August Mack News

Today's building managers and owners must not only manage the most well-known types of environmental issues in buildings, such as asbestos, lead-based paint, lead in the water and mold, but they also must consider the new environmental exposures issues including Chinese drywall, vapor intrusion and PCBs in caulk.

Since buildings exist to protect people from the elements of the outside world while supporting human activity, buildings should not make people sick, cause them discomfort or inhibit their ability to perform. If environmental exposures are not managed properly, a building owner is likely to experience a high remediation cost and a problematic resolution of liability claims.

Are you doing enough to proactively manage the environmental exposures in your building? Call one of the environmental due diligence experts at August Mack Environmental.

Implementing an Environmental Management System (EMS) at your company can be extremely beneficial by providing a general framework for organizing the tasks for effective environmental management. Additionally, implementing an EMS can have the following benefits:

• Integrates existing environmental programs
• Creates an orderly process for understanding and meeting regulatory requirements
• Integrates environmental issues into mainstream business activities
• Reduces risks associated with environmental issues
• Builds an engine of continuous environmental performance
• Improves environmental performance
• Enhances image with public, regulators, lenders and investors
• Increases efficiency/reducing costs

• Entry Supervisor 
• Attendant
• Authorized Entrants

In the in-situ remedial technology of soil vapor extraction (SVE), the following occurs:

• Vacuum is applied to the unsaturated zone through extraction wells.
• Vacuum causes movement of vapors toward extraction wells.
• Volatile constituents are removed through the extraction wells.
• The extracted vapors are discharged to the atmosphere.

• Proven performance; readily available equipment; easy installation; agency approved.
• Minimal disturbance to site operations.
• Short treatment times (usually six months to two years under optimal conditions).
• Easily combined with other remedial technologies.
• Can be used under buildings and other locations that cannot be excavated.

The disadvantages of in-situ SVE are the following:

• Concentration reductions greater than about 90 percent are difficult to achieve.
• Effectiveness less certain when applied to sites with low-permeability soil or stratified soils.
• May require costly treatment for atmospheric discharge of extracted vapors.
• Air emission permits generally required.
• Only treats unsaturated-zone soils; other methods may also be needed to treat saturated-zone soils and groundwater.

The Safety and Environmental Base Module is the foundation of eCAP^®. This module is designed to provide ongoing solutions to environmental compliance requirements. It provides routine interaction with the environmental compliance consultant experts and plant personnel to ensure consistent environmental regulation compliance and program improvement. This can be accomplished at three levels: program development, program implementation and compliance monitoring. In addition, training can be provided to employees to establish an understanding of the facility’s environmental, health and safety mission. At least one of these options are required and selections of additional options is dependent upon the facility’s compliance needs.

• Asbestos can present time and cost constraints
• Asbestos can require ongoing management
• Construction inspections are required prior to renovation and demolition activities
• Asbestos abatement costs can be expensive

• 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
   

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

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.

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

Since its inception in 1999, eCAP^® has been implemented for more than 100 clients throughout North America. When trying to determine the top benefits of eCAP, we asked our clients what they thought and four top benefits were mentioned: file organization, fixed cost structure, technical expertise and preservation of institutional knowledge.

Building owners and managers should keep in mind the following asbestos management requirements:

• Training - Maintenance and custodial (housekeeping) personnel must be trained regarding asbestos if they will be working adjacent to asbestos or asbestos dust
  • 2-Hour Asbestos Awareness Training - Required for maintenance and housekeeping personnel that will be working adjacent to asbestos at no cost to the employee.
  • 16-Hour Asbestos O&M Training - Required for maintenance personnel that perform Class III work (repair and maintenance where asbestos will be disturbed.
• Exercise due diligence to identify asbestos containing materials (ACMs) before disturbing any potential ACMs
• Always investigate the possibility of ACM which may included testing. Do not rely on the word of any person regarding the presence or absence of asbestos.

Since ISO 14001 is a voluntary program, companies tend to choose to participate or not participate based on internal or external driving factors. Some of the drivers for a facility to become ISO 14001 include the following:

• Corporate Policy
• Regulatory Expectations
  • Anticipated Benefits
  • Improved Compliance
• Cost Reductions
• Market Focus
  • Customer Requirements
  • Public Relations Pressures

The two types of confined spaces are a permit-required confined space and a non-permit required confined space. A permit-required confined space is a a space with the following characteristics:

• Large enough for an employee to enter and perform work
• Has limited or restricted means for entry and exit
• Is not designed for continuous employee occupancy
• Plus one or more of the following characteristics:
  • Contains, or has the potential to contain a hazardous atmosphere
  • Contains material with the potential to engulf the entrant
  • Has an internal configuration that may trap, disorient, or asphyxiate an entrant by changing wall configurations or smaller cross sections
  • Contains any other recognized safety or health hazard.

The Ex-Situ removal and disposal cleanup technology results in the following:

• Contaminated soils are removed by physical excavation from the ground
• Source area of contamination is eliminated
• Soils need to be profiled through an appropriate landfill
• Removal technique requires extensive pre-planning and scheduling
• Confirmatory soil samples are collected around the excavation to confirm effectiveness

• It is effective on all soil types
• It is an agency accepted cleanup method
• The timeframe for cleanup is short
• It removes potential contributors to groundwater impacts

• Must understand full extent of impacts
• Disruptive to site operations
• Depth limitations
• Challenging with shallow groundwater present
• Impacts may have to remain under structures and utilities and along property boundaries

Potential safety issues with an open excavation in a populated area.

Since its inception in 1999, eCAP^® has been implemented for more than 100 clients throughout North America. When trying to determine the top benefits of eCAP^®, we asked our clients what they thought and four top benefits were mentioned: file organization, fixed cost structure, technical expertise and preservation of institutional knowledge.