epa environmental ppt presentation houston aug 2014

8/11/2019 EPA Environmental PPT Presentation Houston Aug 2014

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MARKETING

Welcome! My name is Jolene Wiza –from J. J. Keller, we are happy that you can join us. I work in marketing for J.J.

Keller, and I’m your event coordinator and also very proud to introduce your compliance team that will be hosting

today’s forum. Before we kick off today's event please allow me the opportunity to introduce

xxx

xxx

In the audience we have some additional great J.J. Keller Resources….

Field Members:

Ecommerce & Marketing Team:

Before I hand you off to your compliance team, I have few housekeeping items to cover about today’s event…



Marketing

We promise to give you a break at around 10:15 & very nice

lunch buffet from 12-1. We’ll be wrapping up our session todayaround 2:30.

Please take a moment to pull out your cell phones and put them in

silent mode.



Marketing



MARKETING

Before we get started, please know that today’s event is interactive. Don’t hesitate to

ask your questions as we go along.



Marketing:



Marketing –

Include brief overview of JJ Keller Partnership with US Compliance…..



Sales

100% Debt Free

Come Visit Us!



Sales

Identify and Manage Risk

Provide Solutions

3 areas



Sales: Cover agenda & introduce 10 minute Table Exercise: Each table break into

groups & introduce yourself

As a group discuss why you came today and come up with 1-3 things you want to get

out of today’s session or questions you might have related to EPA - Using your notepads

and pens provided at your tables and we’ll come around to collect your questions and

post on the board & cover through-out the day today!

Industry? Size?

MN?

Multi-locations/states?

w/b including MN specific reps

Table ExerciseEHS – both?



USCC

State waste inspections almost always result in fees today, 3 years ago it was the

exception.

Look for the county enforcement groups to start following this trend, although it ismore difficult for them to issue penalties.



USCC



USCC

Ozone Non-attainment affects VOC and NOx



USCC



USCC

BACT – Best Available Control Technology; state BACT allows for material substitution in

additional to controlsAmbient Air Analysis can include the use of MDE toxics spreadsheet or modeling



USCC

Additional requirements and criteria in each PBR

-352: Certain conditions for the Barnett Shale Counties



USCC



Sales

That ends the section on air permitting, are there any questions?

Now we will move into Ozone Depleting Substances, or ODS regulations. This includesrefrigerants that impact the ozone layer, such as R-22 that many of you may be familiar

with.



CFCs and HCFCs (chlorofluorocarbons and hydrochlorofluorcarbons) migrate high into

the atmosphere when released. UV radiation causes the molecules to break down,

releasing chlorine atoms. The released chlorine atoms destroy numerous ozone

molecules through a reoccurring chain reaction. The destruction of the ozone layer

plays a large role in climate change. Without the ozone layer to act as a shieldabsorbing the UV radiation, the earth becomes exposed to high amounts of the

radiation.



Sales



USCC

Refrigeration systems that contain greater than 50 pounds of refrigerant must calculate

the leak rate each time refrigerant is added to the system. Systems with a leak rateexceeding 35% must repair the leaks or retire the system.



USCC

Leak rate calculations can be done using the formula shown. Each time refrigerant is

added to a system containing greater than 50 pounds of refrigerant, leak rate must becalculated.



USCC

Under Section 608 of the Clean Air Act, servicing information records must be

maintained by a facility for all systems that contain greater than 50 pounds ofrefrigerant. Required records include: the date and type of service performed on the

refrigeration system, the amount of refrigerant added along with the date that

refrigerant was added to the system, and the leak rate calculations should be kept on

file.



USCC

Only technicians that have been trained and certified by an EPA approved organization

can legally handle R-12, R-22, and R-134a refrigerants. Certified technicians will receivean ID card like the one pictured. Training educates a technician on refrigerant servicing

and recovery procedures, EPA regulations and approved equipment and the effects on

ozone depletion.

Make sure that the technician servicing your chiller or air conditioning system is

certified!



USCC

The flowchart summarizes the required management criteria and procedures for refrigerant containing systems. Ifyour system is subject to leak repair requirements (great than 50 pounds, contains CFC or HCFC) and exceeds the35% leak rate then intervention is needed to prevent further refrigerant release.



USCC



Sales – slides 35-58

The emergency planning and community right to know act was created by the EPA in

1986 in response to two chemical leak disasters that occurred in Bophal, India andWest Virginia. In 1984, a poisonous gas leak from a Union Carbide pesticide plant killed

of thousands of people and left hundreds of thousands injured in India. The following

year, another Union Carbide leak left 100 people hospitalized.

The EPA responded to these disasters by establishing EPCRA to prevent subsequent

disasters from occurring. EPCRA allows federal, state and local authorities to enforce

hazardous chemical emergency planning and reporting. EPCRA is divided into the two

main reporting sections: Tier II and TRI (or Form R) reporting.



Sales

EPCRA reports must be filed annually. Tier II reporting provides hazardous substance

STORAGE information. Some of the most commonly reported Tier II substances includesulfuric acid and lead contents within lead-acid batteries, and compressed gases, such

as propane. TRI reports provide substance USAGE and RELEASE information. Facility

releases typically occur through recycling procedures. Heavy metals, xylene,

formaldehyde and glycol ethers are a few examples of commonly reported TRI

substances.



Sales



The following summarize the key points to keep in mind when assessing your facility for

Tier II reporting applicability.

• Thresholds are based on the maximum amount of a substance that could be

stored onsite at any one time throughout the year. For example, say your

facility ordered new forklifts. While transitioning from the old equipment to

the new equipment the sulfuric acid and lead onsite storage breeched

threshold. Even if the threshold was only breeched for a few days or a month,

you would have to report for those chemicals.

• Tier II reports are due March 1st each year.

• There is an extremely broad range of reportable substances. It can range

from a chemical that causes minimal irritation to highly toxic chemicals.

(Used Oil versus Dioxin)

•You are responsible for backfiling any reports missed in the previous 5 years.



Sales

Substances that are required to have a Safety Data Sheet maintained onsite under

OSHA regulations are candidates for Tier II reporting. Hazardous substances that meetthe first criteria and also exceed the storage threshold, are required to file a Tier II

report. Extremely Hazardous Substances, identified as such by the EPA, have a reporting

threshold of 500 pounds. All other hazardous substances have a reporting threshold of

10,000 pounds.



USCC

Many manufacturing facilities across all industries have battery operated forklifts on

site. Lead-acid batteries contain two Tier II reportable components: sulfuric acid andlead. It only takes a few batteries to put a facility over the reporting threshold for

sulfuric acid!

If you know your facility has forklifts or other battery operated equipment, use these

steps to help you perform a Tier II assessment. First create a list of all batteries stored

on site, making note of the manufacturer and weight of the battery. Next refer to the

SDS corresponding with each battery brand to determine sulfuric acid and lead percent

composition. Each battery brand has different acid and lead content, so you need to

calculate the total pounds of each component utilizing the battery weight andcomposition percentages.

Please note that commercial sized batteries; i.e., smaller sized batteries commonly

found in cars, trucks, or fossil fuel driven equipment are exempt.



USCC

The chart displays a sample battery inventory and calculation spreadsheet. As you can

see, battery weight and substance composition can range across battery brands. Thecalculation results show that the facility is required to file a Tier II report for sulfuric

acid, due to exceeding the 500 pound threshold as an EHS. Lead has a threshold of

10,000 pounds and therefore Tier II reporting is not required for the metal.



USCC

Reported online in most states



Sales

It is now time for an activity, in your folders you will find a Tier II handout. Feel free to

work on the question as a table.Read through the Facility Description and Reporting Notes and determine whether

each stored item is reportable, an EHS, or Not Reportable. We will give everyone 5

minutes.



USCC



USCC

There are 682 TRI covered chemicals. The 682 chemicals are TRI reportable because

they are known to cause 1. Chronic health effects 2. Significant adverse health effectsOR 3. Significant adverse environmental effects.



Sales

If your facility does not meet all three criteria, TRI reporting is not required. Facilities

must report if their primary North American Industry Classification System (NAICS)code falls under the TRI covered industry list, they employ 10 or more full-time

equivalent employees, AND exceed a chemical usage threshold.



USCC

Various chemical thresholds exist across the reportable chemical categories and

specific chemical procedures at a company. Generally, the reporting threshold will be25,000 pounds for manufactured or processed substances. However, the threshold

drops down to 10,000 pounds for substances used as chemical processing/

manufacturing aids or waste remediation.

Thresholds drop to 100 pounds and 10 pounds for Persistent Bioaccumulative Toxic

(PBT) Chemicals. Dioxin/dioxin-like chemical threshold is 0.1 gram.



USCC

There are a handful of TRI exemptions that have specific criteria for applicability. Someof the most common exemptions include:

• Chemicals used for motor vehicle maintenance procedures on personal vehicles onlyoperated at the facility.

• Structural component within the facility.

• Chemicals used for routine janitorial or grounds maintenance

• Chemicals used for personal employee use within the facility, not used in themanufacturing or processing of an item for another facility.

• De minimis. Each reportable chemical is given a de minimis level. For example, if aspecific carbon steel contains less than one percent of chromium then the chromiumin the carbon steel is not applicable to TRI usage reporting. De minimis levels areusually 1% or 0.1%. De minimis exemption does not apply to PBT chemicals.

• Laboratory chemicals used in sampling and analysis, quality assurance, qualitycontrol or research and development activities and are under direct supervision of a



qualified individual are exempt.

• Article Exemption will be discussed in the next slide.



USCC

Article exemption applies to a TRI reportable substance if the properties (thickness,

diameter) of an item containing a TRI reportable chemical are not altered, the chemicalis not released while processed, and the item is recycled or directly reused at the

facility.

For example, say a facility receives copper wire from a different manufacturing facility.

The facility that received the wire does not use the wire in any processing activities

(i.e.-welding), only cuts the wire into smaller pieces. Cutting the wire does not release

copper emissions into the air, the wire remains in a recognizable wire form and any

copper wire not used onsite is recycled. This facility would not report copper wire

usage due to article exemption.



USCC

There are two different TRI forms: Form R and Form A. Form R is a longer report

requiring more information regarding chemical use, disposal and releases compared toForm A. Form A can only be filed if disposal or other releases and recycling activities do

not exceed 500lbs for a non-PBT chemical AND manufacturing, processing, or

otherwise use of chemical does not exceed one million pounds.



USCC

Unlike Tier II reporting which is state specific, TRI reporting occurs on the EPA’s national

online reporting system. Each facility will login to the central data exchange website.The designated signing official must login to the website following TRI report submittal

to certify the report. The state will receive the TRI report from the online reporting

system and will send out fee invoices once certification is completed.



USCC

P2 plans are a private plan maintained at a facility. The plan outlines a company’s goals

and progress towards pollution reduction in relation to the chemicals reported in theirForm R. P2 plans must be updated every even numbered year.

P2 reports are filed to provide the state and public with annual progress made in

pollution reduction. These reports are due on July 1st, the same deadline as TRI reports.



Sales



Sales

We are now going to transition into Waste Management which will be divided into two

topics. The first of which is RCRA and how it relates to sites generating hazardouswaste.

RCRA: Resource Conservation and Recovery Act – Requires anyone who owns or

operate a facility where hazardous waste is treated, stored, or disposed of to have a

permit



USCC

RCRA authorizes the EPA and state authorities to regulate the generation, storage,

transportation and disposal of hazardous and solid wastes.

The common “cradle to grave” phrase used to describe hazardous waste management

represents the idea that a hazardous waste generator is responsible for the waste that

they generate from the moment it is generated until the moment of the waste’s

ultimate disposal (i.e.- incineration, treatment making substance non-hazardous).

Regulated solid waste includes all non-hazardous, industrial solid wastes. RCRA sets

standards for solid waste disposal.



USCC



USCC

Listed (F-Listed) waste includes solvents: acetone, xylene, toluene



USCC



Sales



USCC

In general, hazardous waste generators are not allowed to intentionally evaporate or

dry hazardous waste to render it nonhazardous. Waste paints or solvents can not beleft open to volatilize.

Despite the mixing rule, you are not allowed to dilute a hazardous waste with a

nonhazardous waste with the purpose of making it not exhibit a hazardous

characteristic.



USCC



USCC

TSDF = Treatment, Storage, and Disposal Facility



USCC

Multi-copy “Cradle to Grave” Tracking Document

Required for all generators (LQGs and SQGs) who offer up hazardous waste fortransport

Must be signed by someone in the company who has had training

Must have an emergency response contact number

Must comply with DOT Hazmat requirements



USCC



USCC

Does not count against waste generator status



USCC



USCC

Shipping does not required manifest; must keep receipt



USCC



USCC

Containers holding hazardouswaste contents are not considered

hazardous waste if… All contents removed by pouring, pumping, spraying

Less than one inch of residue



Less than 3% by weight if <119

gallons

Less than 0.3% by weight if >119

gallons

Example- Can of paint cannot berecycled or landfilled until RCRA empty

container requirements are met.



USCC



Sales – lead the questions to the group

USCC – provide responses



1. Drums require secondary containment. Releases would enter storm drain and be

directed outdoors. Drum three from the left does not have a visible label.

2. Hazardous waste storage area is placarded. Hazardous waste labels are visible on

three of the four drums. Containers appear to be closed.



1. Drums require secondary containment. Releases would enter storm drain and be

directed outdoors. Drum three from the left does not have a visible label.

2. Hazardous waste storage area is placarded. Hazardous waste labels are visible on

three of the four drums. Containers appear to be closed



Both containers are open. The lid is open on the left and bung is off of the drum on the

right.



Aisle spacing, secondary containment, labeling, hazardous waste placard, etc.



USCC

Oil Spill Reporting > 210 gallons in Texas



USCC

That brings us to the other area under waste regulations we are going to discuss.

CERCLA: Comprehensive Environmental Response, Compensation, and Liabilities Act



USCC

1. Hazardous chemicals and hazardous wastes are governed by 4 key federal

regulations:• OSHA – Hazard Communication of hazardous chemicals used in general

industry and construction

• DOT – hazardous materials during transport

• CERCLA – a.k.a. “Superfund” – hazardous/solid wastes, chemicals at

abandoned or historical waste sites

• RCRA – hazardous/solid wastes at active facilities

2. RCRA focuses only on active and future facilities and does not address abandonedor historical sites which are managed under the Comprehensive Environmental

Response, Compensation, and Liabilities Act (CERCLA) – a.k.a. “Superfund”

• CERCLA/Superfund – enacted in 1980

• CERCLA includes 100s, 1000s of sites and the national priorities list



USCC



USCC

CERCLA is retroactive. Facilities that produced the waste before CERCLA existed can still

be held responsible for past hazardous waste releases that were not previously cleanedup. Waste generators, previous owners of a hazardous waste spill site, and even owners

that acquire a hazardous waste spill site after the spill if the waste can be tracked

Example: Only one drum in large waste site but still must split cost equally with 30

other waste generators



USCC



Sales



USCC

The Clean Water Act of 1972 consisted of two main components: the national pollutant

discharge elimination system permitting program and EPA authority to regulate pointsource discharges into United States waters.

Across all industries, any company that wants to discharge pollutants from their facility

must obtain an NPDES permit. The majority of permitting is done at the state level.



USCC

1



Sales

If have covered SIC code must obtain a storm water permit or file a no exposure

certification.

1



Sales

1



USCC

1



Sales: Activity Slides

Use handout to coordinate activity.

Pause at each of the next two slides to allow participants to complete activity

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USCC

1



USCC

Wastewater discharges include any process related water that is discharged from the

facility. Water used in manufacturing, contact/noncontact cooling water, washing andany other processes, other than domestic water use (bathrooms), is considered

industrial discharge.

Your facility may be required to obtain a NPDES permit if you discharge to surface

waters, the sanitary sewer, or produce a categorical wastewater that is shipped off as

waste.

1



USCC

1



USCC

Industry specific process wastewater

(40 CFR 401-471)

EPA Pretreatment Category and Standards

EPA regulations apply regardless of local/state approval or permit

1



USCC

1



Sales –

For the next section we’ll focus on avoiding oil pollution with proper Spill Prevention,

Control and Countermeasure; more commonly referred to as SPCC.

1



Sales

The point of a properly constructed SPCC plan is to keep oil out of any and all navigable

waters such as lakes, rivers, streams, and wetlands as well as any storm drains that maylead to them. One thing to bear in mind is that the EPA’s definition of navigable water

can be quite broad.

1



Sales

So why is this important? Because of its ability to spread, even a small amount of oil can

cause significant damage. Just the small amount of oil used in a typical oil change foryour car, around 5 quarts, can contaiinate up to 1 million gallons of fresh water.

1



USCC

So, at what point are you required to create an SPCC plan? At any given facility, if you

have more than 1,320 gallons of aboveground oil storage capacity or more than 42,000gallons of underground oild storage capacity, you must create a compliant SPCC plan.

Please note that I said CAPACITY. You do not actually need to store that much oil to be

on site, you just need to possess the capacity to do so.

In terms of what sorts of containers count toward this total, they must 55 gallons or

larger. They do not need to be dedicated storage containers, you must also include oil-

filled machines, transformers, generators, etc.

Now that we’ve discussed what sort of containers must be included in your

calculations, let’s discuss what sort of substances are defined as “oils” by the EPA.

1



Sales

1



Sales

While this isn’t a complete list of all oil types, these are the ones that you are most likely

to have onsite. Again, the containment vessels must have a capacity of 55 gallons ormore. Cans of paint or motor oil stored in a workshop or bottles of olive oil stored in a

commercial kitchen do not count toward your total aboveground capacity.

1



USCC

As the acronym implies, a compliant SPCC plan must address 3 primary elements.

1



USCC

The key to Prevention is inspections; we recommend they be done monthly. Both

primary AND secondary containment systems need to be in proper working order at alltimes. One very common oversight is rainwater collected within a containment dyke or

spill pallet. If the secondary containment system is full of water, it can’t serve the

purpose for which it was intended. Also, if there is even a small amount of oil sitting on

top of the rain water, be sure to run the water through an oil separator before you

discard it.

1



USCC

Video of spill captured by Kevin Miller. Launch video and allow Kevin to comment.

1



Sales

Please note that facilities in states that are prone to earthquakes may be required to

provide greater capacity.

1



Sales

So what are the common types of secondary containment?

• Double walled tank – same idea as double-hulled ships used to transport crude oil.

• Spill Pallets – fine for indoor use, but not outdoor use as they are prone to fill with

rain water.

• Dike/Berm: a contained area around the storage tank. As mentioned before, it must

match the capacity of the largest tank plus freeboard.

• Indoors. As long as any spill cannot find it’s way to a drain and as long as the building

is capable of containing the capacity of the largest tank, no additional secondary

containment is required.

Kevin, do we want to mention active containment of this slide?

1



Sales

So, by a show of hands, who believes that these oil drums have sufficient secondary

containment? Why or why not?

1



USCC

1



USCC

So, we’ve spent a fair amount of time on the first “C”, containment. For the most part,

containment systems are passive and either or don’t work as intended during an actualemergency. But, what are the active steps you should take when a spill does occur?

These active steps are called Countermeasures and should include (see slide).

1



USCC

There are three different levels of certification for above ground storage. They are as

follows:• Under 10,000 gallons – self certification is acceptable

• Greater than 10,000 gallons – must be certified by a professional engineer

• Greater than 1 million gallons or involves a transfer over navigable waters – must be

certified by a professional engineer AND must include a Facility Response Plan (Kevin,

can you fill in details on what an FRP is? I should have taken better notes on

Monday).

1



Sales

Chances are there is not going to be any notification, on a moments notice you need to

be ready and prepared for an inspection. BTW your chances of a routine inspectionquadruple during prescheduled vacation.

1



USCC

Civil enforcement actions at facilities and criminal enforcement actions concluded in FY

2012. This doesn’t include basic fines, State or County enforcement!Compliance is no longer an option and our system is command and control.

Colors are different agencies (air, waste, water)

1



Sales

1



USCC

Its important to note that environmental inspections are generally by department (air,

waste, water).

1



USCC

1



Sales

Practice a mock drill, people tend to chatter when nervous – make sure everyone

knows their roll

1



USCC

RCRA Example

A waste label is missing for 8 days. The label is missing, the weekly inspection record

did not record the problem, therefore we also have a training issue. At $150,000 per

day for 8 days, the maximum is $1.2 million. Now, its not entirely realistic that the EPA

would ever follow this model, but it is important to note that they significant ability to

levy penalties.

1



USCC

1



Sales

Each one is a separate inspection but they talk between groups

Don’t over share

Be friendly

We will now review each area individually

1



USCC

1



USCC

In previous accounts site managers have been charged with operator liability. If the

court finds that the site manager has control over waste removal in a CERCLA case,then the manager can be charged with responsibility.

1



USCC

1



Sales

Must always be accessible

1



Sales

Do not forget to include all sources of oil

1



Sales

Driver must be present

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USCC

1



USCC

Passivation, chrome plating, blackening – there are several operations

1



20 minutes !!!!

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USCC

What we have learned and key take aways

1



Sales:

J.J. Keller has services & in-house technology solutions to help keep you in compliance with OSHAregulations. When you want to do it yourself in-house, Keller Online is a great resource. When you needhelp, J.J. Keller consultants like Steve can provide you with the regulatory expertise, direction &knowledge to get you on track.

*** Help button – OK to ask for help.

*** Take you from where you are today to where you want to be.

*** If, after today’s discussion, you’re thinking (issues), then JJK can help you through (solutions).

(issues – Mgmt buy in, overwhelmed, inconsistent tools, can’t currently measure my program, training,

regulatory expertise, etc.)

*** Consistency across all safety professionals – same tools, reference materials, resources, can have

same high expectations for everyone.

*** Reinforce that you are already telling them.

*** Communicate Seriousness – sends message the company takes the safety of their people seriously.

*** “Softer Side” of Safety – at the end of the day, we all want everyone to get home safely to family,spouse, kids, friends, co-workers.

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Sales

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JOLENE-MARKETING

-Let’s give our presenters a round of applause

-We hope you enjoyed today’s session

-Thank you for taking time out of your busy schedules to attend

-Our presenters will be staying afterwards to answer any questions

-Mention Website

-Before we close today, if you could please take a moment to fill out the feedback

forms we are passing out, 2 SIDED FORM. This won’t be the last time we are in your

area, and we really value your feedback for future events.

epa environmental ppt presentation houston aug 2014

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