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Environmental Management – EU 304
APPA Institute, Tampa FL, January 2015 1
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Jay W. Becker, PE
Manager of Mechanical Systems & Facilities Engineer
University of Puget Sound [email protected]
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} Know what you have } Learn the Regulations to follow } Develop procedures } Training } Self Audits and Inspections } DOCUMENTATION
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“Higher education institutions are as much a part of our regulated community as are business, industry and government facilities. They must comply with all state and federal environmental laws. “
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• Compliance Assistance Programs
• Workshops • Targeted Enforcement • Institute Fines
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Universities & Colleges should Implement: } Environmental Management Systems
(EMS)
} Self Audits
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Tool to improve environmental performance;
} Roles & Responsibilities } Procedures } Training } Documentation
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} Achieve consistent compliance (no fines) } Be prepared for inspections } Reduce management and operating costs } Improve relations with regulators
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Established ambient and source emission standards and permit requirements for conventional and hazardous air pollutants.
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} EPA sets limits on how much a pollutant can be in the air anywhere in the US, ensuring consistent health & environmental protection
} Different Regions will require stronger standards base on measured ambient levels of air quality
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} Title I – Attainment and Maintenance of National Ambient Air Quality Standards
} Title II – Mobile Sources and Clean Fuels* } Title III – Hazardous Air Pollutants } Title IV – Acid Deposition Controls* } Title V – Permit Program } Title VI – Protection of Stratospheric Ozone } Title VII – Enforcement
www.epa.gov/air/caa
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} Sets emission standards for motors & fuels } Regulates Hazardous Air Pollutants – HAPS } Protects ozone layer & addresses acid rain } Creates a permit program (Title V) to monitor
air emissions } Imposes strict sanctions
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NAAQS (National Ambient Quality Standards) } NAAQS is the principle regulator program
established und the Clean Air Act. } NAAQS has two basic elements: ◦ Primary standards (Protect Health) ◦ Secondary standards (Protects environment and
Property)
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Definition “Ambient air quality standards the attainment and maintenance of which in the judgment of the administrator, based on such criteria in allowing an adequate margin of safety, are requisite to protect the public health. “
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} Ozone (O3) } Nitrogen Dioxide (NO2) } Carbon Monoxide (CO) } Particulate Matter (PM-10)
{Dust, Smoke, & Soot} } Sulfur Dioxide (SO2) } Lead (Pb)
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} Geographic areas that have failed to meet the NAAQS primary standards for one or more criteria pollutants are designated as “nonattainment areas”
} Geographic areas that have met all of the NAAQS primary standard for all criteria pollutants are designated as “attainment areas”
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The CAA established technology-based (rather than health based) standards for 187 HAPs based on the use of Maximum Achievable Control Technology - MACT
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} National Emission Standards for HAPs (NESHAPs) – Health Based Standards
} Maximum Achievable Control Technology (MACT)
} Accidental Release Prevention
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} HAP emissions are to be identified as major (large) or area (small) sources
} Takes into account costs & other factors } Emission limits based on the best
demonstrated control technology or practices to similar sources applied to major sources emitting one or more of the listed HAPs
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} PTE (Potential To Emit) 10 tons/yr. of a single HAP or PTE 25 tons/yr. combination of HAPs
} Fugitive Emissions Count. } Emission standard for these sources: ◦ Institutional Commercial Boilers ◦ Stationary Internal Combustion Engine
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} A major source must submit permit
application with MACT determination for the applicable source category
} Standard for Industrial / Commercial Boilers
} Select boilers above 10 million BTU
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} T5 permit includes information on pollutants being released and potential amount
} T5 permit includes what kinds of steps to reduce pollution, including plans to monitor (measure) the pollution
} T5 permit is especially useful for Major Sources covered by more than one part of the law, since information about all of a Major Source air pollution will not be in one place
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} Must inventory all air polluting equipment; } If a permit or some other Federal Enforceable
Applicable Requirement (FEAR) limits throughout, burn times etc. use these limits and add emissions to PTE.
} If no FEAR limits use then must calculate at 8760 hr/yr at rated capacity and add emissions to PTE.
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} Criteria Pollutants – PM-10, Pb, NO2, SO2, CO, O3 (including VOC & NOx)
} HAPs – 187 Substances } Class I or II Title VI Substances (CFCs). } Other regulated Substances – HCI, H2S,
TRS, Fluorides, Dioxin/Furan, Sulfuric acid mist
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} Generators } Fume Hoods* } Chlorine/Ozone for Pool Treatment } Printing Services } Gasoline Distribution } Incineration } Fireplaces } Woodworking (potential to require a fabric
bag on every piece of equipment that may produce sawdust)
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} Potential large problem for universities } 2 “Types” of fume hoods found at
universities: ◦ Teaching Labs ◦ Research/Teaching Labs
} EPA is still rule making w.r.t teaching vs. R&D labs, for now requirements and how to include in T5 will be very SIP dependent
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Examples ◦ Insignificant Emission Units (Need not to include T5 application/permit) ◦ Emission Units of an Insignificant Size or Production Rate (Storage tanks, small boilers and emergency generators)
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Items not tracked at one University } Molasses storage tanks } Janitorial & lawn maintenance activities; } Office activities and implements such as
pens, type writers, printers and pens } Bathroom and locker room ventilation
and maintenance procedures } Parking lot resurfacing
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Items tracked at two Universities; } Diesel generators } Cyclone separator at wheat lab } Fugitive dust emissions associated with
coal handling (rail cars and loader) } Stack emissions from wood fired boiler } Fugitive dust emissions on gravel/dirt
roads
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} RECORDS } Reports on fuel usage calculated to show
pollutant amounts (then there is tax based on the amounts)
} Rolling annual emission amounts to show we have not exceeded
} Records of calibrations and monitoring results of emissions
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} Requires that production of CFC’s and halons be reduced in the interim and then completely phased-out
} EPA must list regulated substances, their ozone depleting potential, lifetime in atmosphere & global warming potential
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} Class I Chemicals � CFCs, halons and CCI4 out by 2000 � Methyl Chloroform out be 2002 � Class II Chemicals � HCFCs out be 2030
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} Administrative penalties up to $200,000 } Field citations up to $5,000 } Criminal penalties have been upgraded from
misdemeanors to felonies } Source must certify compliance (T5-
Designated Felon), subpoenas may be issued for compliance data
} Fines may escalate for ‘significant violators’ } It is possible to negotiate use of funds for
environmental projects)
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} If the state has an implementation plan, then the fines come from the state agency but EPA can fine you as well
} Citizens may seek penalties against violators with the penalties going to the US Treasury for use by EPA. (All information in a Title V permit will be made available to the public except where there is a trade secret being protected)
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} Establishes ambient and point source
effluent standards and permit requirements for water pollutants, including sources that discharge directly to a waterway or public sewer system
} MS4 (Municipal Separation of Storm and Sewer Systems)
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} Applicable Regulations ◦ Underground and Aboveground Storage Tanks (UST & AST) ◦ Spill Prevention, Control and Countermeasures (SPCC) ◦ Used Oil Management ◦ Wetlands ◦ Storm Water Runoff ◦ Erosion Control on Building Sites
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} Own/operate facility that could discharge oil } Total above ground storage exceeding 1,320
gallons, count all containers > 55 gallons } Total UST capacity of over 42,000 gallons } Requirements apply to all containers of 55
gallons or more (include drums) ◦ Includes vegetable oils
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} Prepare and implement plan (develop plan before beginning operations)
} Operating procedure to avoid spills } Control measures to keep oil from reaching
‘navigable waters’ } Countermeasures to clean up or mitigate any
impacts of the spill } Training and inspections must be part of plan } Secondary Containment is a “must have”
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} Update as facility changes and a formal review every 5 years.
} Registered PE must certify and sign plan (exceptions apply – self certification for small sites <10,000 gallons).
} Special secondary containment provisions for oil-filled equipment (transformers).
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www.epa.gov/oilspill/guidance.htm
This 521 page document provides guidance to regulatory inspectors who will be verifying your compliance. It is suggested that all SPCC Plan owners use this plan to audit your program for compliance.
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} Minimum Control Measures ◦ Public education and outreach ◦ Public participation ◦ Illicit discharge detection and elimination ◦ Construction site storm water runoff
control ◦ Post construction storm water
management ◦ Pollution prevention (good maintenance)
NOTE: EPA is cracking down on substandard state programs.
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RCRA Resource Conservation and Recovery Act
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How well do we manage and secure hazardous materials?
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} NRC } Health and Human Services } CDC } Department of Agriculture } Department of Homeland Security
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Section 40 CFR } Subpart K is an optional EPA generator
regulation designed for the academic sector. } Alternative requirements for hazardous waste
determination and accumulation of unwanted material
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Implementation on a University Campus
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} Plan new construction } Retrofit existing buildings } Operational procedures to reduce
vulnerability } Emergence planning for evacuation or
sheltering in place } Mitigation of hazards if a release
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} Community involvement } Fires (prevention, evacuation, response,
recovery) } Water (loss or flooding) } Weather related (tornado or hurricane) } Shipping related release of hazardous
substances } Threats or malicious release of hazardous
materials
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“We have enough trouble just taking care of the waste you generate – we need you to identify it and not leave it around for inspectors to find.”
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} Environmental Exposures } Occupational Illness } Hazard Communication } Standard Operating Procedures } Personal Protective Equipment - PPE
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} Keep record of an evaluation that you use to determine if PPE is needed … and review it annually.
} Provide PPE and make sure people know why and how to use it. ◦ Safety glasses, gloves, hard hats, boots, hearing protection, special clothing, etc
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Examples of hazards and exposures to identify and provide protection & training
Develop Procedures
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Authorized Entrants Must use Retrieval Systems
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} Evaluate where it might be } Check before renovations } Train maintenance staff to recognize } Contain and isolate } Negativity air and HEPA filters } Collect wastes (dry better than wet)
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To grow they must have: ◦ A food source – wood, paper or other plant derive materials are best. ◦ A moisture source – leaks, floods, condensation, steam or high humidity.
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} Productivity, comfort, health and safety. } A continuous scale of perception of ones
workplace environment.
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} Living rooms, board rooms, conference and lecture rooms, hotel bedrooms 30-40 db.
} Noisy kitchens in hospitals and hotels, laundry rooms, computer rooms, canteens, supermarkets, office landscape, etc. 40-50 db.
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} Onsite occupant interviews } Inspection (water damage, remodeling
activities, monitor temperature/humidity) } Review building systems (look for things
that have been repaired or shut down) ◦ Many issues can be handled with an onsite inspection and evaluation
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} Work Smarter, not harder
} KISS
} Procedures and standards
} Training
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Jay W. Becker, PE Manager of Mechanical Systems
& Facilities Engineer University of Puget Sound
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