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.





Hurricane Clean Up Health and Safety Hazards

We were all relieved when Hurricane Harvey finally relented and the flood waters began to recede.  After the catastrophe, most residents in Southeast Texas began doing what Texans do.  That is getting to work cleaning up the mess that Harvey left! Many workers, both paid and volunteers, are contributing to the recovery effort.  With that in mind, Lori Siegelman, who specializes in worker safety, has created a guide to alert workers to the health and safety hazards they will likely encounter in the aftermath of a flood event. Workers cleaning up or conducting site visits/surveys of damaged buildings following hurricane or flood damage, can face potential hazards from oil and chemical spills and leaks, debris, unstable work surfaces, and electrical lines.  In addition, there is high potential for other safety and health hazards associated with exposure to bacteria, mold, animals (dead and alive), insects, heat or cold stress.  The goal
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A Millennial Guide To Phase I’s

Since graduating with a degree in Biological Engineering from LSU, I have assisted Environmental Professionals (EP’s) with over 200 projects that required Phase I Environmental Site Assessments (ESAs).  Over the last two years these projects have ranged from vacant lots, multi-family residential apartment complexes, drycleaners, gasoline stations, to industrial manufacturing plants. The goal of a Phase I ESA is to determine if there are conditions that are indicative of releases of petroleum or hazardous materials or chemicals at the site, now or in the past. These conditions are known as recognized environmental conditions (RECs).  Basically, a Phase I is conducted to identify RECs, at the subject property that may require investigation or cleanup, and could impair a property’s value or create liability.  Phase I ESAs include the following: Site inspection (interior and exterior features) A review of historical records of the property (including historical aerial photographs and topographic maps, fire insurance
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W&M Closes Four Voluntary Cleanup Program Sites

2017 kicked off on a good note as four of W&M’s clients received closure letters from the Texas Commission on Environmental Quality (TCEQ) for real property that had been entered into the Voluntary Cleanup Program (VCP). The most challenging closure was for a former light industrial facility in West Texas that had a release of chlorinated volatile organic compounds (VOCs) into the shallow portions of the Ogallala Aquifer. The Ogallala is a highly valued source of water for agricultural, industrial and domestic use in West Texas and beyond.  The affected portion of the aquifer extended to a depth of nearly 100 feet.  Many years of monitoring by previous consultants had shown that the VOCs were not being degraded at a very rapid pace, so W&M recommended that the client seek a Municipal Setting Designation (MSD) to restrict the use of groundwater from the affected area.  W&M worked closely with the
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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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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





SPCC Plan Five-Year Updates and Technical Amendments

The Environmental Protection Agency’s (EPA’s) Spill Prevention, Control, and Countermeasure (SPCC) regulations (Title 40 of the Code of Federal Regulations [CFR] Chapter 112) applies to non-transportation-related facilities that drill, produce, store, process, refine, transfer, distribute, use, or consume oil or oil products; and that could reasonably be expected to discharge oil in harmful quantities (as described in 40 CFR 112.1(b)) to U.S. navigable waters or adjoining shorelines. Facilities subject to this rule are required to prepare and implement a SPCC Plan. The SPCC Plan must contain minimum design criteria and inspection procedures and must be approved by the facility management and certified by a professional engineer (P.E.), unless the total capacity of oil at the facility is less than 10,000 gallons, and the facility meets the criteria of a qualified facility under 40 CFR 112.3(g). All facilities, excluding farms, (defined at 40 CFR 112.2) were required to update, prepare, and
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