Environmental Compliance in the Real World: Tales from an Environmental Lawyer. Craig J. Pritzlaff. A little about myself…. B.S. Bioenvironmental Sciences, Texas A&M Worked with local, state, and federal environmental authorities J.D. Southern Methodist University
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Environmental Compliance in the Real World: Tales from an Environmental Lawyer
Craig J. Pritzlaff
Broadly defined under Clean Water Act/Oil Pollution Act of 1990 to include petroleum and non-petroleum oils (including vegetable oil).
Report RQ to NRC if reach navigable waters.
If facility subject to SPCC, must ALSO report to EPA.
Under OPA, reports must be made IMMEDIATELY upon knowledge of the discharge (40 CFR 110).
Under state law (Texas), obligation to report within 24 hours of the release (30 TAC Chapter 327).
CERCLA. Release of hazardous substance in excess of RQ to or from your site must be reported IMMEDIATELY to NRC. CERCLA excludes petroleum (40 CFR 302).
EPCRA. Releases of hazardous substances and extremely hazardous substances from your site must be reported IMMEDIATELY to SERC and LEPC (40 CFR 355).
Oil (any kind) into water...VISIBLE SHEEN.
Petroleum products onto soils or pavement….25 gallons.
Crude oil onto soils or pavement….210 gallons.
Crude oil into water…VISIBLE SHEEN.
Industrial or Other Substances into water….100 pounds.
Hazardous Substance (land, air or water)…..100-5000 gallons, depending on the substance.
Fed: 40CFR302 (CERCLA), 40CFR172.101 Appendix A (CERCLA)
State: 30TAC327 (incorporates 40CFR302)
Does immediately under CERCLA, EPCRA and OPA mean 24 hours?
Craig J. Pritzlaff
Curran Tomko Tarski LLP
2001 Bryan Street, Suite 2000
Dallas, Texas 75201
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