PWGC Facilities Newsletter -- Summer 2014 Edition
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Summer Newsletter

Facilities Edition

Our facilities newsletters are designed to help you stay up-to-date on ever-changing environmental rules, regulations, and other pertinent issues related to the Manufacturing, Chemical, and Production industries.

Moving Forward with E-Manifests

On February 7, 2014, the US EPA established rules for the e-manifest system. According to the EPA the Final Rule will authorize the use of electronic hazardous waste manifests that will become available when EPA establishes a new electronic hazardous waste manifest system (e-Manifest). The modification will provide waste handlers with the option to complete, sign, transmit, and store manifest information electronically. States that currently receive and collect paper manifest copies will receive copies of manifest data electronically from the system. Although the EPA has an effective rule date starting August 6, 2014, the use of the e-manifest will not be permissible until the EPA has finalized the IT system which is still not complete.

Many facilities have questions on how the e-manifest system will work. Questions and answers can be found at the following EPA web address:


Contact PWGC for additional information

Hurricane Season is Here:
A reminder for emergency preparedness

Predicting weather patterns and weather warning systems have improved dramatically over the last decades allowing us to better prepare for natural disasters. If your facility is subject to CAA (Section 112(r )(1)), a statutory and regulatory program designed to prevent chemical accidents and releases through a program of preparedness, response and prevention,  a Risk Management Plan (RMP) must be implemented.

Part of the RMP is an emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies should an accident occur.  Even if not required by law to have emergency preparedness all owners and operators of facilities which have hazardous materials on site should implement emergency response procedures which include potential natural disasters such as hurricanes.  Such programs can save lives, protect the environment and save businesses. 

Contact PWGC for assistance in preparing an emergency response plan.

Contact PWGC for additional information

EPA’s UST Final Regulations
Have Been Pushed Back to the Fall

The EPA’s Office of Underground Storage Tanks has proposed changes to the 1988 federal UST regulations in October 2011 and planned the final regulations to come out this summer 2014. The EPA is now expects to finalize regulations this fall 2014.  According to the EPA the compliance cost for the proposed rule is in excess of $200 million national wide. The EPA states the regulations would lead to an annual avoided remediation cost of $300 million to $750 million.   
When finalized, this rule will be the first major revision since 1988 and will include changes to operator training,  secondary containment, operations & maintenance, deferrals, internal lining, flow restrictors on vent lines, notification, compatibility, vapor & groundwater monitoring, and interstitial monitoring results.  
For more information, contact PWGC.

Contact PWGC for additional information
PWGC has provided this newsletter solely for informational purposes; we make no warranties or certifications for a specific matter. If you require further information on a subject of this newsletter, would like to discuss your particular circumstances or would like to provide comments, please feel free to contact us.
Copyright © 2014 P.W. Grosser Consulting, All rights reserved.

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