Category: Environmental-Permits

ACGIH Publishes Reduced Guideline for Manganese Exposure

Jim Rabideau

acgihManganese exposure occurs when manganese is heated and reacts with oxygen and creates manganese oxide fume. Exposure to this fume can lead to central nervous system damage. This is of special concern for metal fabricators as manganese is present in various welding rods and filler metals. Prolonged or excessive inhalation or ingestion of manganese has the potential to lead to a condition called manganism. Manganism can lead to weakness, lethargy, paralysis, tremors, and speech and psychological issues.

 

Last year the American Conference of Governmental Industrial Hygienists (ACGIH) published a new threshold limit value (TLV) for manganese of 0.02 mg/m3. This was updated from the previous ACGIH TLV of 0.2 mg/m3. Although the ACGIH limit has been updated, the Occupational Safety and Health Administration (OSHA) has not changed the permissible exposure limit (PEL) of 5 mg/m3. The OSHA limit is federally enforceable unless a state plan has a stricter limit.

 

In order to comply with the updated guidelines, companies may need to conduct air sampling to verify employee exposure. Based on the air sampling results, companies can determine if additional personal protective equipment (PPE), ventilation, work practices, or a combination of these are required to reduce employee exposure.

 

Please contact Bay Environmental Strategies, Inc. at 800 576-2476 for additional assistance and information.

So Now You Can Relax because You Have Your Air Permit in Hand…Wrong!

Jim Rabideau

epaSo you have gone through the long, sometimes exhaustive, process of obtaining your state or federal air pollution control permit. It is time to relax right? Wrong! There are many conditions to an air permit and you must comply with all of them. Now is not the time to take your foot off the gas.

Even if you have incorporated the assistance of an environmental consultant, it is your responsibility to make sure that your facility is in compliance with all permit conditions. Conditions with which your facility might need to comply include, but are not limited to:

  • Monitoring operating parameters on pollution control equipment including pressure drops, operating/inlet/outlet temperatures, and filter conditions
  • Calculating daily, monthly, and/or annual air emissions from permitted contaminant sources.
  • Performing stack testing requirements; one-time and/or on-going events.
  • Complying with emission limitations; both process-specific and facility-wide.
  • Preparing and submitting periodic compliance demonstration reports.
  • Preparing and submitting periodic air contaminant emission estimates.
  • Complying with any and all EPA MACT/GACT standards whether or not they written into your permit.

Many individuals assume that because their air permit is finally in hand they can relax. Again, that is the wrong time to do so. There are many conditions within the permit with which you must comply as long as the processes/facility is in operation. If you would like any assistance complying with these requirements, please contact Bay Environmental Strategies, Inc. (BAY) at 800-576-2476.

Industrial Sand Mining in Wisconsin

Jim Rabideau

untitledSand is a very important component of our industrialized society. There are many industries which in some way or another rely on sand to manufacturer their product. In turn these products are used extensively in our daily life which includes such things as cars, homes and computers. In order to obtain sand it must be extracted from the earth. The mining of sand is extensively regulated in order to protect our water and air. In Wisconsin all new industrial sand mines require permits to be in place prior to construction; the following is a short list of permits required:

  • Air Construction & Operation
  • Storm Water/Wastewater
  • High Capacity Well
  • Reclamation

The air permit will apply federally enforceable conditions and limitations on the mine for both fugitive and stacked emissions. The permit will be structured as to not allow these emissions to exceed national ambient air quality standards. This will be done through fugitive dust management and control technology for stacked sources.

The storm water/wastewater permit will cover both the construction and operational phases of the  mine with the aim to prevent sedimentation and other contaminants from entering waterways. The minimum goal of most mines will be able to control storm water runoff from a 10 year storm event. In addition to storm water, any process water from sand washing activities will need to be treated to meet discharge limits set-forth in the permit.

If there are washing activities, the mine will need to obtain a high capacity well permit. The potential drawdown from the well will be modeled to determine if there will be significant impacts to other high capacity water supply systems. If there are impacts, operational limits may be placed upon the use of the well. Water use costs money such conservation is always the answer.

All mine’s are required to develop and implement reclamation plans which provides a plan on how to restore the land after mining activities have ceased.  The plan will also describe how the mine will operate and provide anticipated costs for the reclamation. Based on those costs, the mine operator will have to post bond or letters of credit to the regulatory authority to ensure that if financial hardship ever occurs, there will be funds available to complete the reclamation process.

Other potential areas of regulation which are dependent on chemicals and products stored onsite include:

  • Department of Homeland Security – Compliance Chemical Anti-terrorism Standards
  • EPCRA 311 & 312
  • Oil Pollution Act – Spill Prevention Control & Countermeasures Plan
  • Registration of Petroleum Containing Tanks

 

Read Your Permits

Jim Rabideau

title VA manufacturing operation generally requires several environmental permits in order to legally operate. These permits may be for wastewater, storm water, and/or air discharges associated with its operations. Each of these permits will detail the specific requirements needed to maintain compliance with the associated discharges. It is extremely important that each permit is thoroughly reviewed to understand these legal requirements. Unfortunately a defense of not reading your permit will not withstand the scrutiny of your State, Federal or Local compliance or enforcement manager.

Most permits can be reviewed in an hour or less depending on the complexity of the facility. A more complex facility that has Title V permit may require a longer period of time to review. If there are sections of the permit that are difficult to understand do not be afraid to ask questions from your regulatory compliance manager or environmental consultant. Your lack of understanding the permit requirements are also not a proper defense to noncompliance.

Some of the facility permits will last several years before reissuance is required. We recommend that not only do you review the permit upon issuance but also annually to ensure continuing compliance. With that said constructing a compliance calendar with the facility’s permit requirements is an invaluable tool to help reduce liability and increase permit compliance.