1 John Wellspring Senior Project Manager [email protected]ENVIRONMENTAL MANAGEMENT FUNDAMENTALS – GETTING STARTED AND STAYING ON TRACK 8:30 AM Session May 21, 2019 Indiana Chamber 2019 Environmental Permitting and Reporting Conference Presentation Content Know the EHS Regulations that apply to your facility and operations Know Your Permit Terms and Conditions Create a System for Managing Regulatory Compliance 1 2
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ENVIRONMENTAL MANAGEMENT FUNDAMENTALS – GETTING STARTED
AND STAYING ON TRACK
8:30 AM Session
May 21, 2019
Indiana Chamber 2019Environmental Permitting and Reporting Conference
Presentation Content
Know the EHS Regulations that apply to your facility and operations
Know Your Permit Terms and Conditions
Create a System for Managing Regulatory Compliance
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About the Audience
Plant or Environmental Manager?
Are you new to EHS regulations?
Industry/ Manufacturing?
Legal / Consulting / Other?
Do you have and ISO 14001 EMS?
Brief History and Scope
Statutes and Regulations
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Significant Environmental Issues of the1970sLeading up to Environmental Regulation
Lake Erie was considered dead
Rivers caught on fire from industrial discharges.
Bird populations in decline (as documented in Rachel Carsons’ Silent Spring)
Serious Environmental Health issues in cities, such as Smog, Air Quality, Water Quality
Growth in population density (Cities) and manufacturing density resulted in increasing pollution levels.
Many industrial processes were running with no pollution controls.
Love Canal Declared State of Emergency issued in 1978
Environmental Events in 1970
- The US Environmental Protection Agency (EPA) was created on December 2, 1970 by executive order of President Richard Nixon (later elevated to Cabinet Level by President Bush in 1990)
1970 - The first Earth Day; April 22, 1970
- National Environmental Policy Act
- Occupational Safety & Health Act
- Presidents Council on Environmental Policy
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Major Environmental Statutes/LegislationBeginning in 1970
1970 – Clean Air Act (CAA)
1972 – Federal Water Pollution Control Act (FWPCA)/ now know as Clean Water Act (CWA)
Intentionally crushed bulbs are typically hazardous waste
Accumulate for up to one year
Date at beginning of accumulation
Keep containers closed
Label as Universal Waste
Petroleum and Hazardous Substance Underground Storage Tanks
Petroleum and regulated substance underground storage tanks (systems with >10% volume underground) must be registered Small farm and residential tanks are exempt
Heating oil, wastewater and flow-through process tanks are exempt
Tanks must meet minimum design and construction standards
Tanks systems must be upgraded to meet applicable standards
Leak detection and inventory control are required
Records of inventory and leak detection must be maintained
Certified operators are required
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Scope of Community Right to Know; EPCRA/SARA Title III Regulation
Requires Public Disclosure of chemicals stored at, and released from, a facility Hazardous Chemical Inventory Reporting (Tier II Inventory
Reports/ SERC Reports)
Toxic Chemical Release Reporting (Toxic Release Inventory Reporting/ Form A, Form R release reports
Requires Community Emergency Planning and Response Planning and Coordination State Emergency Response Commission (SERC)
Local Emergency Planning Committee (LEPC)
Tier II Chemical Inventory Reporting
Annual Reporting Requirement: March 1 due date, update on new chemicals within 60/90 days after storage over threshold
Requires reporting of >10,000 pounds of any OSHA hazardous chemical stored onsite at any one time Certain Exemptions Apply
Requires reporting of any listed Extremely Hazardous Substance (EHS) onsite at >500 or the TPQ, whichever is less
EHS facilities required to participate in emergency planning
Submitted to the State (SERC), County (LEPC) and local fire department
State Electronic reporting; Fees are assessed upon submittal
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Toxic Release Inventory (TRI) Reporting of TRI Listed Chemicals
Annual Reporting Requirement for Manufacturers: July 1due date, based on listed chemical usage above threshold in previous calendar year: (# of FTE Employee and NAICS code limited)
Chemicals manufactured and processed are subject to 25,000 pound per year threshold, while Chemicals otherwise used are subject to 10,000 pound per year threshold
Certain “PBT” chemicals (such as lead and mercury) have very low thresholds (100/10 pounds per year)
Submit TRI reports to USEPA and States via EPA CDX; TRI-ME Web Module
Includes releases to air, water, land and transfers off-site
Scope of Toxic Chemical Regulation (TSCA)
Bans Controls and Restricts Manufacture and use of Materials in Commerce
Asbestos, PCBs, CFCs, Dioxins, Lead
Regulates New Chemical Substances as they introduced into Commerce
Pre-Manufacture Notice (PMNs)
Significant New Use Rules (SNURs)
Requires notification in workplace of adverse chemical reactions
Mandates testing, data collection and reporting
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TSCA Chemical Data Reporting (CDR)
Quadrennial Reporting Requirement for Chemical Manufacturers and Importers: September 30 due date, last due in 2016 for 2012-2015 period
Subject to manufacturers or importers of greater than 25,000 pounds of any substance with CAS # Certain exemptions apply
Has lower Threshold for specifically listed chemicals
Submit to USEPA via EPA CDX; CSPP Web Module, CDR reporting Form: EPA Form U
Includes info on uses on-site, persons exposed, form and distribution in commerce
Other Potentially Applicable Regulatory Requirements
FIFRA: Pesticide Registration, Restricted Pesticide use, and licensed users
Army Corps of Engineers/County Drainage Boards; Stream Alterations, Ponds, Property Improvements
Stormwater Construction Permits; Disturbance of >1acre