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  • What is the status of the cleanup work in the streams?

    There is still more work to be done in Leslie and Sulphur Runs. EPA and Ohio EPA are reviewing the Norfolk Southern sediment mitigation workplan. More cleaning will likely start before April and is expected to continue through July.

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  • Program Level 2 and 3 compliance audits

    Facilities with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). How does a facility submit its compliance audit to EPA? Facilities are not required to submit three year compliance audits to EPA; however, facilities should maintain records…

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  • Maintenance requirements for leased tanks

    I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do? As part of your contract with the supplier, it would be helpful to gain…

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  • When must an incident investigation be initiated for Program 2 and 3 processes?

    When must a stationary source owner or operator begin conducting incident investigations as required under 40 CFR §68.60 (for Program 2 processes) or 40 CFR §68.81 (for Program 3 processes)? For both Program 2 and Program 3 processes, the incident investigation must be initiated as soon as possible, but not…

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  • Breaking a process into separate units to comply with prevention program requirements

    Do I have to do my hazard review, process hazard analysis, or other prevention activity on the whole process or can I break it into separate units? Once you have determined that you have a covered process, you can divide the covered process any way you want to implement the…

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  • Applicability of compliance audit provisions to emergency response programs

    I have a Program 2 covered process and a Program 3 covered process at my stationary source, and I am required to conduct compliance audits certifying that I have evaluated compliance with my prevention program requirements at least every three years (40 CFR Sections 68.58 and 68.79). Do these provisions…

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  • What does "materials of construction" mean?

    What does “materials of construction” apply to and how do I find this information? You must document the materials of construction for all process equipment in a covered process. For example, you need to know the materials of construction for process vessels, storage vessels, piping, hoses, valves, and flanges. Equipment…

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  • Why treat the collected water?

    Water collected at the site has the potential to have come into contact with vinyl chloride and other contaminants from the derailment. After the collected wastewater is treated it is then tested, and if it is not hazardous, can be disposed of as non-hazardous waste.

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  • When will water no longer need to be collected to be returned to Sulphur Run?

    We anticipate in the next two-to-four weeks, this work will start in sections of the derailment site. Soil analysis during the double-check phase is needed to remove the hazardous waste listing from the collected wastewater. Data are showing that water flowing over or through sections of the derailment area do…

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