Transcript Slide 1

Environmental
Environmental Health & Safety
Environmental Protection Program
Public Health Significance
CAA regulations are estimated to produce the following impacts:
200 fewer expected cases of post neonatal mortality; 10,000
fewer asthma hospitalizations in children 1-16 years old, with
estimated benefits ranging from $20 million to $46 million (1990
U.S.$); 40,000 fewer emergency department visits in children
1-16 years old, with estimated benefits ranging from $1.3
million to $5.8 million; 20 million school absences avoided by
children 6-11 years old, with estimated benefits of $0.7-1.8
billion; and 10,000 fewer infants of low birth weight, with
estimated benefits of $230 million.
Slide 2 of
Medium of Releases
• Air
• Water
• Land
Environmental Releases
• Generally are:
– Permitted
– Permit by rule
– Exempt
– de minimus
– Spills
– Uncontrolled
releases (upset
event)
Air Releases
• Clean Air Act promulgated in 40 CFR Part 50 – 99
• TCEQ 30 TAC Chapter 101 - 122
• Includes provisions for attaining
and maintaining the national
ambient air quality standards
(“NAAQS”).
• Identifies six criteria pollutants
(sulfur oxides, particulate matter,
nitrogen oxides, VOC (ozone),
carbon monoxide, and lead).
• Identifies non-attainment areas for
criteria pollutants and
requirements for SIP to achieve
NAAQS.
Major Source Thresholds
• Attainment areas
– Criteria Pollutants 100 tpy
– Other pollutants 250 tpy
– HAPs (NESHAPs) 10 tpy
for any single chemical; 25
tpy total
• Non Attainment
Areas
– Emission limits vary by
area classification
Major Source Thresholds (NAAQS)
VOCs or NOx
PM-10
CO
Marginal or
Moderate
100 tpy
100tpy
100tpy
Serious
50 tpy
70 tpy
50 tpy
Severe
25 tpy
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Extreme
10 tpy
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Nonattainment
Area Category
Potential to Emit
• Potential to emit (PTE) amount of pollution a
source, or group or
sources are physically
capable of emitting in a
year.
– Based upon maximum
hours of use
– Total amount of fuel
– Total amounts of chemical
• Emission Factors can be
obtained from AP-42
documents
Major Source Permits
and Authorizations
• Permit or authorization required before
construction begins
• Permits include:
– New source review
– Prevention of significant deterioration
– Flexible
– Standard
– Title V (federal operation permit)
Exempt Air Sources
• De Minimis facilities/Sources 30 TAC § 116.119(a)
• Permits by rule 30 TAC Ch. 106
– Covers sources including:
• Emergency Generators
• Boilers
• Print shops
• Wood working
• Laboratory Equipment
• Domestic heating & cooling
• Refrigeration units
• Pathological waste incinerators
Permit By Rule Source Limitations
• NOx 100 tpy & CO 250
tpy
• All other pollutants 25 tpy
• May require registration
with TCEQ
• Documentation – 12
month rolling averages
• Pollution limits Apply to all
sources in contiguous
locations (common
ownership & with ¼ mile)
Air Emissions Compliance Worksheets
PTE Worksheet
12 Month Rolling Average
Emergency Generator Use Log
Upset Events
• Applies to air releases in
amounts greater than
Reportable Quantity listed in
– 40 CFR 302.4
– Butanes, hexanes, propane
5000 pounds
• Emissions event - Any upset
event or unscheduled
maintenance, startup, or
shutdown activity that results
in unauthorized emissions
from an emissions point
Water Releases
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Sanitary Sewer
Laboratories
Storm Water
Facilities
Regulations
• Clean Water Act
– Enforced by Environmental Protection
Agency (EPA) and Texas Commission on
Environmental Quality (TCEQ)
– Includes:
• National Pollution Discharge Elimination
Program (NPDES) or equivalent state program
• Surface Water Quality Standards
• Storm Water Pollution Prevention Plan
(SWPPP)
National Pollution Discharge Elimination
System
• Water permitting program
• Applies to point and nonpoint
•
source discharges to
navigable
• waters, e.g., POTWs, animal
• Feed lots, SWPP
• Permit requirements are
based on TMDL and use
classification of the receiving
water body
Storm Water Pollution Prevent Permits
• A SWPPP is required for
any project that disturbs
one acre of soil or more
• SWPPP elements include
training, key personnel
identification, emergency
response measures, and
regular or special site
inspections and
maintenance of "Best
Management Practices"
(BMPs)
Storm Water Quality Management Plans
• Part of MS4 regulations
• Universities may be small MS4’s permitted by
the state, or be co-permit holders with local
municipalities
• Requires:
– Identification of storm water conveyances
– Structural controls
– Best management practices to reduce
pollutants e.g., litter
Spill Prevention Control and
Countermeasures 40 CFR § 112
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Program designed to prevent oil releases into navigable waterways by
requiring certain facilities prepare oil spill control, countermeasures, and
contingency plans
Covers facilities that use, store, transfer, or consume oil or oil products
• Capacity thresholds:
– 1,320 gal aboveground
– 42,000 gal completely
buried
• Exemptions:
– Completely buried tanks
subject to UST regulation
– Containers < 55 gal
– Wastewater treatment
facilities
– Permanently closed
containers
– Motive power containers
• December 2006
Amendments
• AST <10,000 gal and meets
discharge history may:
– Self certify SPCC plan
– Meet security and tank
integrity without PE
certification
• Oil-filled operational
equipment
– Inspection & monitoring
program in lieu of secondary
containment
Exempt Water Releases
• Sanitary sewer
discharges to a
permitted POTW,
or waste water
treatment plant
• Gray water
systems for onsite
irrigation
Spills or Uncontrolled Releases
Reportable Quantity list - 40 CFR 302.4
and 30 TAC Chapter 327
Diesel & Used oil – 25 gallons on land or
amount sufficient to cause a sheen in a
waterway
Sodium hypochlorite – 100 lbs
Bulked hazardous waste – 1 lb or 1 quart
Solid hazardous waste – 40 CFR 302.4
Radioactive materials – 40 CFR 302.4
appendix B
Biological/infectious waste – 100 lbs
Asset Releases
Why Worry About Asset Releases?
•
Institutional assets represent significant liability issues
– environmental releases
– occupational exposures
•
Regulatory requirements
– Texas Health & Safety Code, Title 6, Subtitle C Substance Abuse
Registration and Crimes, Chapter 481 Texas Controlled
Substances Act, Section 481.077 (Chemical Laboratory
Apparatus)
– 40 CFR part 82 Protection of Stratospheric Ozone
– 25 TAC chapter 289 Radiation Control
– 40 CFR part 61.150 National Emission Standards for Hazardous
Air Pollutants
– Memorandum of Understanding between DPS and THECB
Things to Consider
• Assets may possess hazardous characteristics
– Biological, chemical, radioactive or physical
– Non-Hazardous
• furniture
– Inherently hazardous
• LS counters, mass spectrometers, monitors
– Hazardous characteristic added
• Refrigerators, incubators, centrifuges
– Chemical Laboratory Apparatus and precursor
chemicals (compliance with MOU)
Chemical Laboratory Apparatus
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Condensers
Distilling apparatus
Vacuum dryers
Three-neck flasks
Distilling flask
Tableting machines
Encapsulating machines
Funnels - filter, buchner,
separatory
• Flask - Erlenmeyer, twonecked, single neck, round
bottom, thermometer, filtering
• Soxhlet extractors
• Transformers
• Flask heaters
• Heating mantles
• Adapter tubes
Environmental Accounting
and Communication
Adding Perspective • The more removed from
“safety”
– The idea becomes more abstract & requires
better communication and accounting
– Complex regulations
– Must be put into “Context” for communicating
to upper management
• In Addition
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Free from identified hazards
Immediate harm
OSHA 300 Log
Injury/inspection reports
Public concern, outrage can be high
Involuntarily encountered
Little apparent benefit
Controlled by others
Unknown or substantial consequences
Exposures that could result in
harm
Possible precursor to safety
concern
Levels/limits
Releases that could result
in health or safety concerns
Could affect health
Ultimately affect safety
Environmental Reports
• Useful for communicating
results with:
– Upper management
– Regulators
– Safety committees
– Public
– Fellow employees
Graphs vs. Excel Spreadsheets ?
Environmental Reports
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Define Waste Streams or Process
Identify Waste Disposal Cost
Obligations (disposal liability)
Calculate Disposal Expenditures
Calculate Cost Avoidances
Environmental Report Examples…
Chemical Waste Programs
Biological Waste Programs
Radioactive Waste Programs
Environmental Protection Program Summary
Graphical Summaries
Expenditures
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Disposal
Transportation
Stop Fees
Competitive Bids
Packaging
Cost Avoidance
• Monetary value associated with an
environmental program’s activities
• Increases with:
– Large number of hazardous material users
– Multiple satellite accumulation areas
• Accounts for intangible activities such as:
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Personalized services
Emergency response
Historical knowledge
Value of compliance
Chemical Purchases
• Reports can be utilized to show
cost of disposing unused
portions
• Support just-in-time purchasing
• Segregate by chemical
• Total cost of purchases
• Cost of disposal
Important Undertones...
• Relate to business plan or
mission statement
Non compliance
ramifications
• Show environmental
activities that enable the
organization to
accomplish goals
• Embarrassment to the
organization
• Tying your environmental
product to the bottom line
• Monetary fines
• Public scrutiny
Parting Thoughts...at the end of the day......
Safety Committee and CEO Wish lists
Losses
• Personnel
• Property
Compliance
• External
• Internal
Fiscal/Budget
• Over/under – How
much does your
program cost
Service or satisfaction
• Happiness
Questions ?
Alan Lucas
1851 Crosspoint Ave. OCB 1.330
Houston, TX 77054
713-500-8104
[email protected]