Tiered Permitting Unit Closure Cost Updates

Be sure that you have updated and documented your closure cost estimates this year to reflect inflationary changes to the costs, as is required annually by the Tiered Permitting regulation.

Stormwater Sampling

Stormwater Sampling

If you are permitted under the California Stormwater General Permit, don’t forget to collect your samples over two rain events this rainy season.

CDMS can provide sampling kits to make sampling easy.  Contact one of our offices to find out more.

EPA Toxic Release Inventory (TRI) Report

EPA Toxic Release Inventory (TRI) Report – Form R  – Due July 1, 2011

The Form R report is required if any of the over 600  listed chemicals or substances are used as raw material, or as an ingredient in a material, over the reporting threshold for that chemical.

Common and often overlooked reportable materials include:

  • Lead
  • Metals including Copper, Chrome, Nickel, Zinc (stainless steel includes several reportable materials)
  • Nitric Acid
  • Sulfuric Acid

The annual public burden related to Form R reporting, as stated by the EPA, is estimated to average 29.6 hours per response for non-PBT chemicals and 51.3 hours per response for PBT chemicals.

The penalties for failing to submit this report on time are be significant, it is rare that non filers are not assessed a fine.  The EPA does have some provisions for self-disclosure of non compliance in which fines can be eliminated provided certain conditions are met.

For more information or to request a quote go to: http://www.cdms.com/our-services/hazardous-material-regulatory-support/reporting-plans/tri-form-r-reports/

CDMS can assist with the reporting and self-disclosure.

Waste Minimization (SB14) Programs

Every 4 years, qualifying facilities must prepare a new minimization plan and submit the Summary Progress Report (SPR).

Qualifying facilities include those that generated more than 13.2 tons of hazardous waste in 2010.  Wastes that are considered are both RCRA and non-RCRA waste, and are generated on site (even if the generated waste is then treated and/or not manifested).  A common mistake is to not include hazardous waste water that is treated on site and discharged to the sewer, as this waste water does qualify as hazardous waste generated.

For more information go to http://www.cdms.com/our-services/hazardous-material-regulatory-support/reporting-plans/waste-minimization-plans/

If you need assistance determining if you are required to address Waste Minimization requirements, or to learn how CDMS can address the requirements for you, please contact one of our offices.