The Board should include the procedures it expects facilities to implement in order to ''minimize'' spills. For instance, the Board could include using spouts on larger containers, maintaining covers on containers when not in use, etc. 5. The training requirement is vague. The Board should provide more specific requirements as well as a method of validation, i.e. testing or records of employee training in handling and applying materials. The proposal requires owners or operators of a facility to apply for a permit in accordance with Chapter 127.
Facilities vary in size from one bay to very large operations.
Since the Board anticipates using general permits for these facilities, we recommend the Board specify the amount of the permit fees in its final-form regulation. The Board should also explain whether the same application fee would be applied to all sizes of facilities. We further recommend that the Board demonstrate that the permit fee is consistent with the cost of permitting and compliance activity of the Department. The proposal does not specify the manner of enforcement or the penalties for failing to meet its provisions. We recommend the Board address enforcement and penalties in the final-form regulation through a reference to the applicable provision in existing regulations, or through the addition of specific provisions to this subchapter.