Hello! My name is Chuck Staehler and I am the Compliance Department Manager and a Senior Engineer in the Indianapolis, Indiana office of August Mack Environmental, Inc. I have more than 25 years of engineering experience in regulatory environmental compliance audits, NPDES industrial discharge permits, regulatory negotiations, NPDES storm water permitting, design and installation of air pollution control systems, preparation of air permits in accordance with the Clean Air Act, industrial ventilation surveys and system design, dispersion modeling, BACT/MACT analysis, compliance monitoring plans, landfill design as well as the development of waste minimization plans in accordance with RCRA requirements. I plan on using my extensive experience in working with industrial facilities on environmental compliance to serve as the basis for my blog. I hope you enjoy what you read and if you have any questions, please do not hesitate to contact me at 317.916.3140 or via e-mail at cstaehler@augustmack.com.
OSHA Updates Guidance on Laboratoy Hazardous Chemical Exposure
Monday, February 18, 2013 by
Chuck Staehler
A non-mandatory technical amendment taking effect Jan. 22 explains the basics of ensuring safe operations and discusses the roles of the chemical hygiene officer and others.
OSHA is has issued a technical amendment to the non-mandatory appendix in its standard on occupational exposure to hazardous chemicals in laboratories, 1910.1450, which is known as the OSHA Laboratory Standard. Published Jan. 22 in the Federal Register, the amendment takes effect upon publication. It was made in order...
Read More »Required Topics of Chemical Hygiene Plan
Friday, February 8, 2013 by
Chuck Staehler
OSHA has issued a technical amendment to the non-mandatory appendix in its standard on occupational exposure to chemicals in laboratories. The amendment says a lab's Chemical Hygiene Plan must be readily available to workers and should include these topics:
- Individual chemical hygiene responsibilities
- Standard operating procedures
- Personal protective equipment, engineering controls and apparel
- Laboratory equipment
- Safety equipment/
- Chemical management
- Housekeeping
- Emergency procedures for accidents and...
US EPA to Review Existing Environmental Rules
Tuesday, August 16, 2011 by
Chuck Staehler
The US EPA intends to review 31
current regulations to determine if the regulations are
duplicative, outdated or overly burdensome. These regulations
apply to a wide range of environmental media.
The US EPA has indicated that many of the
environmental rules identified for change will involve
technological advances made over the past 40 years. The
US EPA will seek to advance the following
initiatives: electronic reporting, improved transparency,
innovative compliance approaches and systems...
Read More »New and Additional Reporting Under the Toxic Substances Control Act
Tuesday, August 9, 2011 by
Chuck Staehler
The US EPA is publishing its
rule to require more environmental compliance reporting of
chemical information. This rule increases the amount of
information that chemical manufacturers/importers must
provide the US EPA regarding the potential risks that the chemical
poses to human health and the environment. The rule is called
the chemical data reporting rule (CDR rule) and falls under
the Toxic Substances Control Act inventory update rule
(IUR). The rule also requires...
Read More »Deep Well Injection
Monday, August 8, 2011 by
Chuck Staehler
Deep well injection is a liquid
waste disposal tool. Waste (nonhazardous or hazardous) is
injected in underground sites where there is no chance that the
waste will come into contact with drinking water. These types
of wells are typically thousands of feet deep and inject waste into
watertight rock formations. The forms of hazardous
waste usually disposed of in deep wells are saline wastes,
metals, cyanides, pickling wastes, and corrosives among
others. The US has five commercial deep well...
Read More »PSD review for sources of greenhouse gases
Friday, August 5, 2011 by
Chuck Staehler
Beginning on July 1, 2011 facilities can be subject to GHG
permitting requirements if:
The facility is subject to PSD for traditional regulated new source review (NSR) pollutants and greenhouse gas emissions exceed 75,000 tons per year of carbon dioxide equivalents
A new facility has potential greenhouse gas emissions in excess of 100,000 tons per year of carbon dioxide equivalents
An existing facility with potential greenhouse gas emissions of 100,000 tons per year or greater and with an...Read More »
The facility is subject to PSD for traditional regulated new source review (NSR) pollutants and greenhouse gas emissions exceed 75,000 tons per year of carbon dioxide equivalents
A new facility has potential greenhouse gas emissions in excess of 100,000 tons per year of carbon dioxide equivalents
An existing facility with potential greenhouse gas emissions of 100,000 tons per year or greater and with an...Read More »
Toxic Substances Control Act
Monday, August 1, 2011 by
Chuck Staehler
The Toxic Substances Control Act (TSCA) allows the US EPA to track
the 75,000 plus industrial chemicals currently produced or imported
into the United States. The US EPA screens these chemicals for
hazards to the environment or human health. The US EPA
can require the manufacturers or importers of these chemicals
to conduct testing on these hazards and report the findings
of the testing to the US EPA. The US EPA can
ban the manufacture or import of chemicals based upon the
hazards that these...Read More »
Common SPCC plan errors
Wednesday, June 8, 2011 by
Chuck Staehler
According to various sources, common SPCC plan violations include
the following:
- The SPCC plan did not have a signature of approval by management
- The SPCC plan was not certified by a Professional Engineer
- The SPCC plan lacks written procedures for inspections and for maintaining inspection records for 3 years
- the SPCC plan is not reviewed or updated every three years
- Personnel are not properly instructed in spill prevention procedures
- Compatibility of tanks with the material stored is not discussed in...
SPCC Plan
Tuesday, May 31, 2011 by
Chuck Staehler
August Mack prepares and updates spill prevention control and
countermeasure (SPCC) plans. One of the questions which keeps
coming up is how much freeboard should I have on
my outside secondary containment systems. The regulation
does not specifically spell out how much additional freeboard is
required in a secondary containment system. In the
preamble to the regulation, the USEPA stated "While we believe that
the 25 year, 24 hour storm event standard is appropriate for most
facilities and...Read More »
Universal Waste
Tuesday, May 24, 2011 by
Chuck Staehler
August Mack completes numerous
environmental and safety compliance audits each year. One of
the issues that keeps coming up in these audits is how do you
handle green tipped fluorescent lamps. Are the lamps
considered universal waste? Are they hazardous waste? The
manufacturers advertise that the lamps are environmentally friendly
and are not hazardous. The best way to make sure that the
lamps are not classified as hazardous waste is to obtain TCLP data
from the lamp manufacturer. If the...
Read More »Boiler MACT
Wednesday, May 18, 2011 by
Chuck Staehler
See attached link about Boiler:
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