Some of you may know what a cooling tower is and many of you may have no idea. Regardless whether you know what it is, many facillities have one or more cooling towers at their facility. So, why is that important to environmental compliance? In certain areas of the country (depending upon their water quality), the pH of the water in the cooling tower is controlled by adding sulfuric acid. This is where the environmental compliance issues come in. If you have the sulfuric acid in a 55-gallon drum, then it weighs in excess of 500 pounds. Since sulfuric acid (the typical grade used for cooling tower pH control) is an extremely hazardous substance (EHS), you must complete the annual Tier Two report which is an environmental regulatory requirement. There are many other chemicals/substances that may require you to complete a Tier Two report but this one is often overlooked. Click on the link to see a list of chemicals/substances that have environmental reporting implications:
http://www.epa.gov/ceppo/pubs/title3.pdf
The attached link describes chemicals related to a variety of environmental rules. If you do not have an Environmental Compliance Specialist on your staff, feel free to call me (317.916.3105) to learn more about these rules. If you perform an environmental compliance audit, a review of Tier Two requirements should be part of that process. The end result of an audit ought to be a list of environmental compliance solutions and not just a list of problems.
http://www.epa.gov/ceppo/pubs/title3.pdf
The attached link describes chemicals related to a variety of environmental rules. If you do not have an Environmental Compliance Specialist on your staff, feel free to call me (317.916.3105) to learn more about these rules. If you perform an environmental compliance audit, a review of Tier Two requirements should be part of that process. The end result of an audit ought to be a list of environmental compliance solutions and not just a list of problems.
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