Environmental Self-Audit
It is a far, far better thing to know if you are within compliance guidelines before the Environmental Protection Agency (EPA) representative shows up at your doorstep.
By performing a self-audit, you will determine your compliance status, minimize environmental liabilities and minimize long term costs, said Loren Polak, environmental compliance officer with Bunge Corporation, (314-872-3030/www.bunge.com), St. Louis, MO.
Polak was a speaker at the National Grain & Feed Association (NGFA/www.ngfa.org)/Grain Elevator and Processing Society (GEAPS/www. geaps.com) safety, health, and environmental compliance seminar, held in Overland Park, KS, in July.
�There is a lot of overlap between the EPA laws and what is required by the Occupational Safety and Health Administration (OSHA),� he said, but you must meet all the regulations.
A number of items need to be evaluated during your self-audit:
� Pollution control equipment.
� Petroleum and chemical storage areas.
� Waste storage areas.
� Water supply systems.
� Storm water discharges.
� Environmental permits.
� Regulatory reports, plans, and documentation.
Polak recommended the following areas in conducting your self-audit:
Clean Air
The federal Clean Air Act (CAA) was enacted in 1970, with major amendments to expand and update the provisions in 1977 and 1990, Polak said.
EPA has nationwide authority for monitoring and enforcing CAA. However, most state EPA have been authorized to implement the CAA. Polak said most people refer to the regulatory elements of the program by the title numbers within the 1990 amendments.
There are seven titles that cover everything from programs and activities to ozone protection and enforcement of the act.
Under Title V, facilities which are major sources of air emission are required to obtain operating permits. Facilities that are minor sources of air emmission are also required to have air operating permits in many states.
Any equipment or activity that emits, or has the potential to emit pollutants, or causes solid or liquid materials to become airborne, is a source of air pollution that may require a permit.
This includes any facility that handles grain, feed, food products, minerals, produces chemicals, petrochemicals or petroleum products and other processing and manufacturing.
Polak said it is important to determine if your facility meets the requirements for an air permit, and if so, verify that the permit is current.
Additionally, air pollution control equipment, such as baghouses and cyclones, dust suppression systems, enclosures, blowers and motors, aspiration hoods and ductwork, must meet regulatory standards and be in proper working condition.
Tank Management
In 1998, EPA mandated that underground storage tanks not meeting stringent regulations relating to corrosion protection, spill prevention, release detection, etc., had to be dug up and replaced.
If your company still has underground tanks in active use, they must meet the current standards, Polak said.
Above-ground tanks must be regularly inspected for leaks, spills, rust, damage, and have tight-fitting hoses and pipes. Additionally, the area around the tanks must be free of grass and debris and the tanks properly labeled.
OSHA states that tanks or containers cannot exceed a 1,100 gallon capacity in any one pile or area.
The tanks must also be protected by a spill containment system, consisting of a curb or earthen dike. Provisions must be made for draining off accumulations of storm water or collecting spills of flammable or combustible liquids.
The company must have an established spill response system, which includes a way to safely turn off the tank or stop the flow and having adequate spill containment materials on hand.
�Make sure you understand the regulations for reporting releases and know if you are subject to Spill Prevention Control and Countermeasures (SPCC) oil spill prevention program requirements,� Polak said.
If you own or operate a non-transportation-related fixed facility that could reasonably be expected to discharge oil into or upon navigable water, you may fall under SPCC rules, if you meet any of the following conditions:
1) An above-ground oil storage capacity of more than 660 gallons in a single container;
2) A total above ground oil storage capacity of more than 1,320 gallons, or;
3) A total underground buried storage capacity of more than 42,000 gallons.
Oil, Chemicals, Waste
Pesticides, fumigants, oils, chemicals, and used oils must also be handled, Polak said.
� Inspect your hydraulic systems, maintenance shops, storage tanks and inventory storage areas to make sure everything is in good condition.
� Have a spill prevention or containment system in place for dealing with leaks or breaks.
� Used oil must be marked as such and stored in tightly-lidded containers. Arrange for off-site recycling and keep careful records of how and where it was recycled or disposed.
� Remove any polychlorinated biphenyls (PCB) or Resource Conservation and Recovery Act (RCRA) hazardous wastes from the facility, and make sure spills or contaminated soils are promptly collected and properly disposed of, Polak stated.
Water Issues
� Identify non-potable water sources, properly close abandoned wells and document what you have done.
� Test on-site potable wells for bacteria and nitrates, and install water treatment equipment as necessary.
� Under the Clean Water Act, facilities must obtain a National Pollutant Discharge Elimination System (NPDES) permit if their point source (pipes, man-made ditches, etc.) discharges go directly to surface waters.
� If required, install wastewater treatment equipment, such as settling tanks or skimmers and make sure they are properly operated, inspected and maintained.
� Inspect drain fields and septic tanks every five to 10 years and clean as necessary, Polak said. �Do anything you can to prevent contamination.�
Emergency Response
In spite of your best efforts, spills and leaks do occur and Polak emphasized the importance of documenting everything, taking photos if applicable, and sending information to the appropriate people.
He also suggested:
� Establish emergency response arrangements and post the information in an conspicuous place.
� Make a list of relevant state and federal agencies and how to contact them to report a problem.
Written by Coreen Stevick, associate editor
See Related Websites/Articles:
|
