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August 3rd, 2016

Inaugural Liquid Hazardous Waste Annual Reporting Form due for Cook County on September 1st

Last year, Cook County passed the Liquid Hazardous Waste Ordinance which requires cook county sealfacilities in suburban Cook County to report their annual liquid hazardous waste generation and submit a corresponding fee.  The inaugural Liquid Hazardous Waste Annual report for the period January 1, 2016 and June 30, 2016 is due September 1, 2016.

Any facilities with less than 420 gallons of liquid hazardous waste in this time period still need to complete the form by the deadline but no fee will be assessed.  All facilities with greater than 420 gallons of liquid hazardous waste must include a $0.02/gallon fee with their report.

All liquid hazardous waste generated from July 1, 2016 – December 31, 2016 will be reported on a separate form due March 1, 2017.

For all liquid hazardous waste generated each year after 2016, the reporting period is January – December, and the annual report and fee is due March 1st of the following year.

Failure to submit this form on time may result in fines up to $10,000 for each offense.

If you need assistance completing this form, contact Gabriel’s Water Department at 773-486-2123 or waterdept[at]gabenv.com, or Steve Sawyer, CHMM, at 773-486-2123 or ssawyer[at]gabenv.com.

May 25th, 2016

EPA to update Hazardous Waste Generator regulations

U.S. EPA is currently reviewing comments to its proposed rule to update Hazardous Waste Generator regulations.  Most of these epa_logo2regulations are over 30 years old from when the Resource Conservation and Recovery Act (RCRA) hazardous waste amendments originally became law in 1984.  Today there are an estimated 353,300 – 544,300 facilities that generate hazardous waste across the U.S.  14,300 are classified as Large-Quantity Generators (LQGs) which generate 99% of the total hazardous waste produced each year.

The proposed rule includes provisions to:

  • Reorganize hazardous waste generator rules to make them easier to understand
  • Clarify provisions to improve compliance
  • Provide greater flexibility to generators
  • Strengthen environmental protection by closing important gaps where necessary

EPA states that these updated regulations will provide both economic and environmental benefits.  They anticipate this rulemaking will be finalized in 2016 and will be effective at the federal level six months after promulgation.

More information and specifics can be found on the EPA’s Hazardous Waste Generators webpage.

January 22nd, 2015

Innocent Vacant Lot? Or Contaminated Superfund Site?

Occasionally we get Phase I orders from developers or others interested in purchasing a vacant lot, and they wonder why they are spending money on the environmental assessment when there is barely anything to inspect. No building or structures. No visible signs of drums or fly dumping. Just a standard urban lot, waiting for development.

economy plating siteSometimes this innocent looking vacant lot can actually be masking an environmental problem. Take, for example, a vacant lot located on a busy stretch of Elston Avenue, just south of Fullerton. Nothing on this property indicates that there are any potential issues – just weeds and a chain link fence. A less-savvy investor may purchase the property for cash  without any environmental due diligence and think they’re getting a steal. What they’re actually getting is an EPA Superfund site.

The Economy Plating site was first cited in 2009 by the Chicago Department of Environment for its hazardous waste violations, and then referred to U.S. EPA when the owner could not conduct cleanup activities on his own. EPA found 195 drums and 12 chrome plating vats holding hazardous chemicals. Several containers were leaking and holes were found in the ceiling and walls of the basement. Markings indicated that the containers held potentially dangerous and harmful substances, such as chromic acid, hydrochoric acid, and methyl acetate.

EPA officials coordinated the removal, disposal and clean up of these hazardous materials, including the demolition of the building and excavation of impacted soil and groundwater. Their total cost for these clean-up activities and testing was over $800,000. economy plating drums

Analysis from the site after the cleanup was completed shows that the site is now clean to commercial standards, so a developer would be free to build any commercial or industrial structures on the site. Residential units or other sensitive uses (such as a day care or school) would not be advised, however, due to the former use of the site and any remaining contamination from the hazardous materials.

Without having done a Phase I on the property prior to purchasing the property, the developer may not know about any of these environmental concerns and land use restrictions. Furthermore, the new owner would also be responsible for any remaining contamination on the property or that migrated to neighboring sites, including the cost of any future testing, cleanup or lawsuits. Spending a little bit of money on a Phase I now could save this potential developer a lot of money and headaches in the future.