Environmental Compliance Specialist

The Environmental Protection Agency (EPA) regulation of fugitive volatile organic compounds (VOC) emissions, or leaks, arose out of the research projects conducted between the 1950s and 1980s at several facilities throughout the United States. The research concluded the cumulative effect of all the leaking components may present environmental and health problems to the surrounding area. The research also concluded when most components leak, they do so at very low levels, thus a majority of fugitive emissions come from a very small percentage (not exceeding 10 percent) of high leaking components. The need for fugitive VOC emissions was also necessitated by the fact that approximately 70 percent of total VOC emissions from facilities engaging in processing of gases and light liquids arose from uncontrolled emissions.

To learn more about LDAR, click here to read an article written by one of the environmental compliance specialists at August Mack Environmental.

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.

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

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

If a confirmed release has occurred, Environmental Protection Agency (EPA) regulations require that an appropriate cleanup response, or Corrective Action, be conducted

The purpose of the corrective action process is to ensure that releases of petroleum and regulated substances do not threaten human health and the environment. The steps in the process are:

1. Release discovery and reporting
2. Initial Abatement
3. Investigation
4. Corrective Action
5. Incident Closure/No Further Action

• Proper and updated registration
• Compatibility (tank system & substance being stored)
• Annual tank fee payments
• Inventory & inventory reconciliation
• Corrosion protection system inspection & maintenance
• Release detection system inspection & maintenance
• Tank system tightness testing
• Record keeping
  • UST notification forms & proof of registration
  • Construction and installation details
  • Documentation of compatibility
  • Proof of tank fee payment
  • Documentation of tightness testing & results
  • Inventory records (monthly reconciliation)
  • Corrosion protection system inspection & maintenance records
  • Release detection system inspection & maintenance records
  • Documentation of repairs

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.

The benefit of file organization is a major component of eCAP^®. In our opinion, there cannot be an effective environmental management system (EMS) in place without proper organization, timelines, responsibility matrices, corrective action or accountability. With eCAP^®, one of the first tasks is to conduct a thorough file review. This environmental file review identifies which files (reports) are present and more importantly identifies which reports are not present. The eCAP^® program entails creating a web page that contains all, not some, not a few, but all of the required permits, monitoring logs, training records, report submittals, permit modifications and deviation reports required to demonstrate compliance. This allows our clients to have the necessary documentation at their finger tips.

An environmental compliance consultant specialist from August Mack Environmental is likely to ask the following questions regarding waste during the environmental compliance auditing process:

• What is their hazardous waste generator status (CESQG, SQG, LQG or TSDF)?
• Is all waste properly characterized (sludges, dust, etc.)?

• Review all record keeping, manifests and reports
• Inspect all satellite accumulation and hazardous waste storage areas
• Review Universal Waste program

An underground storage tank (UST) Systems may be closed voluntarily if owner or operator chooses, or by mandate if system is not in compliance with regulations.

The guidelines for a temporary UST closure are:

• Corrosion protection must be maintained
• If UST is temporarily closed for 3-12 months:
• Leave vent line open
• Cap and secure all other lines, pumps, equipment, etc.

Keep in mind that if an UST is temporarily closed for more than 12 months it must be permanently closed.

The guidelines for a permanent closure or changes in service are:
 

• Notify implementing agency 30-days before beginning closure or change-in-service
  • Empty tank and clean residual product/sludges
  • Remove from ground or fill with an inert solid
  • Perform UST closure assessment
• Before Closure or change-in-service is complete, owners and operators must measure for presence of contamination.
  • Sample types, locations, and methods dependent on site conditions
  • If contamination is identified, Corrective Action must be initiated

An environmental compliance consultant specialist from August Mack Environmental is likely to ask the following questions regarding SPCC Plan during the environmental compliance auditing process:

• Do they have or do they need a SPCC Plan?
  • Is it updated? Are they following it? Is it PE-certified? Does the plan have all of the necessary elements?
• Where are spill kits located?

• Review all record keeping
• Look at all oil storage areas
• Look at housekeeping

On May 13, 2010, the U.S. Environmental Protection Agency (EPA) issued a final rule to address air permitting of six greenhouse gases (GHGs). This final rule “tailors” the Clean Air Act (CAA) permitting program to limit which facilities are required to obtain a Prevention of Significant Deterioration (PSD) and/or Title V operating permit. The EPA will phase in the Clean Air Act (CAA) permitting requirements in two initial steps.

To learn more about the Greenhouse Gas Tailoring Rule, click here to read an article written by an environmental compliance specialist at August Mack Environmental.