If you store any oil-based liquid, including synthetic oils, animal fats (but not milk), oils, & greases, or vegetable oils, you may be subject to the federal regulation 40 CFR 112, which requires the preparation and implementation of an SPCC plan. To determine whether any non-contiguous site or facility is subject to this rule or not, the following questions need to be answered. In regard to this rule, “oil” does not include such liquids as antifreeze or pesticides, unless the antifreeze is petroleum-based. 1. Is the facility considered to be “non-transportation” related? (I.e., the primary purpose of the facility is not transporting oil on public roads.) If the facility is transportation related, this rule does not apply.2. Is the facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil? If not, this rule does not apply.3. Could the facility reasonably be expected to discharge oil in...

The last blogpost discussed the difference between an environmental audit and a Phase I Environmental Site Assessment (ESA). This post gives more details about a Phase I ESA, First of all, why “Phase I”? The answer is that there are also Phase II and Phase III ESAs. Phase I does not involve any sampling or site remediation. In a Phase II ESA, based on recommendations in the Phase I ESA report, soil, groundwater, and/or building materials are sampled and analyzed for various contaminants. In a Phase III ESA, based on recommendations in the Phase II ESA report, the site is remediated and follow-up monitoring is conducted. A Phase I ESA is conducted within the scope and limitations of the American Society for Testing and Materials’ (ASTM) designation E 1527-13. (EPA regulations also allow ASTM E 1527-05 to be used.) This assessment includes a review of federal and state environmental records and...

The main difference between an environmental audit and a Phase I Environmental Site Assessment (ESA) is that “environmental audit” is a more generic term that may cover a wide variety of issues while the Phase I ESA is strictly defined by the American Society for Testing and Materials (ASTM) so that it complies with the “All Appropriate Inquiries Rule” codified by EPA. Environmental audits are intended to determine whether or not a company or site is in compliance with applicable environmental rules and determine how well a company is managing issues related to compliance. Such audits may be either “multimedia” (identifying and auditing all environmental media, such as air, water, waste, etc.) or “programmatic” (limited to specific pre-identified regulatory areas, such as air). Some companies seek to obtain certification by an independent certification body by conforming to a voluntary international standard for environmental management systems (EMS) known as ISO 14001. (ISO...