Need Help Making Sure Your Business Is In Compliance?

You don’t know what you don’t know. With environmental regulations constantly changing it can sometimes feel overwhelming.  W&M’s environmental compliance experts can help guide you through the maze of regulations to show you where those gaps might be in your environmental program. A Regulatory Applicability Screen (RAS) is a quick and valuable service that provides our clients with a list of potential regulatory concerns ranging from Air permits, Water Supply, Wastewater, Stormwater, Hazardous Waste, and various other environmental reporting requirements.  In this list, W&M outlines the gaps and potential corrective actions that you could undertake to eliminate those gaps. The process begins with an information gathering meeting to understand the nature of the facility.  Then one of our environmental experts conducts the RAS to determine regulatory applicability and potential compliance gaps with U.S. Environmental Protection Agency (EPA) Resource Conservation and Recovery Act (RCRA) and other state and local regulations in the
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RAILROAD COMMISSION OF TEXAS BEGINS REQUESTING THE USE OF EPA METHOD FOR SOIL SAMPLING

The Railroad Commission of Texas (RRC) reportedly is starting to require the use of United States Environmental Protection Agency (EPA) SW-846 Method 5035A, as amended.  The method is also known as Closed-System Purge-and-Trap and Extraction for Volatile Organics in Soil and Waste Samples.  This is a method commonly used for the collection and preparation of solid samples for analysis of volatile organic compounds (VOCs) and total petroleum hydrocarbons (TPH) using purge-and-trap technology. No formal announcement has been made by the RRC concerning VOC or TPH data reported for solid samples collected and prepared using other methods. However, according to the Field Guide for the Assessment and Cleanup of Soil and Groundwater Contaminated with Condensate from a Spill Incident and Statewide Rules 8 and 91, standard methods are left undefined and implied that they are the industry standard and up to the district office or other RRC representative. Additionally, technical coordinator for the
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TRI – It’s Never Too Early to Start

July 1st will be here before you know it – so get started on your Toxics Release Inventory (TRI) reporting now. The TRI is an annual report required under the U.S. Environmental Protection Agency’s (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA). You are required to report if… Your primary NAICS code (formerly SIC) is listed or you are a Federal facility; and Have 10 or more full-time employees (equivalent of 20,000 hours/year); and “Manufacture”, “process” or “otherwise use” listed Section 313 chemicals in excess of their reporting threshold. If your facility meets the first two criteria, you will need to evaluate your chemical usage to determine if you exceed the reporting threshold. If yes, then either a Form A or Form R report must be submitted to the EPA and Texas Commission on Environmental Quality (TCEQ).  Even if you do not exceed the reporting thresholds, you should maintain documentation
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Real Time Reporting

Efficient data collection, flexible formats, and more accurate data in reports that are instantly accessible – those are just a few of the benefits of Real Time Reporting at W&M Environmental Group. The recently adopted system allows staff members in the field to input data directly into tablets and other portable devices, as it’s collected.  Real Time Reporting has proven particularly powerful when clients call on us to collect data or conduct site evaluations at multiple sites in remote locations for large projects. Some of the advantages of Real Time Reporting: *Faster Decision Making: With faster, real-time access to the data, as it’s collected, clients and decision-makers can track information our teams are collecting in their audits or investigations. There’s no waiting until the field personnel return to the office to enter and compile the information. Display options allow clients to map progress and visualize trends in the overall data on
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Understanding OSHA’s New NEP on PSM and EPA’s RMP Final Rule

Facilities that utilize a process that contains any listed (40 CFR 68.130) substances above the threshold quantity are required by the EPA (via the Clean Air Act) to develop and implement a Risk Management Program (RMP). Development of an RMP can be very simple for certain industries to extremely complex for those facilities with multiple regulated substances and processes. EPA’s goal is to prevent off-site impact to the general public. The OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) which focuses on worker safety appears to be the same as an RMP, however, there are key differences. The most important is that they both exist to protect different constituencies and to address different regulations. They also have different threshold limits and regulate different chemicals.  OSHA’s list of Highly Hazardous Chemicals can be found in 29 CFR 1910.119 App A. Reporting requirements are also different. For example, a plant may use over 15,000
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Environmental 101: Finding The Right Consultant

For real estate deals, the standard process for evaluating environmental risks is to conduct a Phase I Environmental Site Assessment (ESA) followed by a Phase II Investigation when a Recognized Environmental Condition (REC, suspected contamination) is identified. Typically, the first question a consultant receives when a Phase II is recommended is “how much?” followed by “can you do it cheaper?”  These are fair questions and I ask them myself with my CPA, handy man, painters, mechanic, etc. The big challenge for W&M is balancing the Phase II scope of work with costs. The bigger the scope (e.g., number of samples, chemical analyses, etc.), the higher the price will be.  Sure it would be nice if we could collect one “magic sample” but such a sample doesn’t exist.  I like to compare the sampling process to playing the board game Battleship.  We can make some educated guesses but don’t really know
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Great Tips On Environmental Reporting

Do Annual Waste Summaries, Air Emission Inventory, storm water, Tier II and TRI Reports give you headaches?  If so, watch our webinar on tips on completing accurate environment reports hosted by Heather Woodward. Topics include: Reporting Due Dates – On Time Completion Data Collection Techniques Common Reporting Mistakes Reporting Resources





W&M Played Investigative Role In Corpus Christi Water Crisis

W&M Environmental recently played a role in investigating the alleged release of an amine compound from an asphalt blending operation into the City of Corpus Christi’s potable water distribution system. A four day water ban was issued in Corpus Christi after a possible chemical release to the city’s water system. On December 14th, city officials placed a ban on using tap water for its 320,000 residents out of concern that hydrochloric acid and Indulin AA-86, a corrosive asphalt-emulsifying agent, may have entered the water system.  Municipal workers claimed that a backflow protection device was not found when searching for the possible source of the release from an industrial facility (others claimed there was one there, but it malfunctioned).  Such devices are required by the state at industrial sites to prevent water and/or waste from backing up into pipes that feed clean water when pressure in the system reverses. The TCEQ described the incident
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Annual Emission Inventory Reporting

W&M experts came together for a unique webinar discussing Annual Emission Inventory Reporting. They covered who needs to report, what needs to be reported, what changes there are, valuable tips for sufficient reporting, and ways to stay off the Texas Commission on Environmental Quality’s (TCEQ) enforcement radar concerning Emission Inventory Reporting (EIR). What Is The Annual Emission Inventory? An Emission Inventory is a comprehensive report to the TCEQ that summarizes a facility’s annual emissions of regulated air pollutants. Emissions are summarized for the calendar year (i.e.: January 1st through December 31st ) and must be reported no later than March 31st of the following year.  If a permitted source had no emissions for the calendar year, this must be included in the Emission Inventory report. There is no filing extension mechanism associated with this deadline.  Facilities reporting after the March 31st deadline are subject to TCEQ enforcement. Reporting is accomplished through the TCEQ’s
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Deal Making Strategies For Contaminated Properties

deal-making-strategies-presentation-final Have you or your client ever come across a property that would work great, but you had to walk away because the property was contaminated?  Michael Whitehead, Chairman of W&M Environmental can help you decide if walking away is a mistake or not.  He hosted a webinar, “Deal Making Strategies for Contaminated Real Estate in Texas” to help you through this process. Whether buying, selling or lending, this informative webinar can help you understand environmental due diligence and solutions for contaminated properties. The webinar will address the Phase I/II ESA process, Texas regulatory programs, and remediation/closure strategies (along with related costs). The webinar will also include an overview of Texas regulatory programs such as the Leaking Petroleum Storage Tank (LPST) program, Innocent Owner/Operator Program (IOP), Voluntary Cleanup Program (VCP), Corrective Action Program, and Municipal Setting Designations (MSD).