August Mack Environmental

• Lessen the environmental burden for your company
• Foresee and/or prevent potential disasters
• Build trust with regulators
• Grow community support
• Mechanism for site-specific evaluation and learning tool
• Creates a team aspect among employees
   

Have you completed your industrial truck training recently?

When preparing for entry into a confined space, you may need the following equipment:

• Ventilation
  • Does the space have potential for a hazardous atmosphere? If so, the space needs to be ventilated.
• Permits
  • A confined space permit needs to be filled out and reviewed by the entry supervisor, the entrants and observers.
• Testing Equipment
  • Air monitoring must be conducted prior to and during entry
  • Results are recorded on the confined space permit
  • All levels of the space need to be tested (top to bottom)
    • Some gases float and others pool
  • Testing needs to be done for oxygen content, lower explosive limits (LEL), hydrogen sulfide and carbon monoxide, at a minimum.
• Personal Protective Equipment (PPE)
  • Special PPE is sometimes required
  • If the space is a permit-required confined space, then a harness and retractable lifeline may be required, so that rescue can be done without entering the space.
  • Respirator protection
  • Specialized clothing/gloves/boots
    • Protect against contamination, lacerations and potential falls

• Communication equipment (walkie-talkie, cell phone if non-flammable atmosphere)
• Audible or visual alarms
• Fire extinguisher
• Explosion-proof lighting
• Rescue and retrieval equipment
• Ventilation equipment
• Barriers, shields and signs

The ex-situ pump and treat cleanup technology results in the following:

• Contaminated groundwater is removed from the subsurface by pumping
• It is often used with treatment technologies such as Air Stripping and Granular Activated Charcoal
• Requires understanding of aquifer characteristics (pilot-testing)
• Requires discharge to sanitary (POTW permit) or storm sewer (NPDES)

• Effective for capturing contaminant plumes and controlling migration
• Mass removal
• POTW discharge parameters negotiable

• Difficult to clean up sites, generally only contains. (Rebound issues)
• Long operation period
• Annual operation and maintenance costs
• Potential air emission issues

Knowing the difficulties associated with compliance, August Mack has developed an environmental, health and safety compliance assurance program (eCAP^®) that can revolutionize the way facilities manage environmental regulation compliance. eCAP^® focuses on the facility’s regulatory compliance, while reducing facility expenses on an annual basis and allowing internal personnel to focus on production. August Mack’s proven program manages corporate risk by outsourcing a plant’s regulatory compliance for a fixed monthly fee.

Our experience shows that clients spend a significant amount of time and money participating in training seminars, policy and regulatory committee meetings to educate themselves and track the ever-changing regulatory requirements. After all the research and education, many manufacturers are still uncertain regarding the applicability of regulations for their specific operations. In the end, compliance can only be confirmed via regulatory agency inspections, which often result in “Notices of Violation”, penalties and fines. eCAP^® is designed to eliminate all of these uncertainties and allows you to focus on your bottom line.

eCAP^® provides a team of experts in all areas of EPA environmental compliance to implement, review and maintain an environmental management system that ensures compliance with current and future regulations. This allows the facility personnel to focus efforts on production requirements and August Mack experts to focus on the facility’s EH&S compliance issues.

eCAP^® is modularly designed to help facilities achieve and maintain compliance with the following: 

• Clean Air Act (CAA)
• Clean Water Act (CWA)
• Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
• Occupational Safety and Health Administration (OSHA)
• Resource Conversation and Recovery Act (RCRA)

Asbestos Operations and Maintenance (O&M) Plans are based on an asbestos survey and have three primary objectives:

• Clean-up existing asbestos contamination
• Minimize future asbestos fiber releases
• Maintain asbestos containing material (ACM) until it is eventually removed

• Notification
• Establishment of a Asbestos Program Manager
• ACM Surveillance
• Supplement to Visual/Physical Evaluation (Air Monitoring)
• Work Control/Permit System Procedures
• O&M Work Practices
• Record Keeping Procedures

Summer is quickly approaching the end and fall is just around the corner. Speaking of fall, the other type of fall is a leading cause of occupational fatalities. These fatalities are considered preventable with the use of fall protection systems. Everyone is at risk at high elevations, and the possibility of falling must be recognized by all. When people are preoccupied with doing a job and have a momentary lapse in safety awareness, a death or injury may occur. Make sure you have the necessary program and equipment in place to protect your employees.

• No Notice of Violations (NOVs) or Notice of Deficiencies (NODs) from any of the regulatory agency inspections
   
• Reduces personnel, turnover, travel and training
   
• Ensured compliance eliminates regulatory fines and penalties
   
• Reduces future environmental, health and safety (EH&S) issues by addressing issues in a timely and efficient manner

When preparing for an employee to enter a confined space, the entry supervisor and crew should pre-plan the entire job focusing on identifying potential hazards and the elimination/control of the hazards. The program coordinator also should be able to provide assistance during the pre-planning process. The pre-planning process must consider at the least the following items:

• Energy hazards and needed Isolation procedures (LO/TO)
• Potential air contaminants, ventilation and air tests needed
• Cleaning requirements and procedures
• Potential ignition sources
• Personal Protective Equipment (PPE)
• Communication methods
• Fall protection and/or lifeline use
• Emergency rescue

If your company needs help with its pre-planning process for confined spaces, contact one of the environmental, health and safety plan consultants at August Mack Environmental at 800.579.0770.

It is estimated leaking components in facilities nationwide emit more than 40,000 tons of volatile organic compounds (VOCs) each year. Recent EPA audits suggest that actual facility leak rates are over five times as much as what had been previously reported. The EPA is increasing enforcement and more facilities are becoming applicable to Leak Detection and Repair (LDAR) program requirements through the Clean Air Act via New Source Performance Standards (NSPS) and National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations.

This informative webinar will detail applicability requirements of facilities subject to LDAR program from NSPS and NESHAP regulations. The webinar will also explore implementation options that facilities have to fully execute LDAR.

Click here to view this recorded webinar presented by an August Mack Environmental Compliance Consultant.

The ex-situ landfarming technology results in the following:

• Contaminated soils are removed by physical excavation from the ground and placed in open-air cells
• Excavated soils are usually placed onto plastic lining with side berms to contain all soils and moisture
• Contaminants are reduced in the soil by aeration and evaporation or by biodegradation
• Source area of contamination is eliminated
• May require some type of permit for evaporation of contaminants
• Confirmatory soil samples are collected from the landfarmed soils to confirm effectiveness
• Soils need to be managed after treatment

• Relatively simple to design and implement
• Short treatment times
• Cost competitive
• Removes potential contributors to groundwater impacts

• Very difficult to eliminate 100 percent of contaminants
• May not be effective for high contaminant concentrations
• Disruptive to site operations – requires large land area
• Presence of metals in soils may inhibit progress
• Dust and vapors may pose air quality concerns
• Impacts may have to remain under structures and utilities and along property boundaries
• May require state-approved air permits
• Requires routine O&M (tilling, etc.) and water collection