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Major Environmental Regulations and How They Affect Everyday Business Operations

Major Environmental Regulations and How They Affect Everyday Business Operations. By Robert J. Gallagher Gallagher Environmental Consulting Group r.gallagher@cox.net Tel 401-423-2409 and Alvin J. Snyder, PE, LSP Environmental Resource Associates, Inc.

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Major Environmental Regulations and How They Affect Everyday Business Operations

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  1. Major Environmental Regulations and How They Affect Everyday Business Operations By Robert J. Gallagher Gallagher Environmental Consulting Group r.gallagher@cox.net Tel 401-423-2409 and Alvin J. Snyder, PE, LSP Environmental Resource Associates, Inc. asnyder@eraengineers.com Tel. 401-349-5252

  2. Contents EPCRA Clean Water Act SPCC RCRA Hazardous Waste Clean Air Act – NESHAPs Remediation / Site Surveys / etc.

  3. EPCRA 301–303 Emergency Planning 304 Releases / Spill Reporting 311-312 MSDS List / Tier 2 Reporting 313 Toxic Release Inventory (TRI)

  4. EPCRA 301–303 Emergency Planning Any facility that has any of the listed chemicals at or above the threshold planning quantity must notify the SERC / LEPC within 60 days after receiving the 1st shipment or producing the substance on-site. 304 Emergency Release Notification Report if released a reportable quantity within a 24 hour period. Use May 2010 List of Lists.

  5. EPCRA 311–312 MSDS List /Tier 2 Reporting Thresholds TPQ or 500# for Section 302 Chemicals 10,000# for all chemicals with an MSDS Deminimis at 1% and 0.1% Submit MSDS List w/in 90 days of receiving on-site Key Dates March 1st - Submit Tier 2 each year for previous year

  6. EPCRA 311–312 MSDS List /Tier 2 Reporting Requirements New RI requirements for transporter routes and contact information. Also, can attach photos, site drawings, MSDS List and plans. Include counties for fire department. Contacts Len Wallace, USEPA – 617-918-1835 Wallace.len@epa.gov Jim Larisa, RIDLT – 401-462-8559 www.riserc.com

  7. EPCRA 313 Toxic Release Inventory (TRI) Thresholds SIC Codes 20-39; and ≥10 full time employees or equivalent; and Mfr or Process 25,000# / Otherwise Use 10,000# Pbts at 10# and 100# / Dioxins at 0.1 gram Key Dates July 1st for previous year to EPA/RI

  8. EPCRA 313 Toxic Release Inventory (TRI) Requirements Complete a mass balance of regulated chemicals above the threshold Place the numbers from the mass balance into the TRIMeWeb electronic reporting software Suggested to create a facility process flow diagram Contacts Dwight Peavey, USEPA– 617-918-1829 Peavey.dwight@epa.gov http://www.epa.gov/tri/report/software/trimeweb/index.htm Karen Slattery, RIDEM – 222-2808 ext. 7030

  9. CLEAN WATER ACT Storm Water Pollution Prevention Plans (SWPPP) Thresholds Point Source of Storm Water to Waters of the United States Notice of Termination No Exposure Key Dates MSGP RIR500000, Expires April 30, 2011

  10. CLEAN WATER ACT Storm Water Pollution Prevention Plans (SWPPP) Requirements NOI / SWPPP Quarterly Visual Inspection Quarterly Benchmark Samples Submittal of Benchmark Results Monthly and Annual Inspections SWPPP Team and Meetings Annual Training Contacts Margarita Chatterton, RIDEM, 222-2234 ext. 7605 Eric Beck, RIDEM, 222-4700 ext. 7202

  11. CLEAN WATER ACT Spill Prevention, Control and Countermeasure Plans (SPCC) Thresholds 1,320 Gallons of Aboveground Oil Storage Capacity From Containers of ≥55 Gallons In addition to facilities that are excluded from the SPCC rule because they are not subject to EPA’s jurisdiction, §112.1(d) exempts: Any facility where the storage capacity of completely buried storage tanks and associated piping and equipment does not exceed 42,000 gallons and the aggregate aboveground storage capacity does not exceed 1,320 gallons; Any container with a storage capacity less than 55 gallons at a facility, whether or not subject to the requirements of the SPCC rule; and Any facility or part thereof used exclusively for wastewater treatment.

  12. CLEAN WATER ACT Spill Prevention, Control and Countermeasure Plans (SPCC) Key Dates On October 7, 2010, EPA maintained the November 10, 2010, compliance date for drilling, production or workover facilities that are offshore or that have an offshore component, and for onshore facilities required to have and submit Facility Response Plans (FRPs). However, EPA extended the compliance date an additional year for all other facilities to amend or develop a SPCC Plan until November 10, 2011. The amendments do not remove the regulatory requirement for owners or operators of facilities in operation before August 16, 2002, to maintain and continue implementing an SPCC Plan in accordance with the SPCC regulations then in effect.

  13. CLEAN WATER ACT Spill Prevention, Control and Countermeasure Plans (SPCC) Requirements Prepare SPCC Plan Annual training Spill Meetings Monthly and annual inspections Integrity Testing RI Oil Pollution Control Regulations Contacts EPA Oil Hotline, (800) 424-9346 or (703) 412-9810

  14. RCRA HAZARDOUS WASTE Thresholds 2200#/month Actual LQG All generators in RI are considered LQG Biennial Report Only for Actual LQG Contingency Plans for All Generators Key Dates June 7, 2010 Revision

  15. RCRA HAZARDOUS WASTE Requirements Hazardous Waste Contingency Plan Characterization TCLPs, etc. Authorized Manifest Signer’s Form 8700-12 Form Updates Labels, Markings Satellite and Storage Areas HW Job Descriptions and Titles Weekly Inspections Annual Training Contacts Mark Dennen, RIDEM 222-2797 ext. 7112

  16. CLEAN AIR ACT NESHAPS: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources 40 CFR 63 Subpart HHHHHH (6H) Thresholds Paint Stripping with MeCl >1 ton Motor Vehicle and Mobile Equipment Surface Coating Operations Miscellaneous Surface Coating Operations – NAICS Codes 5 Target Metals : Cr, Mn, Ni, Cd, Pb Metals 1% or 0.1% for Carcinogens

  17. CLEAN AIR ACT NESHAPS: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources 40 CFR 63 Subpart HHHHHH (6H) Key Dates Existing Source if Commenced Construction Prior to 9/17/2007 Initial Notification – 1/11/2010 Notification of Compliance Status – 3/2011 Compliance Date – 1/2011 FR/Vol.73,No.6/Wednesday,January 9, 2008

  18. CLEAN AIR ACT NESHAPS: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources 40 CFR 63 Subpart HHHHHH (6H) Requirements Must Petition EPA to be Exempted for Coatings Implementation Plan if >1 ton MeCl Booth Filters 98% Efficiency HVLP Gun Contacts Susan Lancey, USEPA 617-918-1656 Gina Friedman, RIDEM 222-2808 Ext. 7016

  19. CLEAN AIR ACT NESHAPS: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources 40 CFR 63 Subpart HHHHHH (6H) Websites: http://www.epa.gov/ttn/atw/area/arearules.html http://www.epa.gov/ttn/atw/mactfnlalph.html

  20. CLEAN AIR ACT NESHAPS: Reciprocating Internal Combustion Engines (RICE) 40 CFR 63 Subpart ZZZZ (4Z) Thresholds Check Applicability Flowchart Existing v New Sources Spark v. Compression Ignition <100 Hp, ≤300, >300 Hp, ≤500 Hp , >500 Hp Emergency v. Non emergency Offroad v Onroad Vehicles Stationary v. Mobile Sources

  21. CLEAN AIR ACT NESHAPS: Reciprocating Internal Combustion Engines (RICE) 40 CFR 63 Subpart ZZZZ (4Z) Key Dates Final Rule Effective on October 19, 2010 Existing Source Compliance No Later than May 3, 2013 or October 19, 2013 Depending On Category

  22. CLEAN AIR ACT NESHAPS: ReciprocatingInternal Combustion Engines (RICE) 40 CFR 63 Subpart ZZZZ (4Z) Requirements See RICE Summary Tables Log hours Crankcase Cleaning Maintenance Stack Testing

  23. CLEAN AIR ACT NESHAPS: Reciprocating Internal Combustion Engines (RICE) 40 CFR 63 Subpart ZZZZ (4Z) Contacts Susan Lancey, USEPA 617-918-1656 Gina Friedman, RIDEM 222-2808 Ext. 7016

  24. CLEAN AIR ACT NESHAPS: Reciprocating Internal Combustion Engines (RICE) 40 CFR 63 Subpart ZZZZ (4Z) Websites http://www.epa.gov/ttn/atw/rice/ricepg.html http://www.epa.gov/ttn/atw/area/arearules.html http://www.epa.gov/ttn/atw/mactfnlalph.html

  25. Regulating Environmental Risk Types of Risk • Lifestyle choices • Naturally occurring • Man-made Contaminants can be found in air, water or soil. Can originate from yours or neighboring properties.

  26. This is a Risk I Enjoy Taking...

  27. Lifestyle Risks in Our Environment Increasing chance of death by 1 in 1 million • Traveling 6 min. by canoe (accident) • Smoking 1.4 cigarettes (cancer, disease) • Drink ½ liter of wine (liver) • Eating 100 charcoal broiled steaks (cancer) • Living 2 days in Boston or New York (air) • Living 2 months in stone/brick house (radiation) • Flying 1000 miles by jet (accident) • One chest x-ray (cancer from radiation) Regulations limit risk to 1/100,000 or 1/MM

  28. Clean Air Act (CAA) Rules • Discharges to air by stack or area ventilation • Opacity, odor, any emission but water vapor • RI Minor permit – 10 lb/hr tot., 100 lb/d tot., 25 tn/yr HAP, 1 - 10 MMbtu/hr fuel burning, emit > min. Air Toxics quantities, particulates for 100 lb proc. wt. • RI Major permit – 50 tn/yr NOx or VOC, 100 tn/yr others • MA – LPA for 1 to 10 tn/yr single contam., 5-40 MMbtu/hr fuels, 3 MMbtu/hr used oil, CPA for >10 tn/yr, fuel usage • NESHAP area rules, reporting, controls, lengthy permitting Look For • Stacks, process vents, boilers, incinerators, generators, vats, painting, coating, scrubbers • Any vapors, gas, dust, mist or smoke, opacity, odor • Check Industrial Source Codes for NESHAP rules

  29. Solution for a Workplace Nightmare Rubber Coating of Fabric (gas masks) • Poor ventilation, solvent vapors in building • No removal or recovery of vapors • Over 3,500 tons per year discharged to air Solution • New ventilation and vapor capture system • Design activated carbon recovery system • Steam regenerable, recover solvents • Reduce to <300 tons per year • No vapors in building

  30. Gas Mask Solvent Vapor Solution

  31. Subsurface Contamination Comprehensive Emergency Response, Compensation and Liability Act (CERCLA) Rule • Chemical releases to environment • Notification timelines, testing, reporting • Reportable limits, exclusions vary by state • State regulations (RI Remed. Reg., MA MCP) • Hire professional (LSP in MA, PE in RI) Look for • Buried drums, stains, seepage pits, dry wells • Dumps, spillage or disposal, leaking tanks • Non domestic waste to septic system

  32. Major Oil Spill to River - before

  33. Major Oil Spill to River - after

  34. Gasoline Remediation Problem Gas stations since 1920 Contaminated soil 12’ gas on groundwater Solution 4900 tons soil removed Remove gas on water Less than ¼” gas now

  35. A Hidden Risk Naturally occurring arsenic • Quite prevalent as background • Handled differently by state regs Lead/arsenic from fruit orchards • Lead arsenate pesticide spray used in past • Top layer of soil generally contaminated Solution • Remove top layer • Conduct ESA before purchase or sale

  36. Identifying an Old Orchard Area 2007 Aerial 1951 Aerial Resources: Google Earth - http://earth.google.com/ RIGIS - http://www.edc.uri.edu/rigis/ or http://www.edc.uri.edu/atlas/

  37. Regulatory Overlap for Remedial Waste Is it Remediation, MCP, RCRA, TSCA or Solid Waste? • What’s the source? History of site, tank, process, waste, transformer, drum, groundwater • Where is it? Container, groundwater, soil, tank, NAPL • What’s in it? Characterization, PCB, ACM, etc. • Is it hazardous? Listed, hazardous characteristics, “mixture” rule, “derived from” rule • When is it generated? Containerized or moved offsite • Affects disposal! Haz.-RCRA, PCB-TSCA, Nonhaz. & no release-SW, Nonhaz. & released-remedial waste • High penalties for noncompliance or misinterpretation!

  38. Emerging Concerns Potential regulation of compounds • Endocrine disruptors – water, sewers • Pharmaceuticals – discard, not degraded • Nanomaterials – Ag, carbon, etc. in water/air • CO2, refrigerants – Cap & trade air emissions Issues • 46 million have drugs in drink. water - EPA • Health effects, persistence, aquatic mutations, bacterial resistance? • Pass through POTW untreated • New requirements, pretreatment methods

  39. Questions? Robert J. Gallagher Gallagher Environmental Consulting Group r.gallagher@cox.net Tel. 401-423-2409 Alvin J. Snyder, PE, LSP Environmental Resource Associates, Inc. asnyder@eraengineers.com Tel. 401-349-5252

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