IN THIS ISSUE |
PRACTICAL MANAGEMENT: 10 STEPS TO ENVIRONMENTAL COMPLIANCE EPA PROPOSES NEW NSPS FOR GAS PLANTS EPA ACCEPTS FIRST GHG REPORTING DATA JAY SAYS |
PRACTICAL MANAGEMENT: 10 STEPS TO ENVIRONMENTAL COMPLIANCE |
by Wei Li
Posted: July 28, 2011
Ever wondered why some companies never seem to get into trouble with EPA? There is never bad press about them on TV in the newspaper. Meanwhile other companies constantly seem to be in trouble with the agencies for environmental violations. What sets these companies apart? Simple: Preparation. Here are some practical tips on how to properly prepare for, and thus avoid, compliance nightmares. - Make sure to have a written environmental policy that is signed by the CEO and communicated to all employees. Post it in a prominent place such as a company website. It can be a simple declaration by senior management on how it plans to conduct its business in the context of the environment. The latest buzzword is “sustainability.” It means do no harm to the environment and save it for the next generation.
- Have a designated senior company officer whose job it is to oversee environmental compliance. This person should have the confidence of senior management, and can muster the necessary financial resources and institutional commitment to implement the company’s environmental policy and plans.
- Write and post a simple, straightforward emergency response plan. The main purpose of such a plan is to tell the employees what they need to do when something goes wrong. It must be concise, realistic and easy to understand.
- The employees should have ownership of the company’s environmental plans. In other words, the employees charged with the responsibility of implementing an environmental plan should have been involved in some manner in the development of the plan.
- Be sure to perform environmental due diligence prior to shipping hazardous wastes to a Treatment Storage and Disposal Facility. Check up on their compliance history by going to EPA’s Environmental Compliance History Online webpage. Never cede this responsibility to someone else.
- If planning on leasing a piece of property, make sure to perform a baseline environmental study on the site to identify any pre-existing conditions. In this way, when the leased property is returned to the landlord, it needs to be in at least the same condition that it was at the start.
- Always maintain a good, cordial and professional relationship with the regulatory agencies. Instruct all employees to NEVER lie to an inspector.
- Never automatically go with the lowest bidders when hiring vendors or consultants. Always go with the most qualified contractors to ensure compliance with environmental laws.
- Stay on top of emerging new environmental regulations. There are free (Ed- e.g. Pollution Engineering’s website) as well as paid services to accomplish this task.
- Always know the chemical spill reporting requirements before the actual spill occurs. Many states have additional spill reporting requirements that are more stringent than those of federal regulators. Do the homework and match the chemical inventory against EPA’s List of Lists to determine the reportable quantities of each chemical. This way if there is a chemical spill in the middle of the night, everyone will know exactly if the reportable quantity has been exceeded, thereby triggering a reporting obligation.
http://www.pollutionengineering.com/copyright/BNP_GUID_9-5-2006_A_10000000000001083920?view=print |
EPA PROPOSES NEW NSPS FOR GAS PLANTS |
Posted: August 23, 2011
The EPA announced a proposal to address the reviews of the new source performance standards (NSPS) for volatVOCs and SO2 emissions from natural gas processing plants. The agency is proposing to add to the source category list any oil and gas operation that are currently not listed. This action also includes proposed amendments to the existing NSPS for VOCs from natural gas processing plants and proposed standards for operations that are not covered by the existing NSPS. In addition, this action proposes how the EPA will address the residual risk and technology review conducted for the oil and natural gas production and natural gas transmission and storage national emission standards for hazardous air pollutants (HAPs). This action further proposes standards for emission sources within these two source categories that are not currently addressed, as well as amendments to improve aspects of these national emission standards for hazardous air pollutants (NESHAPs) related to applicability and implementation. Finally, this action addresses provisions in these NSPS and NESHAPs related to emissions during periods of startup, shutdown and malfunction.
All comments must be received on or before Oct. 24, 2011. Three public hearings will be held to provide the public an opportunity to provide comments on this proposed rulemaking. One will be held in the Dallas, Texas area, one in Pittsburgh, Pa., and one in Denver, Colo., on dates to be announced in a separate document. |
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http://www.pollutionengineering.com/copyright/BNP_GUID_9-5-2006_A_10000000000001093932?view=print |
EPA ACCEPTS FIRST GHG REPORTING DATA
Posted: August 22, 2011
The EPA announced that they have launched a new tool to allow 28 industrial sectors to submit their 2010 greenhouse gas (GHG) pollution data electronically. Prior to being finalized, more than 1,000 stakeholders, including industry associations, states and NGOs tested the electronic GHG Reporting Tool (e-GGRT) to ensure clarity and user-friendliness.
The data collected with e-GGRT will provide the public with important information about the nation’s largest stationary sources of GHG pollution. Industries and businesses can also use the data to help find ways to decrease carbon pollution, increase efficiency and save money.
The EPA expects to receive 2010 GHG data from approximately 7,000 large industrial GHG emitters and suppliers, including power plants, petroleum refineries and landfills.
EPA’s GHG Reporting Program, launched in October 2009, requires the reporting of GHG data from large emission sources across a range of industry sectors. Suppliers of products that would emit GHGs if released, combusted or oxidized are also required to report GHG data. Under this program, covered entities are required to submit GHG data annually to the EPA and the first round of data will be submitted electronically by Sept. 30, 2011. The agency plans to publish non-confidential GHG data collected through the GHGRP by the end of 2011. |
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http://www.pollutionengineering.com/Articles/Industry_News/BNP_GUID_9-5-2006_A_10000000000001093739 |
JAY SAYS: Approximately 10,000 US facilities must begin collecting data and complying with all Environmental Protection Agency 40 CFR Part 98 Greenhouse Gas guidelines starting on January 1, 2010. This new regulation will affect a range of manufacturing and process plants including the chemical industry and the refining industry.
Flow measurement technology and expertise ensures reliable and accurate measurement on many CO²e emission points to meet both immediate reporting requirements and expected, longer term monitoring regulations.
Compliance assistance providers help regulated communities and businesses comply with environmental laws through one-to-one counseling, online resource centers, fact sheets, guides and training. Providers include EPA regional office staff; state, local and tribal governments; federal and state small business and pollution prevention technical assistance extension agents, consultants, and trade associations.
Compliance assistance is not effective when used in an integrated strategy combining compliance monitoring (inspections), compliance incentives and auditing (self-disclosure polices) and enforcement. www.epa.gov/compliance/assistance Best regards,
Jay Klaus
JKlaus@KlausEquipment.com
Klaus Equipment Company
President |
Klaus Equipment Company
Phone: 724-444-3420
Fax: 724-444-3425
2866 West Bardonner Road,
Gibsonia, PA 15044
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