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.





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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