Spill Response – Failing to Plan is Planning to Fail

Releases, spills, and overflows……nobody ever wants to hear those words. However, despite the best precautions, accidents happen or systems fail, and you need to be prepared.  From the initial spill response, to the critical first 24 hours of Site activities, there is a lot to do and a lot to process. Are you prepared? Emergency response, spill response, and rapid response teams are critical pieces to be included in preparation for a potential future spill or disaster that a number of industries may encounter. For oil and gas facilities, metal manufacturing facilities, and even food manufacturers, the potential for a spill or disaster could occur at any moment. There are a number of regulatory agencies that govern spills or discharges in Texas. However, what they all have in common is that spills need to be reported, assessed, and remediated as soon as possible to reduce potential long-term issues or liabilities. When
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Don’t Let Your Wastewater Knowledge Go Down The Drain

We all create wastewater every day, and for the most part, don’t give it a second thought. You wash your dishes and the water goes down the drain. You flush the toilet. You wash your car and the water runs off into the street or storm drain. But when a factory or industrial operation creates wastewater, it’s a different matter. Depending on how much wastewater is created and what types of pollutants or solids are involved, the business may need to obtain permits, build some type of wastewater treatment facility, or both. Failure to do so properly could create hazards to your employees, people in the community, wildlife, as well as the surrounding environment. Common types of wastewater and methods of dealing with wastewater issues including: Domestic wastewater from households & rural businesses Municipal wastewater from communities (sewage) Industrial wastewater from industrial activities Businesses call on W&M for assistance in handling the
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Stormwater Compliance In Practice

The history of stormwater regulation dates all the way back to 1972 with the passage of the Clean Water Act (CWA) by the US Environmental Protection Agency (EPA). The CWA, and subsequent legislation over the years, is both the precursor and the framework for current stormwater permits today.  The laws were initially passed to create some control over the amount of pollution entering waterways through industrial stormwater runoff.  The EPA has given the Texas Commission on Environmental Quality (TCEQ) the authority to regulate stormwater permits in Texas.  The permit most commonly used by industry is the TXR050000 Multi-Sector General Permit. So what is a “sector?” The TCEQ has broken the TXR050000 permit down into industry specific sectors, from A through Z and on to AD.  Each sector covers a specific industry or group of industries.  You can find which sector you might fall into based on your SIC code.  With
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Are We In Compliance With Environmental Regulations?

If someone has ever asked you “Are we in compliance with environmental regulations?”, there’s a good chance your role involves managing environmental compliance programs at your operating facility.  Or maybe your role is at the corporate level where you focus on strategic development of environmental, health, and safety programs and how that aligns with the operational and growth goals of the company.  Either way, you know the challenges associated with maintaining environmental compliance and how the question can sometimes be hard to answer. So what kind of environmental management system (EMS) do you need to answer the question? Odds are you don’t need an ISO certified management system, but you probably need to know the key metrics that ensure that the environmental and sustainability commitments that your company have established are on track.  The basis of this usually stems from an evaluation and identification of risks, review of culture and
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It’s Crucial! Safety First…No Matter What!

As an Environmental Health and Safety (EHS) consultant,  I am often asked to provide site level safety support overseeing multiple subcontractors.  I’ve found that the safety culture of our subcontractors varies greatly.  For example, the smaller subcontractors may not have the resources to implement a strong or well developed safety program. My job is to bridge the gap between the client and the subcontractors.  I’ve learned that regardless of the project type, a successful project is one in which safety is considered during the planning phase.  If you have a good understanding of your client’s safety culture and expectations from the start, you can pre-qualify your subcontractors for safety.  A contractor health and safety plan can be developed to include training requirements, injury reporting requirements and program requirements, and be provided to the contractors before they bid on the project.  Project communication and training can be tailored to fill the “gaps” that may
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REDUCTIVE DECHLORINATION OF A CHLORINATED SOLVENT PLUME IN HOUSTON, TEXAS

ABSTRACT Jim Florey, Andrew Adams, Larry Michell (in memoriam) Chlorinated solvents such as tetrachloroethene (perchloroethene, PCE) and trichloroethene (TCE) have been extensively used in various industrial applications for many years. Because neither are typically consumed through their various uses, they are often released to the environment through industrial application or disposal.  Once released, PCE and TCE tend to migrate downward into groundwater, where they persist.  In the current case study, cheese whey was used as a groundwater amendment to facilitate the reductive dechlorination of a chlorinated solvent plume underlying an auto dealer/repair shop in Harris County, Texas.  From September 2010 to January 2014, over 32,000 gallons of cheese whey were injected into the subsurface resulting in a marked reduction in oxidation-reduction potential (ORP) and nitrate concentrations, coupled with an increase in ferrous iron concentrations.  Statistical trend analyses indicate the primary contaminants PCE and TCE, as well as the daughter product
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It’s All About Who You Know and Knowing What To Look For

Let’s face it, during environmental reporting season, it seems like co-workers will intentionally walk halfway around your facility to avoid being sighted out your doorway.  The co-workers that normally stop by your office every other day or go to lunch with you are all of the sudden M.I.A.  The hint of Tier II, TRI, AEIR, or AWS talk sends them scrambling for the exits.  Information gathering for environmental reporting is time consuming but it doesn’t have to be scary or tedious. Before you dive headfirst into your data gathering, consider assembling a team of veteran coworkers from the various departments within your facility.  Some of the more valuable helpers we rely on are purchasers, maintenance managers, and line managers from each value stream.  Purchasers have access to a wealth of knowledge such as quantities of chemicals purchased, typical or average inventory, and which departments are ordering which chemicals.  Maintenance managers are typically
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WHAT IS going on with WOTUS?

On November 16, 2017 the U.S. Environmental Protection Agency and the U.S. Army Corp of Engineers (Agencies) proposed to amend the effective date of the 2015 Clean Water Rule (commonly known as the WOTUS Rule) defining the “waters of the US”. The proposal is to delay the effective date of the Rule until 2020 giving the agencies time to reconsider and revise the definition. The WOTUS Rule, which was originally slated to come into effect in  August 2017, was adopted by the Agencies under the Obama administration in a 2015 Rule titled “Clean Water Rule: Definition of Waters of the United States”. In June 2017, the Agencies proposed to rescind the WOTUS Rule following an executive order under the Trump Administration to review and revise the definition of the “waters of the US”. The WOTUS Rule affords federal protection for about 22 million acres of wetlands and over two million miles
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TCEQ Permit By Rule Program

Due to technical difficulties the first 8 minutes of the webinar was not recorded.  We apologize for the inconvenience. The Texas Commission on Environmental Quality’s (TCEQ’s) “Permit by Rule” (PBR) program allows the regulated community to efficiently design, construct, start-up, and operate a substantial number of differing types of air emission facilities. Based in over 100 standardized permits delineated in Title 30 of the Texas Administrative Code (30 TAC), they can cover everything from hand grinding of metal to natural gas liquefaction.  They enable sites to construct new emission facilities or make modifications to existing, previously permitted facilities. There are several different paths through the PBR process determined by a number of different factors. Some must be approved/authorized by the TCEQ, others do not require administrative review and approval.  While PBRs are efficient in terms of authorizing new emissions, they are also very prescriptive and very seldom open to interpretation
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Hazardous Waste in the Healthcare Industry

W&M’s Lori Siegelman and Pat Larkin, an Environmental Attorney and Partner with Strasburger & Price, LLP, conducted a lunchtime webinar on hazardous waste management in the healthcare industry.  Medical and laboratory professionals may not be  well-versed about the intricacies and potential complexities of State and Federal regulations applicable to waste being generated in the pharmacy, clinic, laboratory, or hospital.   Listen to experts explain how hazardous waste generated in the healthcare industry should be identified and properly managed.