Brace yourself for March, it’s just around the corner.

For Environmental Health and Safety (EHS) Managers or professionals, the new year brings a new outlook on your job, promises to yourself and your company, and the desire for improvement over the past year. Unfortunately, the new year also brings the crushing realization that March is just around the corner, almost taunting you for becoming cocky in November and December when few environmental reports are due to the State or EPA. March marks the beginning of the annual reporting deadlines. The reporting calendar begins with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II report and the Annual Waste Summary (AWS) due March 1st, and then you dive right into the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) Benchmark Monitoring (BM) reporting and Discharge Monitoring Report, and the Air Emissions Inventory Report (AEIR), all due on March 31.  Individually the reports are not overly difficult or time
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Compliance Reporting: Don’t Let the Deadlines Sneak up on You


  • Compliance Reporting
    January 24, 2019
    11:30 am - 12:30 pm

As the new year comes, so does another opportunity to get it done right. Instead of avoiding the tedium of environmental reporting, dive in head first to prepare your reports accurately and punctually. Join us for our lunchtime webinar, hosted by Nick Foreman, covering the reports due in March: Annual Waste Summary Stormwater Benchmark Monitoring (more…)

Venue:  

Address:
Streaming From, Plano, Texas, 75074, United States





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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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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What To Know About Tier II Chemical Reports

The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 is a US federal law concerned with emergency response preparedness. Its objective is to encourage and support emergency planning efforts at the state and local levels, and to provide the public and local governments with information concerning potential chemical hazards present in their communities. The US Environmental Protection Agency (EPA) administers EPCRA which requires certain businesses to file notifications and reports on their activities involving various hazardous chemicals. Specific implementing requirements are found in Title 40 of the Code of Federal Regulations (CFR) Chapters 350 – 372. Hazardous chemical reporting is specifically required under EPCRA sections 311-312 to report chemical hazard and inventory information on the hazardous chemicals present onsite at any one time. EPA defines “hazardous chemical” as a “chemical which is a physical or health hazard.” The reporting thresholds for various categories of  hazardous chemicals shown below: The
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Waters of the U.S. – Webinar

W&M’s Aaron Brewer, P.G. conducted a  webinar to help explain the EPA’s new rule defining waters of the U.S. and wetland permitting.  The webinar gives you the basic know-how to define waters of the U.S. and secure a Section 404 permit for your project.  Those well versed in these practices will enjoy Aaron’s perspective from years of private practice. The Clean Water Rule redefining waters of the U.S. was briefly the law of the land in Texas.  This webinar will present the definition of the Clean Water Rule and what it will mean for Texas if it becomes law.  Given that “waters of the U.S.” is one of the most fundamental of environmental definitions affecting an array of environmental permits and protection of natural resources its worth taking the time to get it right.  If you have any question on this webinar please contact Aaron Brewer.





Implementing the Clean Water Rule In Texas

The EPA’s new rule defining waters of the U.S. (the Clean Water Rule) was briefly the law of the land here in Texas.  “Waters of the U.S.” is one of the most fundamental of environmental definitions because it effects an array of extensive legislation including Section 404 of the Clean Water Act and most developments that require filling a pond, wetland, or stream.  From August 28 to October 8, 2015, the new waters of the U.S. definition was in force, but not clearly understood.  It takes time and experience to find the true limits of a new legal definition.  The rule has been blocked by two courts putting off implementation of the new definition for now.  What is at stake in Texas? Here are three of the biggest issues that remain undecided while Texas waits to hear from the courts: 1. Tributaries Under the old rule, waters of the U.S. extended from a
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W&M Completes Toxic Release Inventory Reports

W&M finalized threshold determination analysis of Toxic Release Inventory reports for RY 2011 using the TRI-MEweb program for a client recently.  W&M also assisted in certifying client officials with registering for the EPA’s Central Data eXchange (CDX) program. We also prepared a Self-Disclosure letter for submission by the client to the U.S. Environmental Protection Agency (EPA) and are available to assist in any future correspondence with the EPA. For additional information please contact Heather Woodward.

W&M finalized threshold determination analysis of Toxic Release Inventory reports for RY 2011 using the TRI-MEweb program for a client recently. W&M also assisted in certifying client officials with registering for the EPA’s Central Data eXchange (CDX) program. We also prepared a Self-Disclosure letter for submission by the client to the U.S. Environmental Protection Agency (EPA) and are available to assist in any future correspondence with the EPA. For additional information please contact Heather Woodward.



W&M Speaks at Seminar for Texas Aggregates and Concrete Association

Heather Woodward, Technical Director for W&M, was a featured speaker at this year’s Texas Aggregate & Concrete Association Environmental and Sustainability Seminar last month in San Antonio, TX.  She spoke on classification and proper disposal of hazardous waste according to RCRA guidelines.  The talk was extremely well received with the attendees of the Seminar.  Eddie Saucedo, TACA Environmental Committee Chairman, commented that “This was the best talk on this subject that we’ve ever had.” The lecture was an abbreviated version of the 8 hour RCRA class that W&M administer throughout the year in Dallas, Houston and San Antonio. Jennifer Adams, Division Manager of the Austin office at W&M Environmental, has worked with the Aggregates and Ready Mix industry for 9 years.  She knows a challenging area that most aggregate and ready mix plants face is the classification and disposal of waste.  “The most common challenge is understanding RCRA rules and classifying
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Medical Hazardous Waste Management

When it comes to managing the hazardous waste in your medical facility, what “you don’t know you don’t know” can hurt you.  If hazardous wastes aren’t managed properly, your medical facility could be at risk for fines, legal action, or a public relations nightmare. Hospitals ranked third – behind printed circuit board manufacturers and copper foundries – on the Environmental Protection Agency’s list of sectors with the most violations relating to hazardous wastes. And the EPA is not the only regulatory agency that can weigh in. Hospitals without good hazardous waste management procedures can also end up in the crosshairs of the Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT), and one or more state regulatory bodies. Many hospitals make errors in their hazardous waste determinations – that is, personnel assume certain chemicals are hazardous, when they’re not, or conversely, mis-classify other waste that in fact classified as hazardous. 
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