Abstract of Presentation at DIS Ft. Worth Meeting

by:  Daniel Longbrake, August Mack Environmental, Inc.

1. Lawsuit filed against utilities for violations of the clean air act.
The law suit alleges that the utilities have made major modifications that would have required the controls to be put in place. If this law suit is successful, one could expect to see the USEPA targeting other title V facilities.

2. Phase II storm water rule.
According to this rule, a separate storm water system must be in place for construction sites greater than five acres and/or if the population is greater than 100,000.

3. MACT (Maximum Allowable Compliance Target) for iron and steel industry is scheduled to be promulgated prior to 11/00.
This is about twelve months behind schedule and 600 MACT long forms have been submitted by the industry. Foundries with cupola operations will be asked to complete another questionnaire (bag house vs scrubber for MACT). This will come from the MACT task force.

4. Risk management plans.
The plans were due by June 21, 1999. On August 5, 1999 Clinton signed the chemical safety information, site security and fuels regulatory act, that provided an exemption for all hydrocarbon fuels that are used on site as fuel. (Example - propane) The propane exemption is still in the US Court of Appeals.

1. Clean air act and amendments
2. Clean water act
3. Resource conservation and recovery act (RCRA)
4. Superfund amendments and reauthorization act of 1986 (SARA Title III)
5. Toxic substance control act (TSCA)
6. Oil pollution prevention
7. OSHA

1. Get Buy-In from management
2. Establish relationship with regulators
3. Plan ahead
4. Participate in capital planning
5. Conduct training
6. Recognize that any program is dynamic: anticipate and account for change
7. Utilize resources that are available (E.G., regulators, web pages, associations, consultants)

1. Compliance audit program

• Continually update and track progress

• Establish responsibility and accountability

2. Integrated contingency plan

• Address the issues of storm water pollution

• Prevention plans: OSHA Emergency Action Plan; RCRA Contingency Plan

3. Emergency health and safety tracking system

• Develop electronic record keeping

• Utilize software available in the market

• Utilize graphics (facility layouts, plans)

4. Environmental liability assessments

• Determine or update liabilities

• Account for changes in regulations/technology

• Free up capital for expansion/growth

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