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2016_EHS Seminar_Portsmouth NH slides

Feb 07, 2017

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Environment

  • 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