Question

As the Environmental Health and Safety Director for a plating facility, you note that the facility has historically stored two 55-gallon plastic drums of chromic acid just outside the shop door on a wooden pallet. Prepare a memorandum to your boss outlining a summary of the congressional environmental acts and/or regulations that apply to storage and release reporting requirements for those drums. Include in your memorandum an outline or summary of the requirements should one or both of those drums release their entire contents, both from a reporting point of view and from a spill response point of view. If the company expects to respond internally to any spill, what must the company have in place? What regulation(s) requires this?

Answer 1

Environmental laws such as RCRA and SPCC rule guide the storage and spill response for hazardous materials like chromic acid. A spill requires immediate reporting and a well-structured internal spill response plan as per EPA and DOT regulations.

Step-by-step explanation:

As the Environmental Health and Safety Director, numerous congressional environmental acts and regulations apply to the storage of chromium acid at your facility. Particularly, the Resource Conservation and Recovery Act (RCRA) provides a framework for the management of hazardous waste, ensuring safe handling from creation to disposal. Hazardous waste recycling regulations, as part of this act, aim to minimize risks such as spills and contamination.

Should an incident occur, where one or both drums release their contents, immediate action is required under regulations such as the Spill Prevention, Control, and Countermeasure (SPCC) rule. This includes reporting to local authorities and potentially the Environmental Protection Agency's Toxic Release Inventory (TRI), depending on the substance and quantity released. It's also essential that your facility has a written response plan in place, satisfying secondary containment and clean-up requirements.

The company's spill response plan must encompass necessary procedures and resources for internal action, as mandated by the United States Environmental Protection Agency and the United States Department of Transportation hazardous materials regulations. This ensures timely containment and mitigation of releases to protect workers, the public, and the environment.