Upcoming (2nd Quarter) Environmental Requirements and How we can help you
Over 50% of our clients are in Kansas and 16% in Missouri the remainder of our work is in the other 28 states. We have only posted items that we work with in these states. There will probably be other requirements specific to the states that if you have permits or requirements you need to calendar for compliance.
FEDERAL REQUIREMENTS THAT APPLY TO ALL STATES:
Toxic Release Inventories for required facilities must have reports filled by June 30.
Hazardous Waste (RCRA) Changes from changes in November 2016 (Federal Register) are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Some states have earlier filling requirements. We have noted some of these earlier reporting period.
STATES
Kansas
Government Organizations such as Counties and Cities
The EPA and State Solid/Hazardous Waste Requirements are that every organization must decide following certain guidelines about materials that they are disposing of. The State has specific forms and processes to determine which items are Hazardous Waste, Oils, Universal Waste and Special Waste. There also other products that have specific disposal requirements such as FIFRA and PCB materials.
We can assist your organization with determining what materials are in which category and documenting your solid waste program.
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021.
Ready Mix/Asphalt
The EPA requires all companies with certain industry codes and activities to prepare Toxic Release Inventory (TRI or FORM R). Both Ready Mix and Asphalt operations have materials that must be reported that are as small as 100 pounds and one material is 10 pounds.
We can do some simple calculations to let you know if you must do the report and if you require assistance, we can assist you.
This is the quarter that all ready-mix facilities must complete their annual stormwater comprehensive evaluation for forwarding next quarter. We already assist 50 organizations in Kansas and Missouri.
If we provide the assistance, we will complete an electronic checklist that will be e-mailed as well as the state inspectors checklist and the other state forms that must be mailed in.
Airports
This is the quarter you should review your Spill Prevention Control and Countermeasure (SPCC) Plan. Most airports have at least 1,320 gallons of oil products (Fuels, Fluids and Lubricants). You must have a current SPCC Plan (Prepared and reviewed every five years) that is specific to your location and details your compliance with the Federal Requirements and organization policies. Those locations that have over 10,000 gallons total oil products including portable containers like refuelers and transports) must be signed by a Professional Engineer.
Annual Inspections should include a review of the plan, ensuring all employees that may see a release have had annual training related to spills and the portion of your SPCC Plan that covers releases.
Verify your monthly inspection documentation
Verify your secondary containment discharge records.
Power Plants/Electric
The 2nd Quarter is a great opportunity to review your tank inspection program. Your SPCC Plan must detail this program including scheduling of the Integrity Testing of the tanks and methods to be used. If the Tank does not have a UL Label, then it must be inspected immediately to establish a baseline. If it has a label and is within secondary containment (including double wall tanks) then the general guidelines are:
Every tank must have a periodic inspection by a qualified inspector
Vertical Tanks should have an external inspection within a 10-year service schedule.
Horizontal Tanks (raised) should have an external inspection within a 20-year service schedule.
In addition, annually the tank should be inspected for visual issues such as leaking valves, hoses and to ensure overfill protection is accurate and in working order.
Fuel Providers
This is the quarter you should review your Spill Prevention and Control and Countermeasure (SPCC) Plan. The basic threshold is at least 1,320 gallons of oil products (Fuels, Fluids and Lubricants). You must have a current SPCC Plan (Prepared and reviewed every five years) that is specific to your location and details your compliance with the Federal Requirements and organization policies. Those locations that have over 10,000 gallons total oil products including portable containers like refuelers and transports) must be signed by a Professional Engineer.
Annual Inspections should include a review of the plan, ensuring all employees that may see a release have had annual training related to spills and the portion of your SPCC Plan that covers releases.
Verify your monthly inspection documentation
Verify your secondary containment discharge records.
Missouri
Specific to Missouri Facilities
Stormwater – Annual Certification of your Plans and Compliance Requirements.
April – Agrichemical Facilities such as bulk fertilizer and pesticides.
April - Stormwater and other specified discharges from limestone and other rock quarries, concrete, glass, and asphalt industries.
May – Plastics and Rubber Manufacturing Operations
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Missouri has an earlier reporting period of July 1.
Nebraska
Stormwater Permit and Plans – Nebraska Stormwater Permit expires in June and all facilities that are covered by these requirements must send in a notification to continue coverage and should update their SWP Plan with the new requirements that the EPA and the State have established since the last permit was issued.
Currently the following States are reissuing their Stormwater Permits for the State and could become effective this quarter.
Colorado
Maryland
South Dakota
Idaho – will be taking over the Stormwater Program from the EPA, effective July 1, 2021.
Remaining States
Arkansas
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Arkansas required this report be submitted by March 1.
California
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. California required this report be submitted by March 1.
Indiana
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Indiana required this report be submitted by March 1.
Louisiana
Stormwater Permit and Plans – Louisiana Stormwater Permit expires in May and all facilities that are covered by these requirements must send in a notification to continue coverage and should update their SWP Plan with the new requirements that the EPA and the State have established since the last permit was issued.
Michigan
Stormwater – Annual Certification of your Plans and Compliance Requirements by April.
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Michigan required this report be submitted by March 30.
Mississippi
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Mississippi required this report be submitted by March 1.
Minnesota
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Minnesota required this report be submitted by March 1.
Nevada
Stormwater – Annual Certification of your Plans and Compliance Requirements by June.
New York
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. New York required this report be submitted by March 1.
North Dakota
Stormwater – Annual Certification of your Plans and Compliance Requirements by April.
Ohio
Stormwater – Annual Certification of your Plans and Compliance Requirements by May.
Oklahoma
Stormwater – Annual Certification of your Plans and Compliance Requirements by June.
Tennessee
Stormwater – Annual Certification of your Plans and Compliance Requirements by April.
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Tennessee required this report be submitted by March 1.
Texas
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Texas required this report be submitted by March 1.
West Virginia
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. West Virginia required this report be submitted by March 1.
Wisconsin
Stormwater Permit and Plans – Wisconsin Stormwater Permit expires in May and all facilities that are covered by these requirements must send in a notification to continue coverage and should update their SWP Plan with the new requirements that the EPA and the State have established since the last permit was issued.
RCRA Changes from the November 2016 are requiring additional reporting requirements for every facility with an EPA ID Number, be completed by September 2021. Wisconsin required this report be submitted by March 1.