
Washington County Public Works – SPCC Plan and Integrity Testing
Waubanesse County Public Works – SPCC Plan
We Mac Manufacturing – Safety and Environmental Assistance (Air Permit, Form R and Tier II, SWPPP and SPCC Plan)
Wear Concepts – Liberty, MO – MACT 6X
Wes Recycling – Centerview, KS (SPCC and SWPPP Plans)
Western Chemical Pumps, Olathe, KS (Safety and Industrial Hygiene Assistance)
Wheatland Electric – Garden City, Kansas – SPCC Plan
White River Electric – Branson, Missouri – Integrity Testing
WIESE USA – St Louis – EPCRA TIER II – 28 locations in seven states
Wilson Trucking – Abilene, Kansas – SPCC Plan
Zollicker Oil – Clinton and Warsaw – SPCC Plans
Z W Tech, Kansas City, Kansas – SPCC Plan and Storm Water Plans
“Facilities covered by The Emergency Planning and Community Right-to-Know Act (EPCRA) must submit an emergency and hazardous chemical inventory form (Tier II Report) to the LEPC, the SERC and the local fire department annually.” This report is due March 1st of each year.
The EPA currently lists over 300 Extremely Hazardous Chemicals. If you use, store or manufacture any of the listed chemicals at or above their Threshold Planning Quantity (TPQ), those chemicals must be reported in a Tier II Report. Please note – if a chemical does not meet its TPQ, but you manufacture, use or store over 500 pounds in weight at your facility, it also must be disclosed in a Tier II Report. In addition, ALL other chemicals have a TPQ of 10,000 pounds, and if you use, store or manufacture these chemicals in quantities greater than 10,000 pounds at your facility, they must also be reported.
If a chemical meets its TPQ, an Emergency Planning Document must also be prepared.
It is important to note the standard of measurement for these chemicals is pounds, not gallons. Items easily overlooked are Compressed Gases (propane, nitrogen, oxygen) which may weigh over 10 pounds per gallon; Forklift Batteries contain battery acid and approximately 18% of the total weight of a battery, in some cases one battery could reach the 500 pound threshold.
You may already have the necessary documents by another name. If you have a Spill Prevention Plan certified by a professional engineer it would meet the requirement for over 10,000 pounds (1,320 gallons) of petroleum products. An RCRA Contingency Plan, developed for hazardous waste, may meet the requirement if modified.
We do an on-site inspection, prepare all necessary cover letters and documentation, including a chemical list and site diagram. If needed, we also prepare an Emergency Planning Document for your facility.
For the 2015 annual reporting we completed over 125 reports.
Tank Management Systems
Owners Responsibilities relating to Tank Management.
The owner is responsible for compliance with the Steel Tank Institute SP-001, fire codes, ordinances, and other rules and regulations.
The owner shall verify that persons working on ASTs understand and address all hazards association with the contents of the ASTs, as well as safe entry and hot work procedures with those ASTs.
The owner inspections are responsible for performing the periodic AST inspections and documentation the results.
The owner is responsible for assuring that the tank is appropriately designed, constructed, repaired (if necessary) and maintained to operate safety in the intercede service conditions.
The owner has the responsibility to address corrective actions identified in inspection reports.
The management program we propose to assist you with is:
First, we categorize your Above Ground Storage Tank to determine what your inspection and full integrity testing requirements must be completed.
The EPA requires an Annual Tank Inspection. Steel Tank Institute which is one of the standards the EPA states should be completed. This would include an initial External Inspection by STI Inspector and document event.
This inspection will include: Documenting the inspection from US EPA and Steel Tank Institute – Annual Inspection Requirements for Above Ground Storage Tanks and Components of the Tank.
We already have an automated tracking system for environmental and tank inspection requirements. We can assist you with the input of your locations and will assist you in suspensing the inspection requirements of your bulk tanks. Tracking will include all tank maintenance, Fire Codes, state and local Ordinances and other rules and regulations.
An initial external inspection and evaluation of the tank program. Includes identifying a baseline integrity of the steel tank. If the tank does not have an Underwriters Laboratory label or engineering drawings, then a baseline must be established. If records of the tank are not available, ultra sound measurements may be taken. If additional inspection such as integrity testing of some tanks, we can do that also. Documentation for each tank will completed.
Initial and Periodic Tank Inspection –
Initial inspection includes checking for presence of water inside a tank and including the interstice if a double wall AST.
Management of fuel tanks systems.
Corrosion Management and evaluation
Ensure water management program is conducted.
Verify compliance with employee monthly inspections.
Verify regulatory inspections of equipment such as overfill protection is completed, tested, and issues are corrected.
Vents are proper and working
Check electrical wiring, including grounding
Inspect and verify operation of ancillary equipment to include:
Piping and piping connections
Stairways, handrails and platforms
Monitoring of correction of deficiencies.
Documentation of Water Releases from Containment.
Conduct Annual Employee Training for Above Ground Storage Tanks (how to conduct inspections) and management of SPCC Plans.
We can also provide Quarterly information (provided through email) on up to date Environmental and Tank programs.
We can also assist with evaluation of additional mandatory external inspection requirements for initial installation, episodic (Severe Weather and Extreme Icing), change of product and repairs to tank.
If we can answer any questions, please contact us. We expect most of the assistance after the initial visit, can be by phone, email and other electronic means.
Richard Smith, MTCS, Phone Number is 913-638-3455. Email firstname.lastname@example.org, Company Website: Midwest-training.com
Storm Water Permits
General: Facilities with a stormwater discharge associated with industrial activity subject must request authorization for and obtain coverage under an NDPES permit. Coverage may be obtained under this general permit, or by meeting the requirements for permit exemption or exclusion. This program does not relieve a facility with other Clean Water Act requirements relating to direct discharges, wetlands and special aquatic restrictions, and community requirements.
Stormwater Associated with Industrial Activity means the discharge from any conveyance that is used for collecting and conveying stormwater and which is directly related to manufacturing, process or raw materials storage areas at an industrial plant.
If your facility has “no exposure” (all industrial materials and activities are protected by storm resistant shelter to prevent exposure to precipitation, snowmelt, surface runoff or drainage) then a certification that there is “no exposure” must be submitted.
There are 11 categories some of the more common are listed below.
Category (i) Facilities subject to stormwater effluent limitation guidelines, new source performance standards, or toxic pollutant effluent standards under 40 CFR Subchapter N (numerous activities and processes). There are already 57 specific industry requirements relating to water run-off of facilities. Category (ii) Certain specific industries Series 24, 26, 28, 29, 311, 32, 33, 34, 373. Category (iii) Mineral Industries, Category (iv) Hazardous Waste Activities, Category (viii) Transportation Activities. Category (xi) Light Industry activities
The EPA program documents includes material handling equipment (including earth moving).
Obtaining Authorization – Notice of Intent
Submission of a Notice of Intent must be submitted, even if already submitted. There is a change of form that requires certain information be provided. In addition, there is a state fee required at the submission.
For new facilities requiring authorization to discharge stormwater runoff, must submit an NOI at least 60 days prior to commencement of the covered industrial activity.
Stormwater Pollution Prevention (SWP2) plans and Best Management Practices (BMP).
The permittee must develop a stormwater pollution prevention (SWP2) plan that is specific to the industrial activity and site characteristics occurring at the permitted location described in the NOI. The permittee must fully implement and periodically review, and update as necessary, the provisions of their SWP2 plan.
The SWP2 Plan is to be retained on site and made available to State EPA, or MS4 upon request.
The plan requirements are outlined in the EPA/State document. This includes general facility information, description of potential pollutant sources, measures and controls, monitoring and recordkeeping requirements, spill and release requirements and reporting.
• Review facility for versus requirements of the procedure.
• Ensure Notice of Intent (NOI) and Annual review (fees) are submitted.
• Develop documentation a Stormwater (P2) Plan for facility.
• Designate person to administer the Stormwater (P2) plan program.
• Provide local training of site personnel.
• Conduct Inspections required by Site specific Stormwater (P2) Plan
• Maintain inventory of equipment and containment to reduce or eliminate stormwater contamination from facility.
• A log to document a description of incidents and items that need follow-up must be maintained.
• Visually inspect stormwater quality periodically.
Phase One Environmental Site Assessments
WHO NEEDS An Environmental Site Assessment: Phase I
Owner/Operators that intend to apply liability defenses must complete the Phase I or Due Diligence is completed to satisfy one of the requirements to qualify for the liability defense:
1) Innocent Landowners (Owner/Operator)
2) Contiguous Property Owner
3) Bona Fide Prospectus Purchaser
4) Application for EPA Brownfield's Grants
PURPOSE OF PHASE I
The Phase I uses requirements of ASTM E1527-05 and 40 CFR 312 is required to find:
A. Recognized environmental conditions means presence or likely presence of any hazardous substances and/or petroleum products.
B. All appropriate inquiry for other state, local laws and federal laws.
C. Brownfield’s grants, you must also look for controlled substances that could be at the property.
WHAT WILL YOU GET WITH THE PHASE I
Four Components that must be included:
A. Records Review, historical sources and records from federal, state, and local government records, UST records, and Hazardous Waste handling, treatment, storage, disposal and spill records.
B. Site Reconnaissance, visual inspection of the facility and adjoining property. Includes geological concerns, general description of property, storage tanks, pools of liquids.
C. Interviews, past and present owners, operators, and occupants of facility.
E. If Brownfield’s Grants, then research on history of controlled substances must be reviewed.
F. No bulk sampling of materials, this could be recommended for the Phase II.
WHY YOU MIGHT WANT TO HAVE A PHASE I
This is something you want before your purchase the property. Financing companies will want this before approving the financial agreement.
1. Obtaining a new commercial or industrial property
2. Expanding your current facility by obtaining adjoining property.
3. Expanding your current operations by leasing additional property.
4. Leasing your facility property to another industrial/commercial enterprise.
5. Refinancing your operations budget.
6. A government agency may condemn property for local government buildings.
7. Recovering a property for delinquent obligations (back taxes).
8. Obtaining a Brownfield’s grants for assistance in a hazardous substance clean-up.
ADDITIONAL ITEMS ON PHASE I that may be requested:
Asbestos Lead in Paint and Drinking Water
Wetlands Endangered Species
Regulatory Compliance status Mold and other Indoor Air Quality Issues
Midwest Training and Consulting Services (MTCS) started in April 1996 as an independent safety, health and environmental consulting services. WE ARE THE PREMIER PROVIDER OF THE EPA’s SPILL PREVENTION PLANS (SPCC) in the four state areas of Kansas, Missouri, Iowa and Nebraska. We completed over 74 last year and nearly 800 plans in the total.
DO YOU NEED SPCC PLAN? Companies meet the threshold of the SPCC Plan (40 CFR 112.7) requirement (1,320 gallons of oil products (fuels, fluids, and lubricants). This includes all containers 55 gallons or greater – drums, totes, tanks, electrical equipment and equipment reservoirs new or used. Once the threshold is met you will need to have a Spill Prevention Control and Countermeasure Plan. This law has been in place since 1973 and has had many changes since that date. You should complete these documents as soon as possible, so you will know what changes to your facility and operations the Professional Engineer will require meeting the EPA rules.
I recently reviewed of all EPA Inspections of locations where SPCC Plan’s were the reason for the inspection. The following information is based on inspections where no fuel or oil was released. 85% of all SPCC Plans inspected had deficiencies including no SPCC Plans completed with fines assessed. Technical Amendments: Technical changes to your facility operations and bulk storage containers must be approved by a Professional Engineer. You have 6 months to make these amendments to your facility once the change has been made. Every Year: Your management official should review the document for any changes and if technical amendments are noted. A review of your facility, training and recordkeeping should also be checked. Five Year Review: EPA requires a management official to review the SPCC Plan every five years. This has two important requirements bring your SPCC Plan update with changes the EPA has made in past five years and changes to your facility in the past five years.
Other inspections violations include 45% of the locations had deficiencies related to inspections and 50% of the locations had not completed required training. 95% of the locations had not completed the integrity testing of the bulk storage containers. We can assist your organization with our training and inspection workbooks and we can complete the tank inspections for steel – shop built tanks.
INTEGRITY TESTING OF ABOVE GROUND STORAGE TANKS (AST)
If you have a SPCC Plan then you know you must complete integrity testing for your tanks. The EPA has spelled this out since the 2002 changes to these regulations. The allowed some grace period to get it completed by November 2011.
If you have above ground storage tanks the professional engineer should have designated a period of time to complete your inspections including the integrity testing of bulk containers larger than a drum. You should make sure your tank has a UL 142 stamped label on the tank. If you do you should be able to have the tank in service for 10 years without integrity testing. If you do not have a UL label or you do not know how long the tank has been in service, you should arrange for this testing immediately. If you know the manufacturer of the tanks you may contact them to verify the date of service or the standard which was used to construct the tank.
The EPA regulation 40 CFR 112.8 states a qualified inspector with either Steel Tank Institute (STI) or American Petroleum Institute (API) complete the inspection. There will be a visual inspection to verify the tank system is complete and one form of nondestructive testing. Since technology exists with the ultrasound device, many companies including ours uses this type of device.
The key to not completing an internal inspection is the tank cannot be in contact with soil. The ultrasound measurement device allows us to do this inspection at a reduced rate.
Some basic questions you should be asking your staff.
Do we have an integrity testing program?
Do we have all inspection and maintenance items in our SPCC Plan.
Do we have any plastic totes that we are reusing in service over 5 years.
Do we have any bulk containers greater than 55 gallons that we have had in service over 10 years need integrity testing by a qualified inspector.
Have we completed all items of concern from maintenance items and inspectors requirements.
FORM R Reporting
What is the Toxics Release Inventory?
Why was the TRI Program created?
In 1986, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) to support and promote emergency planning and to provide the public with information about releases of toxic chemicals in their community. Section 313 of EPCRA established the Toxics Release Inventory.
Is TRI a mandatory program?
TRI is a mandatory program. The TRI Compliance and Enforcement webpage has more information.
What is the Toxics Release Inventory?
TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. U.S. facilities in different industry sectors must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery and treatment. (A "release" of a chemical means that it is emitted to the air or water or placed in some type of land disposal.)
The information submitted by facilities is compiled in the Toxics Release Inventory. TRI helps support informed decision-making by companies, government agencies, non-governmental organizations and the public.
What are TRI toxic chemicals?
In general, chemicals covered by the TRI Program are those that cause:
Cancer or other chronic human health effects
Significant adverse acute human health effects
Significant adverse environmental effects
There are currently 755 individually listed chemicals and 33 chemical categories covered by the TRI Program. Facilities that manufacture, process or otherwise use these chemicals in amounts above established levels must submit annual reporting forms for each chemical. Note that the TRI chemical list doesn't include all toxic chemicals used in the U.S.
What types of industries are included in TRI?
Facilities that report to TRI are typically larger facilities involved in manufacturing, metal mining, electric power generation, chemical manufacturing and hazardous waste treatment. Not all industry sectors are covered by the TRI Program, and not all facilities in covered sectors are required to report to TRI.
Your organization must have 10 employees and meet the threshold of listed chemicals. Common materials for Ready Mix are Lead which is found in cement and Nitrates in Aqueous Solution found in Non Chlorinated Additives (NCA).
TRI Compliance and Enforcement
Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) created the Toxics Release Inventory (TRI) Program. Under the requirements of EPCRA, all U.S. facilities that meet TRI reporting criteria must submit TRI data to EPA and the relevant state or tribe by July 1 of each year. This is strictly electronic submission. The initial set up will take some time and each aspect must be approved by the EPA website administrator. Generally after May 15, the system gets bogged down because there is only one site for the entire country and the system is closed off at Midnight of June 30. The next two weeks they generate non receipt of forms, letters.
EPA investigates cases of EPCRA non-compliance and may issue civil penalties, including monetary fines, and may also require correction of the violation. EPCRA Section 313 compliance resources include inspectors and attorneys in each of EPA's 10 regional offices and at EPA headquarters.
For more information, please call Steve Spencer at 316-644-6102 or MTCS at 913-712-8077