The Chemical Safety Board (CSB) has issued a safety alert regarding emergency pressure relief systems as the agency is continuing to see them playing their part in major chemical incidents.
Who is the CSB?
The CSB is an independent federal agency who investigates the root causes of chemical incidents at industrial sites such as chemical plants, refineries, and manufacturing facilities. They are not a regulatory agency, but their teams of investigators make recommendations to OSHA and EPA, industry groups and the facilities they investigate.
In addition to investigation reports and root cause analyses, CSB issues safety videos on both their website and YouTube that summarize the important findings from their investigations in order to help prevent similar accidents from reoccurring.
Emergency Pressure Relief System Issues
In its investigations, CSB is continuing to find issues with the safety of emergency pressure relief systems. In several of their investigations these systems were found to be discharging toxic or flammable materials to areas which were not safe for workers or the public.
Emergency pressure relief systems are devices installed on storage tanks, silos, vessels and processing plant equipment to help relieve the excessive pressure caused by fire, process failure, equipment failure or some other change in condition. The pressure relief device is supposed to prevent the equipment it’s installed on from rupturing or exploding.
One of the most well-known accidents involving an emergency pressure relief system was the Union Carbide disaster in Bhopal, India in the 1980s. A runaway reaction generated high pressure conditions in a storage tank and a methyl isocyanate cloud escaped from the pressure relief system, killing 3,800 people, and injuring or creating long-term illnesses for tens of thousands.
Three Key CSB Suggestions
CSB recommends that rather than discharge into the air or back into the plant, emergency relief systems should discharge to a flare or a scrubber system.
CSB offers three key lessons from its findings:
Follow Existing Good Practice Guidance
Use API 521, Pressure-relieving and Depressuring Systems as a standard guidance. CSB says this document “…addresses many concerns about releasing flammable vapors directly into the atmosphere and generally requires using inherently safer alternatives for toxic release scenarios or when the potential exists for a flammable vapor cloud.”
CSB also recommends documents published by the Center for Chemical Process Safety (CCPS) called Guidelines for Pressure-relief and Effluent Handling Systems and Safe Design and Operation of Process Vents and Emission Control Systems as well as viewing American Institute of Chemical Engineers (AIChE) presentations and courses on Venting and Emergency Relief.
Evaluate Whether the Atmosphere is the Appropriate Discharge Location or if There May Be Safer Alternatives
CSB typically recommends flaring is safer than atmospheric vent stacks when venting flammable vapor into the atmosphere. Something like flammable hydrocarbons can cause a fire or a vapor cloud explosion when they are vented into the atmosphere. CSB recognizes flaring is safer, but does allow for venting into the atmosphere in special cases, especially when that venting will not put workers or the public at risk.
Ensure Hazardous Chemicals Vented Into the Atmosphere Discharge to a Safe Location
Where are the discharge points on your emergency pressure relief systems? Are they at areas where they can harm workers within its proximity at ground level or on walkways or platforms? Are they near building intakes? If your company is subject to Process Safety Management (PSM) requirements, CSB says the required periodic reviews would be a good time to evaluate these issues as well as other audits or incident investigations.
Read the Report
Find CSB’s report, along with four case studies and their resulting recommendations at https://www.csb.gov/assets/1/6/csb_eprs_alert.pdf.
In an era where environmental consciousness is at the forefront, businesses must ensure they meet and exceed environmental compliance norms. As leaders in Environmental, Health, and Safety (EHS) services, iSi is committed to guiding you through the intricacies of environmental compliance.
Decoding Environmental Compliance
Environmental compliance refers to the adherence to environmental laws, environmental regulations, standards, and other requirements such as site permits to operate. Non-compliance can lead to severe penalties, including substantial fines and potential operational shutdowns.
The Importance of Environmental Audit Reports
Environmental audit reports are essential tools for assessing a company’s environmental performance. These reports provide a comprehensive picture of how well a business adheres to environmental rules, helping identify possible environmental issues and areas for improvement.
The Role of an Environmental Compliance Audit
An environmental compliance audit evaluates a company’s adherence to environmental laws and regulations. It assesses the effectiveness of the company’s environmental management systems, providing a detailed overview of the company’s environmental impact.
Unpacking the Audit Checklist
Creating an audit checklist for an environmental audit can be daunting due to the extensive range of factors involved. However, our expertise allows us to distill this process into key areas that should be your primary focus:
1. Regulatory Requirements: Ensure your business is aware of and complies with all relevant local, state, and federal environmental laws and regulations. This includes rules related to air quality, water quality, waste management, and hazardous materials.
2. Environmental Permits: Verify that all necessary environmentally focused permits are current and that operations are within permit conditions. This could include discharge permits, emission permits, or waste disposal permits.
3. Waste Management: Review waste management practices to ensure hazardous and non-hazardous waste is correctly identified, stored, transported, and disposed of. This is particularly important under acts like the Toxic Substances Control Act.
4. Emissions Control: Check that all emission control systems are functioning correctly and comply with required standards.
5. Record Keeping: Ensure all necessary records, reports, and documentation related to environmental compliance, including employee training records, are properly maintained and readily accessible.
6. Employee Training: Confirm that all employees have received appropriate training regarding environmental compliance responsibilities.
7. Emergency Preparedness: Evaluate your company’s preparedness for environmental emergencies and ensure there is an emergency response plan in place.
The Depth of Functional Environmental Audits
Functional environmental audits assess the effectiveness of a company’s environmental management system. These audits evaluate various aspects, such as air quality monitoring, wastewater management, materials management, and compliance monitoring.
Understanding Environmental Laws
Environmental laws are designed to mitigate environmental harm by regulating activities that impact the environment. They cover a broad range of areas, from air and water quality to waste disposal and hazardous materials.
The Role of Regulatory Agencies
Regulatory agencies enforce these laws and regulations. They play a crucial role in issuing environmental permits, monitoring compliance, and taking enforcement action when necessary.
The Impact of a Company’s Environmental Performance
A company’s environmental performance has significant implications for its reputation and bottom line. High environmental performance can lead to cost savings, improved stakeholder relations, and enhanced market opportunities.
The Importance of a Detailed Regulatory Checklist
A detailed regulatory checklist is an invaluable tool for ensuring compliance with environmental rules and regulations. This checklist provides a structured approach to identifying potential compliance issues and addressing them effectively.
Final Thoughts on Environmental Compliance
In conclusion, an environmental compliance audit is not just a formality but a vital part of your business’s sustainability strategy. With this comprehensive checklist and iSi by your side, you can navigate the complexities of environmental compliance with confidence and ease.
At iSi, our focus is not just on helping businesses meet environmental standards but also on fostering a culture of sustainability and responsibility. We believe that environmental compliance is not just a box-ticking exercise but a commitment to our planet and future generations.
Choose iSi for your environmental auditing needs, and let’s work together to create a safer, healthier, and more sustainable world. Contact us today to learn how we can help you achieve EHS excellence.
How Can We Help? Ask a Question or Request Info or Pricing
Do you need an idea of where you stand with EPA or OSHA regulations? Do you need full-time or temporary personnel to manage the day-to-day compliance tasks? Would your employees benefit from onsite environmental training? Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!
There are two types of audits: manual and automated.
A waste audit can be conducted in a variety of ways, depending on the organization and its goals. Generally, there are two types of audits: manual and automated. Manual waste audits involve sorting through garbage bags or dumpsters to determine what is being thrown away. Automated audits use sensors or other technology to track the types and quantities of waste that an organization produces.
The resulting data from waste audits can be used to develop a better understanding of the organization’s waste stream and how it can be improved. The data can also help organizations make informed decisions about their purchasing practices, lead to more efficient processes and identify cost-saving opportunities.
How do you plan a waste audit in an organization?
A waste audit is an analysis of a company’s waste stream where you inspect waste management and then implement waste management protocols. It gives insight into the types and amounts of materials that are being sent to landfill and helps inform strategies to reduce, reuse, and recycle more effectively.
What are the steps involved in a waste audit?
To plan a successful waste audit in an organization, there are several steps that should be added to your waste audit checklist:
1. Select your team and plan a date for the waste audit.
Waste audits are useful for many reasons. They can provide facility managers and other stakeholders with important insights into the effectiveness of their current waste management practices and how they might be improved.
Waste audits can also help identify areas where more resources should be devoted to better manage waste, or where additional training or education is needed. By understanding the composition and volume of the waste generated, organizations can better understand how to reduce, reuse and recycle more efficiently and effectively.
Additionally, detailed audits can provide information about potential safety and health hazards within a facility’s regular waste stream.
What are the 7 principles of solid waste management?
The following are the seven principles that will effectively explain solid waste management:
Rethink
Refuse
Reduce
Reuse & recycle
Repurpose
Repair
Compost
Conclusion
Solid Waste Management is an important tool to reducing our environmental impact. By adding the 7 principles to the solid waste management checklist, we can begin to make a positive difference in the amount of waste generated and disposed of into the environment.
Rethinking how we purchase and use products, refusing those items that are not necessary, reducing the total amount of waste going into the environment, reusing and recycling items that can be either repurposed or repaired, and composting rather than throwing organic waste away are all effective methods of reducing our environmental impact without creating more waste.
By making small changes in our everyday lives, we can have a large impact on the amount of waste going into the environment. The way households and company disposes of waste will significantly aid in the improvement of the communities we live in as well as limit unnecessary waste in landfills.
What are the four criteria that the EPA uses to classify hazardous waste?
EPA’s (Environmental Protection Agency) regulations in the Code of Federal Regulations (40 CFR) identify four hazardous waste characteristic properties: ignitability, corrosivity, reactivity, or toxicity (see 40 CFR 261.21- 261.24).
As part of EPA compliance, company key members, facilities teams, and site management should identify, collect, and document all hazardous waste that is in their facility. Regular site visits and inspections helps determine is the hazardous waste management protocols are properly enforced and in good condition.
Steps following an waste disposal facility audit:
1. Determine whether the waste containers size and pickup frequency still match your needs. If your trash output changed, a different size or number of pickups could cost you less money. 2. Add recycling service to your plan. If you don’t have recycling bins as part of your waste removal plan, consider add it. 3. Set a goal for increasing your recycled waste rate. 4. Create recycling guidelines for meeting that goal and share them with your staff. 5. Set a goal for reducing the amount of waste in your largest categories. 6. Determine the steps to meet that goal and let your staff know. Implementation is key. 7. Identify any items you can reuse. For example, can you repair or recycle your electronics instead of purchasing new ones? Can you repurpose any of your packaging materials? 8. Decide on a timeline for meeting your recycling and reduction goals. One or two years usually makes sense. Plan to conduct another waste audit at that time to see if you met your goals.
What is Environmental Management System (EMS) auditing?
An Environmental Management System (EMS) audit is the process of assessing an organization’s compliance with ISO 14001:2015, the international standard for environmental management systems.
The audit assesses whether the organization has proper procedures in place to manage its environmental responsibilities, and if any corrective actions need to be taken for non-compliance.
An Environmental Management System audit can be conducted by internal or external auditors who analyze an organization’s operational procedures, documents, records and measurements against ISO 14001:2015 requirements.
The auditor will then report their findings and make recommendations on areas of improvement that need to be addressed. Achieving ISO 14001:2015 certification demonstrates that a company takes environmental responsibility seriously and is committed to reducing their environmental impact.
It also serves as a tool for continual improvement of environmental management system processes. A successful EMS audit is essential for an organization to remain compliant with ISO 14001:2015 standards and maintain their certification status.
Organizations looking to get certified under ISO 14001:2015 need to arrange for an EMS audit, in order to assess their current environmental management system and identify any areas that require attention as well as address significant environmental aspects. The auditor will also provide advice on ways to improve the organization’s EMS and suggest best practices.
A successful audit is essential for obtaining certification and achieving a high level of compliance with ISO 14001:2015 standards. To ensure a smooth audit process, organizations should have all necessary procedures, documents, records and measurements in place prior to the commencement of the audit.
Additionally, they should take the time to train their personnel on environmental policies and requirements so that they can answer any questions from the auditor.
What to expect during ISO 14001 audit?
The key stages of an EMS audit include:
– Preparation – development of the audit plan, followed by the assessment team’s familiarization with the requirements of ISO 14001:2015.
– On-site visits – review and analysis of documents, operating criteria, records and data, as well as interviews with relevant personnel.
– Reporting – summarizing of findings in a non-conformance report that identifies areas for improvement or corrective action.
– Follow up – implementing environmental management systems and the implementation of any identified corrective actions and verification that all issues have been addressed properly.
By completing these steps, organizations can ensure that their EMS meets the requirements of ISO 14001:2015 and is effectively implemented. Additionally, they can identify areas where processes or procedures could be improved to ensure continued compliance with environmental regulations.
Finally, an EMS audit can provide valuable insight into the environmental performance of an organization, helping them make informed decisions about how to reduce their impacts on the environment and save costs in the long term.
The environmental management system requirements are set in place to help each organization established environmental objectives and internal audits to aid in proper business processes incase of an unplanned external audit.
In addition to identifying issues and providing recommendations for improvement, a successful ISO 14001 audit should include education and training for relevant personnel in implementing the necessary corrective actions.
This will help to ensure that any changes or improvements identified as part of the audit process are properly understood and put into practice effectively.
Furthermore, regular audits help to ensure that any non-conformances are addressed in a timely manner and that the organization remains compliant with all applicable regulations. By undergoing periodic EMS audits, organizations can demonstrate their commitment to environmental responsibility and sustainability.
What are the basic requirements of ISO 14001?
Scope of the Environmental Management System
The organization’s activities, products and services should be clearly stated in the scope of the EMS.
This should include a description of the organization’s operations, processes, sites, departments, divisions, etc., to identify any associated environmental aspects or any adverse environmental impacts. Any legal or other requirements that must be addressed should also be specified.
Environmental Policy
The Environmental Policy outlines the organization’s commitment to protecting and enhancing the environment, as well as meeting all legal requirements.
Evaluation of Environmental Risks and Opportunities
Risks and opportunities should be identified, evaluated, monitored and managed in order to minimize the environmental impact of the organization or to identify any significant environmental aspects. This will involve collecting data relating to environmental performance indicators such as air quality, water usage, waste production and energy consumption.
Evaluation of Environmental Aspects
Businesses have a responsibility to put in place measures to reduce the environmental impacts of their activities. This involves assessing what impacts are created and putting in place sustainable practices that minimize or eliminate them.
Examples of such practices include reducing energy consumption, waste minimization, reusing materials and resources, and exploring renewable energy sources. Additionally, businesses must stay abreast of environmental regulations and laws, as failure to comply with these can lead to substantial financial penalties.
Environmental Objectives and plans for achieving them
The environmental objectives of your organization should be realistic, achievable and measurable. They should also cover both short-term and long-term goals for the business.
To ensure that these objectives are achieved, it is essential to have a structured plan in place with clear steps toward achieving each one as well as keep maintained documented environmental objectives for all relevant interested parties.
Operational Control Procedures
Organizations must take responsibility for setting their own operational controls to ensure that they meet the requirements of ISO 14001.
The standard provides guidance on how organizations should go about this, including defining and documenting relevant internal procedures; assessing environmental objectives; conducting risk assessments; and identifying any training needs.
When it comes to implementing these operational controls, organizations need to ensure that they are appropriate for the sector they operate in and take into account any relevant legal or compliance requirements.
Furthermore, organization should review these controls regularly to ensure that they remain effective and address any changes in legislation or industry practices.
Procedure for Emergency Preparedness and Response
With an emergency plan, your organization will be able to respond appropriately and effectively in the event of an environmental emergency. A well-developed plan should include clear roles and responsibilities for staff, methods for communicating with stakeholders, and a system for evaluating the effectiveness of response measures.
List of Interested Parties, Legal and Other Requirements
In order to ensure a successful management system, it is essential that the needs and expectations of all interested parties are taken into account. Understanding these interests provides an insight into how the organization’s operations can contribute positively to the wider environment.
Competence records
Recording the training and competence levels of every member of your organization is an important part of introducing and managing an EMS. A successful EMS requires all staff to have a good understanding of their environmental responsibilities.
Evidence of Communication
Internal and External communications are also a key part of your management system. You can use external communications to inform people in the community or industry about your environmental objectives, progress reports on performance metrics, initiatives you have introduced and successes achieved.
This will demonstrate to stakeholders that your organization is committed to environmental improvement and accountable for its actions.
Monitoring Performance Information
In order to demonstrate continual improvement, your organization must measure its performance and effectiveness in relation to the objectives of ISO 14001. It is important to have a record of these evaluations so that you can track the progress made toward achieving those objectives.
Compliance obligations record
It is essential to stay up-to-date with all legal environmental requirements that your organization is subject to. This can be achieved by carrying out a competent evaluation of applicable laws and regulations and conducting regular reviews to ensure the record is accurate and current. Additionally, it should also be documented any obligations your organization has to other parties.
Internal Audit Program and Results
A regular internal audit of your EMS is essential for its ongoing effectiveness and the overall environmental performance of your organisation. An audit can help to identify any issues or opportunities for improvement that have been overlooked, as well as demonstrate compliance with processes set up as part of implementing an EMS.
Management Review Results
The results of a management review should be used to identify areas for improvement, as well as any corrective and preventive actions necessary. Furthermore, senior management should also provide feedback on the effectiveness of corrective and preventive action taken in response to the review results.
Nonconformities and Corrective Action
It is important that root cause analysis is conducted to identify the source of the nonconformity. This should include a review of any relevant documentation, as well as an examination of processes and/or procedures which may have contributed to the issue. Once a root cause has been identified, corrective action can be taken to prevent recurrence and ensure compliance.
The corrective action should be documented clearly in your records, including the specific steps taken to ensure the environmental management system conforms to the new policy.
This should include details of any training or process modifications that have been implemented, as well as any changes to procedures and/or equipment used. You should also identify the individuals responsible for each stage of the process.
What are the 3 C’s of ISO 14001 EMS auditing?
Conformance
Consistency
Continual Improvement
What are the mandatory records for ISO 14001?
The mandatory records of ISO 14001 include: Records of competence, awareness, and training.
These records are essential to your environmental management system, as they provide evidence that those involved in the system are adequately trained and aware of their responsibilities.
They demonstrate to regulators and other stakeholders that you have taken steps to ensure that everyone is well informed on how to reduce your environmental impact. Records may include details of courses attended, training materials such as manuals or handouts, and any assessments made about an individual’s knowledge or ability.
Additionally, these records should be regularly updated so that you can track changes in personnel and keep up with advances in technology or processes.
By maintaining a clear record of who has been trained, when they were trained, and what specifically was addressed during the training session(s), you will be able to ensure that all parties understand their roles and remain up-to-date on the latest regulations and best practices.
Additionally, these records provide a basis for continuing improvement in your environmental management system by allowing you to identify gaps or areas where more training may be needed.
How do I audit a ISO 14001 checklist?
In order to achieve ISO 14001 certification, organizations must first develop an environmental policy that contains a commitment to continual improvement and compliance with applicable laws.
The organization must also create objectives and targets for their EMS. These should be aimed at reducing the company’s negative impact on the environment and can include such areas as energy efficiency, waste management, water conservation, emissions control, and pollution prevention.
The next step is to assess any existing environmental impacts of the organization’s operations. This assessment should identify risks or opportunities associated with environmental issues in order to develop mitigation strategies or take advantage of potential benefits.
Once these steps are completed, the organization needs to develop procedures related to all aspects of their environmental activities. These procedures ensure that employees are aware of their responsibilities and know how to handle environmental issues. The organization must also put in place a system for monitoring, measuring, and evaluating the performance of its EMS.
Finally, organizations must provide training to employees on the content covered by their environmental policy and procedures. They should also strive to continually improve their EMS by setting new goals or expanding upon existing objectives.
Doing so will help them maintain ISO 14001 certification while also reducing their negative impacts on the environment.
In summary, ISO 14001 provides organizations with an internationally recognized framework for designing, implementing, and improving an effective environmental management system that can be certified for.
Need Help?
iSi’s safety audit team can help you determine where you stand on compliance with OSHA regulations and provide a prioritized list of findings. Contact us today to learn more about our audits!
The modern world is a sustainable one. It’s time for your business to join the ranks of those who are making a difference.
Sustainability has become one of the most important topics of our time. As the world becomes more and more aware of the environmental, social, and economic challenges we face, more and more businesses are looking for ways to operate in a more sustainable way.
That’s where sustainability consulting comes in. A sustainability consultant helps businesses identify opportunities to operate in a more sustainable way. This can mean anything from reducing energy consumption to increasing employee engagement in sustainability goals.
Sustainability consultants come from a variety of backgrounds, but all share a common goal: to help businesses move towards a more sustainable future with sustainability services.
The good news is that sustainability consulting is one of the fastest growing industries in North America and the world. The bad news is that it can be hard to know where to start when it comes to finding a sustainability consultant that’s right for your business.
Here are four tips to help you find the right sustainability consultant for your business:
1. Define your sustainability goals and ESG strategy.
What does your business want to achieve by working with a sustainability consultant? Do you want to reduce your carbon footprint in your global business? Develop more robust sustainability strategies? Achieve sustainable development goals? Incorporate sustainability solutions and a sustainable infrastructure into your business strategy? Improve employee engagement? Need risk management? Find ways to save money.
Once you know what you want to achieve, you can start looking for consulting firms that specialize in those areas.
2. Identify a budget.
Do your sustainability ambitions match resources available for the project? Does the ESG (Environmental Social and Governance) strategy align with your corporate growth strategy?
It is recommended to present a sustainability strategy internally, that outlines tiers of investment and the types of sustainability performance to be expected per expenditure.
3. Do your research.
Do a deep dive in the sustainability consulting services universe. Once you’ve identified some consulting firms that might be a good fit, take some time to learn about their backgrounds and experience and nail it down to your favorite consulting firm.
How long have they been working in a sustainable business? What are some of the clients they’ve worked with? What do other people say about them? Top consulting firms offer diverse corporate responsibility solutions and professional services across a wide swathe of industry sectors.
4. Ask for recommendations.
Talk to other businesses in your industry and see if they’ve worked with any sustainability consulting firms that they would recommend. If you know someone who works in sustainable business, ask them for their thoughts on different consultants.
The best way to find a good consultant in the large world of the consulting industry is through word-of-mouth from people who have worked with them before.
A global management consultancy will have the general pulse on corporate social responsibility. Top sustainability consulting firms will be a global leader in change management and integrated business planning.
The best ones possess deep expertise in the management of business risk and climate risk, while working with you to embed sustainability into your culture.
These days, there’s no excuse for not being sustainable, not manage risk, and not create sustainable business models.
Future leaders and businesses that don’t take steps to operate sustainably will not only be missing out on opportunities and losing business value, but will also be left behind as society progresses towards a more sustainable future.
These can be complex problems. Sustainability consulting is one of the best ways for businesses to make sure they’re operating sustainably and making a positive impact measurement on the world around them.
iSi Environmental is a leading provider of environmental consulting and management consulting services in the United States and we are committed to protecting the planet and its inhabitants with the skills and knowledge of our people. With us you get long term value.
Senior Executives and Sustainability Teams turn to us when:
Their team is short on time and resources to achieve organizational sustainability strategy
They need hands-on implementation of new compliance processes
They need to integrate sustainability at multiple locations
Also turn to us when looking to roll local best practices into a global corporate system
At the recent KDHE Environmental Conference, Dave Cozad, Director of the Enforcement and Compliance Assurance Division with Region VII EPA gave an update outlining EPA’s upcoming compliance and enforcement priorities.
Compliance Inspections & Public Posting of Reports
EPA was scheduled to go back out to do more onsite inspections, but the resurgence of COVID put a delay on that. For the past year they had been doing some announced remote inspections to evaluate compliance. However, unannounced inspections will eventually resume. Inspectors will have Smart Tables preloaded before they go onsite. Their goal is for the report of findings be available in less than 60 days after inspection.
One important comment made was that EPA is working on implementing the public posting of inspection reports. That is, what is found at your site during an inspection and what’s on your report will eventually be available for anyone to see.
Executive Orders Provide Roadmap
EPA has been given several directives through Executive Orders (EOs), and the issues EPA will focus on will very much be related to these.
These EOs include the following guidelines:
Hold polluters accountable, including those who disproportionately harm communities of color and low-income communities.
Strengthen and enforce environmental violations with disproportionate impact on underserved communities
Create a community notification program to monitor and provide real-time data to the public on current environmental pollution
Strengthen enforcement in communities with environmental justice concerns
Tackle climate change and enforcement of climate change-related issues
The term “environmental justice”, or EJ, goes along with these directives and will be applied to daily decision making. To meet the directives, EPA will be spending more of their time looking at regulated industries in these underserved communities and will be strengthening enforcement of violations for cornerstone environmental statutes and civil laws. Thus, the number of air, wastewater, and hazardous waste inspections in these areas will increase and items such as air monitoring results may be posted for the public to review.
EPA plans on going into these areas and speaking with the people about their enforcement case concerns rather than just determining themselves what EPA thinks they need, as they historically have done.
In the area of climate change, they’ll be targeting cases with greenhouse gas-related requirements and a ban on importing hydrofluorocarbons. Climate-focused mitigation and resilience will be a part of the efforts. For example, taking a look at situations like floods where there are chemical plants in floodplains or where sewer systems could have major overflows.
National Compliance Initiatives
National Compliance Initiatives are set goals that follow a certain process and include the states. Because of this, they are much harder to change from administration to administration. Some of these have been initiatives for the past 2 years, but give an idea of certain targets of inspections.
RCRA Air
This is hazardous waste emissions via air, where there are regulations related to the quantity of VOCs emitted. This is for facilities with tanks, surface impoundments and valves. Inspectors have started making a concerted effort to look at these during their inspections and it’s one of the lesser items focused on by some facilities. Right now 30% of facilities being inspected are not complying with this part of the regulation, and the fines can be $255,000. What is RCRA Air? Learn more here.
Chemical Accident Reduction – RMP
EPA will be checking that Risk Management Plans are in place and implemented properly for those that are required to have them. This is related to Clean Air Act section 112(r) for the prevention of accidental releases of chemicals. Facilities that store and handle large quantities of listed regulated substance in a process, over certain threshold amounts. EPA inspection data is showing that 50-75% of facilities are not complying fully with RMP.
Creating Cleaner Air for Communities and Drinking Water
We listed these 2 initiatives together because they will be treated similarly under the umbrella of EJ. Making air and water cleaner has always been a goal, but considering the EOs, a focus on issues with public water systems, lead-based paint and air emissions from inner-city factories helps EPA accomplish more than one goal. Plus those kinds of issues will affect a large amount of people at once. It becomes a more bang for their buck item, so to speak.
Mobile Source Aftermarket Defeat Devices
EPA is looking to conduct enforcement on companies who make, develop and sell aftermarket devices that bypass, defeat or renders inoperative any emission control device in order to enhance engine performance. Examples would be plates that partially block a portion of exhaust gas stream, kits that enable the removal of the catalytic converter or the diesel particulate filter or tuners that stop signals from going to the vehicle’s computer that usually would turn on the check engine light or put the vehicle in limp mode. EPA’s news updates have been announcing fines for a number of companies recently for violations so this initiative is up and running.
NPDES Permit Compliance
EPA is looking to reduce the significant non-compliance they’re seeing with National Pollutant Discharge Elimination System (NPDES) permits. In an EPA memo to regional administrators regarding this initiative, they identified they wanted to reduce the noncompliance baseline rate by 50% by the end of FY 2022, while assuring that the worst violators are timely and appropriately addressed.
EPA wants its regions and states to work together. Each state’s rate will be looked at as will its approaches (past and future) to reduce the non-compliance rate, the completeness and accuracy of its compliance data (and why it’s wrong/missing), and how and when they plan on addressing the more severe non-compliance violations.
Over 60% of the non-compliance is attributed to “non-receipt” of Discharge Monitoring Reports (DMRs). Interestingly, EPA speculates that some of this isn’t all about companies not turning in their reports, but the way the states communicate or handle getting the information into the EPA’s tracking system. However, make sure you get your DMRs in as this is something that’s on the radar.
If any of these initiatives can be tied back to those EOs, then all the better for EPA and their compliance goals. For example, in the press release announcing a settlement for one of the companies found selling mobile defeat devices, part of the settlement was for the company to “…replace 3 school busses in a Columbus, OH in the areas of environmental justice concern.” In that same release, the regional administrator said she was “…pleased that the settlement will reduce the impact of pollution in already overburdened neighborhoods.”
EJScreen
EPA has a screening and mapping tool to help them identify areas that may be candidates for environmental justice-related consideration, outreach or programs. EJScreen is considered to be “…a consistent tool that can be used by EPA, its governmental partners and the public to understand environmental and demographical characteristics of locations throughout the United States.”
EJScreen was actually developed in 2010 as a response to an Executive Order by the Clinton Administration. It is geared to help users identify areas with minority/low income populations, potential environmental quality issues and places where environmental and demographical indicators are greater than usual. EPA plans to use EJScreen to implement permitting, enforcement, compliance, outreach and enhance geographically-based initiatives. Facilities who lie within an EJScreen target area will be the ones who will receive the most inspections.
Other compliance hot topic/focus areas mentioned on EPA’s radar include:
Children’s health, mainly related to lead
Generators without proper status/notifications
Asphalt plants using mine tailings from CERCLA sites
PFAS
“Recycling” facilities
Coal combustion residuals
Potential return of supplemental environmental projects
EPA budget and staffing
Do you see any issues here that may be affecting your company? Or are you unsure which ones may affect you? Contact iSi today for EPA and state environmental compliance assistance and advice!
A member of our Consulting Services division, Bria works with client facilities for annual environmental reporting and day-to-day environmental compliance assistance. She also manages iSi project managers. Bria has conducted well over 100 Phase I environmental site assessments for iSi and is one of the trainers for our Hazardous Waste Management class.
