1. Environmental Compliance
The Industrial Prospective

2. Trends in USEPA Enforcement

3. 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.

4. 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?

5. 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?

6. Process includes Maintenance

7. 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

8. Design Considerations

9. 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?

10. 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?

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

12. 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

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

14. 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

15. 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

16. 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?

17. 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?

18. 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

19. 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 certified.

20. 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.

21. 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