Top Five UST Compliance Violations

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) along with assistance from the U.S. Environmental Protection Agency (EPA) Office of Underground Storage Tanks (OUST) recently released a report titled UST Common Compliance Violations. This effort was done to help the regulated community better understand common areas for underground storage tank (UST) compliance violations.  By using this information, the regulated community can focus their efforts to allocate resources to improve compliance, and the data gathered by these groups could also impact how states conduct onsite UST inspections.

We can assume that because these occur with the greatest frequency, they are the most challenging to prevent, address and/or correct. Below are the top five UST compliance violations:

  • The number one most common violation is operator training; over 40% of all violations reported are associated with Class A, B or C Operator training.
  • The second most common violation is release detection for piping, where 98% of these violations were a failure to perform annual line testing or line leak detector testing.
  • Number three on the list was spill prevention where 94% of the violations were related to the spill devices not being cleaned or maintained.
  • The fourth most common violation was within the release detection – tank The main violation, at 97%, related to a failure to conduct monthly monitoring.
  • Finally, at number five, the compliance violation was financial responsibility. The two main failures were a failure to meet the financial responsibility requirements at 69% and a failure to provide financial responsibility at 31%.

Please visit ASTSWMO’s website for additional information from the original report.

Posted in Blog, Environmental Compliance, EPA News & Regulations, Louisiana, News

Reviewing History – The Walnut Creek Explosion

In November of 2004, the high-pressure fuel pipeline breach at Walnut Creek was one of the worst in California’s history. Many lives were changed forever, subsequently this event would go on to highlight the importance of managing encroachments and working with engineering and design firms in the early stages of projects. Doing so would have safely identified the error that caused the November 9, 2004 tragedy.

An excavator trenching for a water main owned by the East Bay Municipal Utilities District near downtown Walnut Creek punctured a 10-inch petroleum line that was assumed to be a few feet away. The resulting explosion cost five workers their lives as well as the destruction of a nearby home and even forced the evacuation of a school.

The follow-up investigation led to the discovery of a bend in the pipeline incorrectly marked due to the presence of an oak tree. No aboveground signs indicated a cause for concern or that the pipe did not run straight because the oak tree was removed in 2000. This accident is still remembered as a tragic example of the importance of communication and proper map detailing between engineering firms and pipeline companies. Companies now implement damage prevention programs and have technicians who are charged with responding to call notifications to make sure that an event like this never occurs again.

Contributed by Harrison Haley, Marketing Associate
Posted in Blog

New Found Facts about PFAS

Per- and polyfluoroalkyl substances (PFAS) are a group of contaminants on the Department of Defense’s (DoD) Emerging Contaminant Action List. This list is comprised of chemicals and materials that pose a perceived or real threat to the environment or human health. PFASs have crept their way onto the environmental scene due to the physical and chemical properties that allow them to be manufactured and used worldwide. The scientific community has begun to recognize and discover the dangers and risks involved with PFASs in the environment.

Researchers and scientists at the Interstate Technology and Regulatory Council (ITRC) recently developed six fact sheets to summarize the latest findings. They are as follows:

  1. Naming Conventions and Physical and Chemical Properties
  2. Regulations, Guidance, and Advisories
  3. History and Use
  4. Environmental Fate and Transport
  5. Site Characterization Tools, Sampling Techniques, and Laboratory Analytical Methods
  6. Remediation Technologies and Methods.

These fact sheets are to be used by state regulatory program personnel to further assist them in making informed and timely decisions regarding PFAS-impacted sites. This content is not only beneficial to regulatory programs but also to consultants and parties responsible for the release of these contaminants.

The ITRC PFAS team is currently working on the associated Technical and Regulatory Guidance Document to go along with these sheets, and an introductory document can be found here. For more information on PFAS, please visit our past article here.

Contributed by Harrison Haley, Marketing Associate
Posted in Blog, Company News, Environmental Compliance, Louisiana, News

Will We See You at the Southeast Brownfields Workshop?

The Southeast Brownfields Workshop will be held November 7 – 9 at the Georgia Tech Research Institute Conference Center in Atlanta, Georgia. Registration is available online.

The EPA Region 4 and the Georgia Brownfield Association will be hosting this event that will educate attendees about revitalization in their communities. Trey Hess, director of brownfields and economic development at PPM Consultants, will speak about “Getting Ready for Redevelopment” to more than 200 attendees. View the full agenda here.

PPM will also have a booth here, so make sure you stop by the exhibit hall and visit us.

For more information visit the Georgia Brownfield Association site, or contact Kelly Andrews (Kelly@HLStrategy.com) with any questions about the event.

Posted in Blog, Brownfields, Company News, Georgia, Louisiana, Mississippi, News

Join Us at the MMA Environmental & Safety Conference and Expo

Join PPM at the MMA Environmental & Safety Conference and Expo in Philadelphia, Mississippi, powered by the Mississippi Manufacturers Association.

The Expo will include a pre-conference MMA PAC Golf Tournament, along with topics including “How Does Industry Plan for Its Business Needs & Outlook for the Future Under the Trump Administration?”, “Alternative Energy & Incentivizing the Growing Demand”, and more.

The conference will be held at the Pearl River Resort on October 12 through 13. View full agenda of courses and activities here. Register online.

Posted in Blog, Company News, Louisiana, Mississippi, News

Ozone Deadlines: Is An Extension Needed?

With the October 1, 2017, statutory deadline fast approaching, a number of state agencies, city leaders and industry personnel are anxiously awaiting Environmental Protection Agency’s (EPA) initial area designations for the 2015 ozone National Ambient Air Quality Standard (NAAQS) of  70 parts per billion (ppb).  Given recent history, it is unlikely anyone will be surprised if the EPA fails to meet the October 1 statutory deadline; however, Scott Pruitt, administrator of the EPA, was quoted as saying, “We do not believe in regulation through litigation, and we take deadlines seriously. We also take the statute and the authority it gives us seriously.”  Even so, an extension of the October 1 deadline remains a possibility as the EPA stated, “The Administrator may still determine that an extension of time to complete designations is necessary, but is not making such a determination at this time.”

According to EPA data, as of June 2017, approximately 1/3 of the US population lived in areas classified as nonattainment for the 75 ppb 2008 ozone standard.  More than 240 counties are expected to violate the new 70 ppb standard.  Counties and areas classified as nonattainment can face significant challenges in the form of air permitting delays, restrictions on industry expansion within the area, as well as impacts to transportation planning.  These challenges commonly lead to reduced economic development in and around the nonattainment area in addition to greater EPA involvement and oversight in air permit permitting.

Although the 70 ppb ozone standard was finalized in 2015, the EPA has yet to finalize how implementation of the rule will be handled.  The EPA has stated that some of the guidance and rules from the 2008 standard remain applicable; however, there continues to be questions on nonattainment classification thresholds and how to address background ozone concentrations.

After nonattainment areas are designated, states will have up to 3 years to produce State Implementation Plans (SIPs), which outline measures to reduce emission levels to attain and/or maintain the NAAQS. SIPs must be codified through an EPA review and approval process which can also take years to complete. Finally, under the Clean Air Act (CAA), actual attainment of the standards is allowed to stretch over a 3-year to 20-year period, depending on the severity of the area’s pollution.

As with most of EPA’s actions this is another wait and see event, stay tuned…..

Rule History

  • December 17, 2014 – Ozone NAAQS Proposed Rule published in Federal Register (FR)
  • October 26, 2015 – Ozone NAAQS Final Rule published in FR
  • June 28, 2017 – Scott Pruitt announces 1 year extension (Oct 1, 2018) on initial area designations
  • August 2, 2017 – Scott Pruitt withdraws notice delaying initial area designations
  • October 1, 2017 – Statutory requirement date for initial area designations by EPA
Contributed by Isaac Smith, Environmental Compliance Manager
Posted in Alabama, Blog, Company News, Environmental Compliance, EPA News & Regulations, Louisiana, News

Trey Hess To Speak At The Community Development Event In Clarksdale, Mississippi

Trey Hess, director of brownfields and economic development at PPM Consultants, will speak at Federal Reserve of St. Louis’ “Delta Communities Workshop” on September 21 in Clarksdale, Mississippi.

This free event will explore how affordable housing development can break the cycle of poverty, catalyze change and generate economic development for communities and families in the Delta. There also will be two panels comprised of representatives from lenders who offer financing for single- and multifamily housing.

In his talk, Hess will discuss how one city’s liability will be transformed into an asset: an affordable housing development. This liability, which was the former Kuhn Memorial Hospital site, will become a brownfield redevelopment property that is scheduled for completion in 2018-2019.

Delta Communities will be held at The Bank on September 21. This event is free to attend, but pre-registration is required. For more information, please contact Faith Weekly at 502-568-9216 or faith.e.weekly@stls.frb.org.

Contributed by Harrison Haley, Marketing Associate
Posted in Blog, Company News, Louisiana, Mississippi, News

Join Us at the 2017 Southern Section AWMA Meeting September 20-22

 

The Air & Waste Management Association Southern Section’s Annual Meeting will be held September 20 – 22 at the Sheraton Music City Hotel in Nashville, Tennessee. Registration is available online.

Join PPM and approximately 250 attendees from all over the Southeast for networking and presentations on regulatory updates, new developments and more. The meeting’s theme is Managing Change: Developing Proactive Environmental Strategies. View the full meeting agenda here.

For more information visit the Air & Waste Management Southern Section site.

Posted in Alabama, Blog, Company News, Louisiana, Mississippi, News

Free Webinar: Incentivizing Brownfield Redevelopment

 

The Mississippi Economic Development Council (MEDC) will host a free webinar Tuesday, September 12th from 11:30 AM – 12:00 PM CDT.

Trey Hess, director of brownfields and economic development at PPM Consultants, will be presenting this webinar aimed at informing developers of Mississippi’s competitive redevelopment incentive. This incentive successfully entices private sector developers to cleanup and reuse brownfield sites.

Through the Mississippi Economic Redevelopment Act (§ 57-91-1), this incentive can positively impact future economic development opportunities in both rural and urban communities across Mississippi.

Join the free presentation and discussion here. For more information or assistance joining the webinar, contact Gwen Howard at ghoward@medc.ms or call at (601) 352-1909.

Contributed by Harrison Haley, Marketing Associate
Posted in Blog, Brownfields, Company News, Louisiana, Mississippi, News

PPM’s Charles Ray Talks with WXXV 25 News at Mississippi Municipal League Conference

Mississippi Municipal League Conference

Posted in Blog, Brownfields, Mississippi