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What is a site assessment and what is the difference between a site assessment and a site investigation?
The first step of the site assessment process is known as a preliminary assessment (PA). This assessment gathers historical and other readily available information on site conditions and surroundings to evaluate whether the site poses a potential threat to human health and the environment and/or whether further investigation is needed…
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Why hasn’t the Norwood Landfill Site been identified as a Superfund Site? Two nearby landfills, Folcroft and Clearview, which were established and in use at the same time as Norwood Landfill and Dump have both been designated as Superfund sites.
EPA is still conducting its investigation of the Norwood Landfill Site to determine if it should be placed on the National Priorities List (NPL), or Superfund List. Thus far, the data collected has not demonstrated that the site warrants placement on the NPL. Both the Folcroft and Clearview Landfills went…
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Why did EPA wait so long to begin its investigation of the Norwood Landfill and Old Norwood Dump?
In the months leading up to the preliminary assessment, EPA gathered information on the property to determine whether a site investigation under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was warranted. EPA determined to proceed with an investigation and EPA began procuring contractor services to conduct the preliminary…
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What is the key question EPA tries to answer through a site investigation?
Findings of the site investigation determine what hazardous substances may be present, whether they may be released to the environment, and any potential threat to human health. Information about the site that is collected in the preliminary assessment and site investigation phase helps EPA to evaluate the risks posed by…
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What changes did EPA finalize to the SPCC Rule in December 2006?
The revised rule modifies requirements for facilities with smaller oil storage capacity and specific types of oil-filled operating equipment. If a facility has 10,000 gallons or less in aggregate aboveground oil storage capacity and the facility meets the oil discharge history criteria, then an owner/operator of a facility may prepare…
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SPCC change in ownership
If there is a change in ownership at a facility, can the facility operate under the same SPCC Plan without the certification from a professional engineer (PE)? If no change in procedures has been made, it may still be feasible to operate under the existing SPCC Plan. The information in…
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Liability of oil retailers at SPCC regulated farm
If a farm is out of compliance of Spill Prevention, Control, and Countermeasure (SPCC) regulations and is checked by EPA and/or has a spill, is the retailer that filled the tank liable? No, EPA considers the oil tank owner responsible for lack of compliance.
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PE certifying a technical amendment
Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) must certify all technical amendments to an existing SPCC Plan (§112.5(c)). When certifying a technical change to an existing SPCC Plan, does the PE have to inspect and certify the entire Plan or only the amended…
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Products authorized for use on oil discharges
Does EPA maintain a list of products that are authorized for use on oil discharges? If so, how can a manufacturer have their product included on the list? Section 311(d)(2)(G) of the Clean Water Act (CWA) directs EPA to prepare a schedule of dispersants, other chemicals, and oil spill mitigating…
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Is a PE required to review an SPCC Plan if it has not changed?
Under the 2002 regulations, is a PE required to review the SPCC Plans at the end of a 5-year SPCC Plan cycle if no changes have occurred at the facilities? No. It is the responsibility of the owner or operator to document the completion of a review and decide whether…
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PE certifying an SPCC plan in a different state
Except as provided in 40 CFR §112.6 for qualified facilities, a licensed Professional Engineer (PE) must review and certify an SPCC Plan for it to be effective to satisfy the requirements of Part 112 (§112.3(d)). When reviewing and certifying a facility’s SPCC Plan, must the PE be licensed in the…
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How did EPA amend the requirements for animal fats and vegetable oils in 2006?
In December 2006, EPA removed the following SPCC requirements for the following specific types of animal fat and vegetable oil facilities: Requirements for onshore oil production facilities (Section 112.13) Requirements for onshore oil drilling and workover facilities (Section 112.14) Requirements for offshore oil drilling, production, or workover facilities (Section 112.15)…
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Rainwater in containment system of SPCC regulated farm
What do I do with rainwater that accumulates in my containment system for a farm regulated by the Spill Prevention, Control, and Countermeasure (SPCC) rule? Check the rainwater for any oil, and if no oil is present, this can be released. If there is oil in the water, this water…
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