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  • Why collect the rainwater and snowmelt around the derailment site?

    Until excavation work and confirmatory sampling are completed, any wastewater collected from the derailment site is considered a “listed hazardous waste” because it may have come into contact with vinyl chloride or other hazardous contaminants from the derailment. Even though the soil contamination has been removed, our double-check work is…

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  • What has changed?

    For the past several months as the collected wastewater has gone through the system, sample results have shown that the wastewater meets the standards set for vinyl chloride and other derailment-caused contaminants without treatment, meaning it can be disposed of as non-hazardous waste. Testing of the collected wastewater will continue…

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  • Leasing out empty oil storage containers.

    A facility leases out empty stationary tanks to other facilities that use the tanks to store oil (e.g., gasoline). The stationary tanks are empty while at the initial facility and eventually leased to other customers to be reused for oil storage. Is the facility that leases out the empty tanks…

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  • When is a mobile refueler subject to SPCC requirements?

    According to a 1971 Memorandum of Understanding between the Department of Transportation (DOT) and the Environmental Protection Agency, EPA regulates non-transportation-related facilities and DOT regulates transportation-related facilities: • Mobile refuelers that operate solely within the confines of a non-transportation-related facility subject to the SPCC rule must comply with the general…

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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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  • Does a product or substance have to create a sheen to be subject to SPCC?

    The SPCC general applicability in 40 CFR §112.1(b) refers to a discharge of oil in quantities that may be harmful, as described in Part 110. Part 110 is often referred to as the sheen rule. Does a product or substance have to create a sheen to be subject to SPCC…

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  • Who is regulated by the SPCC Rule?

    Before a facility is subject to the SPCC Rule, it must meet three criteria: 1) it must be non-transportation-related; 2) it must have an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and 3) there must be a reasonable expectation…

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  • Oil-filled equipment capacity less than 55 gallons

    Do the revised SPCC requirements apply to electrical substations that have transformers larger than 55 gallons and a total storage of 1,320 gallons? An owner/operator must prepare an SPCC Plan if the facility, due to its location could reasonable be expected to discharge oil into or upon a navigable water…

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  • Are all milk farms and milk producers exempt from the SPCC Rule?

    The exemption is for all milk and milk product containers, piping and appurtenances, but does not exempt containers that store other oils, such as petroleum oil at dairies, milk producers and milk product manufacturing facilities. These facilities will not have to account for, or address the exempt milk and milk…

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  • What milk and milk products are covered by the Milk and Milk Product Containers, Associated Piping and Appurtenances Exemption?

    The exemption will cover all containers, piping and appurtenances of milk and milk products. For example, milk products include cheeses, yogurts and ice cream. Additionally, transfers and milk handling associated with these containers and appurtenances are exempt from the SPCC requirements.

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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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