2016_EHS Seminar_Portsmouth NH slides

Breakfast Seminar Series

Environmental, Health & Safety Regulatory Updates

IntroductionsNovember 1, 2016 Portsmouth, NH

Wayne E. Bates, PhD, PE, Principal Engineer

Firm Overview

Multi-disciplinary Consulting Firm Founded in 1911 Full Service Capabilities: 290 Person Staff Employee Owned 8 Offices in MA, CT, NH and NY

Geographic Coverage

Tighe & Bond Full Service Capabilities

Civil Engineering

Dams & LeveesGeotechnical Engineering

InfrastructureLand Use PlanningLow Impact DesignParking & CirculationSite Planning & Design

Transportation

Environmental ConsultingBrownfieldsDemolition & Asbestos/ Hazardous Materials

Environmental Permitting & Planning

Fuel StorageHealth & SafetyRegulatory Compliance

Site Assessment & Remediation

Wetlands and Ecological Services

Building Services Geotechnical Engineering

Electrical & Mechanical Engineering

LEED Green DesignOwners Project Manager

Structural Engineering

Technology 3D ModelingGIS

SustainabilityEnergy & Resource Conservation

LEED Green DesignLow Impact DesignRenewable Energy

Environmental EngineeringDrinking WaterSolid WasteStormwaterWastewater

About our Speakers?

Regulatory Experts Actively engaged in professional societies Track regulations Good reputation among regulators History of helping clients with regulatory

challenges Ability to assist in determining applicability

Challenges

Take a minute to write down 5 challenges you are facing or expect to face regarding compliance in the coming year

Breakfast Seminar Series

EH&S Regulatory Updates

November 1st Portsmouth, NH

David P. Horowitz, PE, CSP, Project Manager

Tanks

Agenda Regulatory Updates

Tanks Federal Perspective NHDES Nuts & Bolts

Hazardous Materials Toxic Release Inventory (TRI) Air Quality Hazardous Building Materials (HBM) Safety and Health

Regulatory Updates Tanks (Above ground)

Bad Tank News Port Arthur, TX

Explosion, fatality, injuries

Elk River - West Virginia Chemical leak, 300,000

w/o water Smith County, TX

PresenterPresentation NotesDifferent than the Kyoto protocol in that the allowances arent free.

Approximately generators 230 in 10-state region; 30 in MA, 15 in CT

RGGI is started in the absence of an acceptable national climate policy

Regulatory Updates Tanks (Above ground)

PresenterPresentation NotesDifferent than the Kyoto protocol in that the allowances arent free.

Approximately generators 230 in 10-state region; 30 in MA, 15 in CT

RGGI is started in the absence of an acceptable national climate policy

Regulatory Updates Tanks (Above ground)

PresenterPresentation NotesDifferent than the Kyoto protocol in that the allowances arent free.

Approximately generators 230 in 10-state region; 30 in MA, 15 in CT

RGGI is started in the absence of an acceptable national climate policy

Regulatory Updates Tanks (underground)

PresenterPresentation NotesDifferent than the Kyoto protocol in that the allowances arent free.

Approximately generators 230 in 10-state region; 30 in MA, 15 in CT

RGGI is started in the absence of an acceptable national climate policy

Regulatory Updates Tanks (underground)

PresenterPresentation NotesDifferent than the Kyoto protocol in that the allowances arent free.

Approximately generators 230 in 10-state region; 30 in MA, 15 in CT

RGGI is started in the absence of an acceptable national climate policy

Regulatory Updates Tanks (underground)

PresenterPresentation NotesDifferent than the Kyoto protocol in that the allowances arent free.

Approximately generators 230 in 10-state region; 30 in MA, 15 in CT

RGGI is started in the absence of an acceptable national climate policy

FAQs Tanks

What is Underground Storage Tank Operator Training? UST Operator Training is a federal requirement that was part of

the Energy Act of 2005

What facilities does the Operator Training Act apply to? Any underground storage facility Any tank having an individual capacity of greater than 110

gallons that stores a regulated substance

FAQs Tanks

What are kind of Operators are there and what are their primary responsibilities? Class A Class B Class C

Who needs to be Operator Trained at each facility? Every applicable UST facility owner is required to have a Class A,

B and C operator designated for each facility

By what date must facilities be in compliance with the Operator Training Act? By August 8, 2012 no facility can operate without designated

Class A, B and C operators who have been properly trained and certified.

FAQs Tanks

By what date must facilities be in compliance with the Operator Training Act? By August 8, 2012 no facility can operate without designated

Class A, B and C operators who have been properly trained and certified.

Where can Operators get certified? DES UST Operator Training Class for Class A and B operators. International Code Council (ICC)

Typical Deficiencies USTs Inspected (No Retail)

Deficiency % Identified

Maintenance 91%

Financial Assurance 84%

Sump Monitoring 66%

Registration 61%

Overfill Prevention 38%

Cathodic Protection 18%

Double Wall Piping Issues 12%

Shear Valve 11%

Extra Vents 6%

Top Things Regulators Look For

1. Managing sumps & spill buckets (USTs)

2. A/B/C Operator coverage (USTs)

3. Financial Assurance (USTs)

4. Inspection Frequency (ASTs) 5001 Gallon ASTs

Questions

Breakfast Seminar Series

EH&S Regulatory Updates

November 1 Portsmouth, NH

Timothy K. Kucab, CHMM, Project Compliance SpecialistDouglas Stellato, Project Compliance Specialist

Air Quality

Breakfast Seminar Series

Agenda RTAP Review Planning for 2017 Emergency Generators Siting and Noise Top 5

RTAP

Regulated Toxic Air Pollutants Env-A 1400

Above and beyond EPA Standards

Modeling new processes

Review Annually Memo to File

Very Specific Permit Conditions and ComplianceProvisions

Planning for 2017

Reporting Season Semi-Annual / Annual Compliance Reports (January) NESHAP/MACT Annual Updates (January, March) Annual Emissions Statements and Fee (April) Source Registration Reports (March, site specific) Greenhouse Gas Reporting (March/April)

Changes to MassDEP Reporting

So You Operate a Generator

New

Old

Emergency

Non-Emergency

Area Source

Major Source of HAP

Installation Date Generator Use

Facility HAP Emissions

Types of Requirements

Emergency Monitoring Recordkeeping Operating Limitations Fuel Requirements Emissions Limitations

Non-Emergency Controls Performance Tests Reporting Notifications

Emergency Engines Nuts and Bolts

Emergency engines may operate for 100 hr/yr for any combination of the following:

maintenance/testing; emergency demand response 50 hr/yr of the 100 hr/yr allocation can be used for:

non-emergency situations if no financial arrangement

State Requirements

Individual Permits General Permits Permit-by-Rule Certifications

NHDES General Permit

Internal combustion engines used to produce electricity through a generator or to produce mechanical power for fire pumps located at non-Title V facilities that:

Meet the permitting threshold applicability of Env-A 607 Are certified to meet USEPA emission levels for newer

compression ignition engines or newer spark ignition engines if applicable

Operate strictly within the USEPA and NHDES definition of an emergency engine

NHDES General Permit

An emergency engine is a stationary internal combustion engine used for emergency purposes that is limited to 500 hours of total operation during any consecutive 12-month period.

Application 15 day processing

Fee - $1,279.20

Emission Dispersion

Good Engineering Practices No Shanty Caps or Egg Beaters Vertical exhaust

Stack Height Requirements May Vary 10 Feet Above Nearest Roofline If the stack is lower than 1.5 times the building height or lower

than the height of a structure that is within 5L of the stack (5L being five times the lesser of the height or maximum projected width of the structure) MODELING REQUIRED

Other states have additional requirements

Siting Considerations

Siting Considerations

Impacts from Project Sound Levels Visual Impacts

Generator Housing

Generator Exhaust

Residence less than 25 feet away

Noise Considerations

Noise Policies Sound Levels Pure Tones

Zoning Specific Noise Provisions

Sound Level Monitoring Pre-Construction Post-Construction Ambient

Top Five Things Regulators Look For

#1 Recordkeeping Every Permit Condition

#2 Reporting Dont Miss Deadlines

#3 Inspections Document Required Inspections

#4 Non-Delegated Regulations Local / State / Federal

#5 General Duty Facility Condition

PresenterPresentation NotesAdd RMP

Questions

Breakfast Seminar Series

EH&S Regulatory Updates

November 1 Portsmouth, NH

Doug Stellato, Project Compliance Special