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  • Will EPA sample the Glenolden Laboratory property?

    The former Glenolden Laboratory property located on South Avenue is a separate site. The previous owners conducted a voluntary cleanup pursuant to the Pennsylvania Department of Environmental Protection’s (PADEP) Environmental Cleanup Program, known as Act 2. Concerns regarding remedial actions conducted under Act 2 should be directed to PADEP as…

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  • CFAT Impacts on EPCRA and RMP

    The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act section…

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  • EPCRA Reporting Mechanisms for Protecting Sensitive Business Information

    Does EPCRA provide any mechanisms for facilities that must submit Tier II inventory information to protect sensitive business information? Trade secret and confidential location information (CLI) are two separate confidentiality provisions under EPCRA. Trade secret claims made under EPCRA Sections 303, 311, 312, or 313 allow facilities to claim the…

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  • What questions was EPA trying to find answers to during its first round of sampling at the Norwood Landfill site?

    The main question that EPA seeks to answer is whether the identified waste areas warrant consideration for placement of the Site on the National Priorities List (NPL) or Superfund List. In the first round of sampling, EPA collected surface soil samples (0-2 feet) from the landfill property, and surface water…

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  • What does it mean when EPA finds contamination that “exceeds screening levels?”

    Screening levels are not the same as cleanup or action levels. An exceedance of a screening level indicates the need for additional evaluation, potentially including a site-specific risk assessment.

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  • How do you know you are not missing some areas that might be contaminated?

    EPA uses all credible information available, including community input, regarding the boundaries and geographic areas of waste that may have been deposited or where contaminated soil may have been placed. The team selects its sampling locations based on those areas and consults historic aerial images that help depict those boundaries.

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  • If EPA finds any contamination associated with the Norwood Landfill site that “exceeds” what is considered safe, will EPA clean up that contamination - even if the Agency cannot find any “pathways” for that contamination to reach humans or sensitive environments?

    If the sampling data shows an exceedance of a screening level, EPA will consult with the site Toxicologist and the Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a human health risk screening assessment to determine any potential threat to human health. EPA will also consult with the…

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  • Are landfills covered under Title III of SARA since they are covered by RCRA?

    Yes, landfills are subject to certain Title III requirements. Subtitle A of Title III is intended to identify facilities which present a potential hazard for a chemical emergency and to provide a process for local emergency planning committees to engage with such facilities in determining the significance of the release…

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  • Are mobile boosters eligible for the transportation exemption?

    An oil company owns many wells on an oil field. Each well is on its own plot of land. These plots are not adjacent or contiguous and, therefore, each well is its own facility. When operating these wells, it is sometimes necessary to inject air or gas into the well…

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  • Pipeline tanks and the transportation exemption in Title III

    An oil corporation's pipeline facility contains three kinds of tanks. One type is a breakout tank used to receive and store hazardous liquids transported by a pipeline for reinjection and continued transportation by the corporation's pipeline. Another type is used to receive and store hazardous liquid for delivery to pipelines…

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  • Will EPA conduct sampling in local parks in the Norwood community?

    EPA will sample Norwood Park because of its close proximity to the Old Norwood Dump and Norwood Landfill. There is no current information that would warrant sampling in other parks.

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  • Will EPA sample the Norwood school?

    EPA continues to work closely with the Interboro School District, but there are no plans to sample the Norwood school at this time. For site investigations, sampling activities must be based upon the identification of a potential source of contamination. Based upon research and historic images, EPA has not seen…

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  • Chemicals in facility pipelines and the EPCRA transportation exemption

    Section 327 of the Emergency Planning and Community Right-to-Know Act (EPCRA) exempts from any Title III reporting requirement (other than the §304 notification obligation) substances or chemicals in transportation and/or being stored incident to transportation. In a final rule promulgated April 22, 1987 ( 52 FR 13378 ), the Agency…

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  • Can members of SERCs and LEPCs be sued?

    What are the liabilities of members of a state emergency response commission and a local emergency planning committee, if an incident is not handled properly despite following procedures developed and reviewed by those commission and committee members? Can the individual members be sued and held liable? The general rule is…

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  • Civil action attorney and court fees, awarding of fines

    A waste treatment facility has a release of chlorine above the reportable quantity. The facility owner or operator did not make initial notification of the release as required under EPCRA Section 304. In addition, the facility owner or operator also refused to submit a written follow-up regarding the release of…

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