Environmental Compliance The Industrial Prospective

Trends in USEPA Enforcement

Typical Manufacturing Overview By Products Raw Materials Process Products Waste Environmental impacts are relevant at each stage from process design through product delivery and waste disposal or treatment.

Raw Materials Procurement specs – What are the impurities? How do they affect the site emissions/wastes? Transportation of materials – What are the truck/rail/barge/ship control requirements for transporting material to this location? Permits? Material storage – Are existing tanks adequately controlled, sized, constructed, and permitted? Material transfer – Are components, pipelines, loading racks appropriately permitted and controlled?

Process Material transfer – Will new piping, pumps & components be required that need permitting? Will new components require monitoring and reporting? Process vents – Is the facility located in an area requiring control of process vents for these type air/water emissions? What are reporting requirements associated with chemicals in the process? ISBL – What are the limits on process water to the sewers? How are emissions generated? Wastes? OSBL – Will the current cooling capacity be adequate and will a new process result in potential emissions to the tower? What are the emissions resulting from the requirement for new/additional utilities?

Process includes Maintenance

Design Considerations Do you need a permit? Use new/existing emission controls? Will waste handling capacity increase? Will storage, loading or transfer operations need upgrades? Details next slide

Design Considerations

By Products Value – Is this a waste, fuel or by product? How do you intend to use it? What will be requirements associated with that use? Storage – Are tanks permitted, constructed and controlled to fit this service? Transfer - Will new piping, pumps & components be required that need permitting or special construction? If transported offsite, how? Truck/rail/barge/ship?

Products Storage – Are tanks permitted, constructed and controlled to fit this service? Transfer - Will new piping, pumps & components be required that need permitting? How will products be shipped? Truck/Rail/barge/ship? What happens in case of spill during transport?

Waste Gas, Liquid, Solids – Hazardous/Non-Hazardous Storage Treatment Control Transfer

Types of Waste HAZARDOUS NON-HAZARDOUS Characteristic Class 1 Ignitable Corrosive Reactive Toxic Listed F-list K-list P-list U-list NON-HAZARDOUS Class 1 Class 2 Class 3

Waste Disposal All shipments must be manifested Company approved disposal facility only DOT approved containers Placards identifying waste on trucks

Environmental Protection Acts by Congress Clean Water Act Permits set mass rate limits on amount of pollutants discharged Requires permits for storm water and process water Resource Conservation and Recovery Act (RCRA) Rules established for proper management of hazardous waste (“cradle to grave”) Requires permits for generators, treatment and disposal facility CERCLA (Superfund) Requires notification for releases of certain chemicals Establishes “polluter pays” principle for env. damage

Environmental Protection Acts by Congress Clean Air Act (Most Complex) Permits set mass rate limits on amount of emissions More stringent requirements on new construction/modified sources More stringent requirements on air toxic emissions More stringent requirements if source is located in an area with poor air quality

Life in a “Non-attainment” Area Industrial Controls Harder to obtain permits for new/modified facilities (impacts facility siting decisions) Must reduce emissions equal to amount facility would create Expensive controls required on existing sources of ozone precursors (nitrogen oxides and hydrocarbons) Non-Industrial Controls Strict vehicle emissions testing – “Tailpipe Emissions Tax” Gasoline vapor pressure restrictions – “Pay at the Pump” Speed limit restrictions?

The Future of Environmental Rules More stringent controls on the amounts of emissions Areas must achieve attainment for ozone EPA goal for air toxics (benzene, methanol, etc.) levels is to limit cancer risk from air toxics to one in a million Lower ability to excuse emissions due to breakdown of equipment Higher expectations to handle these situations without “emergency” releases Regulation of new contaminants Very fine particulates Carbon dioxide?

Company Response Regulations are required by law How should a company react to the intense controls placed upon it by the government in an attempt to protect the environment? Regulations are required by law There are civil and criminal penalties at stake Public reaction affects the value of a company Employees are citizen and have concerns The community controls our “license to operate” Stockholders are citizens and want to ensure management is not placing their investment at risk

Industrial Commitment “Getting Health Safety Environment Right” sets the company’s vision, direction and expectations. The goal is No accidents No harm to people No damage to the environment, which includes Pollution prevention Compliance with laws and regulations, and Continuous improvement All major sites to have their Environmental Management System (EMS) ISO 14001 certified.

Industrial Approach to the Environment Environmental Management System (EMS): a systematic approach to meeting environmental requirements across an organization ISO 14001: an international standard and structure for environmental management systems. Requires external verification that your EMS meets the standard.

What does this mean to me? You will be paid to solve problems in a way that creates value for your employer Environmental protection will be a critical component of your job…don’t fail to recognize that fact. Engineers are the key to environmental protection in manufacturing…via incorporation into siting, design, construction, operations, maintenance and abandonment. Don’t do any project without asking yourself how it impacts compliance with environmental protection requirements or principles You have an opportunity to make a difference