PWGC Facilities Newsletter -- Spring 2014 Edition
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Spring Newsletter

Facilities Edition

Our facilities newsletters are designed to help you stay up-to-date on ever-changing environmental rules, regulations, and other pertinent issues related to the Manufacturing, Chemical, and Production industries.

New York UST Operator Training Update

Draft 6 NYCRR Part 613-2.5

The New York State Department of Environmental Conservation (NYSDEC) has changed its UST operator training program. They originally allowed training to be completed using a variety of resources, including a company's internal program.

NYSDEC is instituting a new approach -- they're making all training materials available on the NYSDEC website. NYSDEC is developing the exam for Class A and Class B operators and is anticipating that this will also be available on-line.

At this point it appears that the NYSDEC will be offering the training materials and the NYSDEC exam for free.
Contact PWGC for additional information

E-Manifests in the Works

The 2012 Hazardous Waste Electronic Manifest Establish Act spearheaded the movement toward electronic hazardous waste manifests. On February 7, 2014 the EPA released the final rule allowing electronic manifests for hazardous waste transportation, as an alternative to the paper forms that have been required for tracking shipments.

As stated by the EPA, this rule affects approximately 160,000 entities in at least 45 industries that are involved in shipping off-site, transporting, and receiving approximately 5.9 million tons of RCRA hazardous wastes annually (non-wastewaters and wastewaters). These entities currently use between 4.6 and 5.6 million EPA Uniform Hazardous Waste Manifests (EPA Form 8700-22 and continuation sheets EPA Form 8700-22A) to track hazardous waste shipments from the site of generation to sites of treatment, storage, or disposal.

The next milestone for the EPA is to develop an e-Manifest Information Technology (IT) system, to be up and running by October 5, 2015. At this time, the technical capabilities of the e-Manifest are not fully defined; however, the EPA does have some vision which may be viewed in the Q&A at the EPA website.

Contact PWGC for additional information

The EPA's WaterSense Program

The EPA’s WaterSense Program has commercial fact sheets with specific categories to assist with understanding water usage and potential savings in use reduction. According to the tool, industrial facilities should go though the following checklist. The program provides best management practices described in WaterSense At Work that can be applied to industrial facilities.

The tool lists the following items for industrial facilities to consider when it comes to water:
  • Optimizing Processes: Industrial facilities may be able to improve water efficiency by evaluating the amount of water used in each step of a process or in between the steps of a process. EPA has created the Lean and Water Toolkit to assist industrial facilities in evaluating process water using pollution prevention and traditional manufacturing efficiency techniques.
  • Reusing Water: Depending on the water quality requirements, water from one step of a process can sometimes be recycled or reused in another part of the manufacturing facility. In some cases, pretreatment of this water may be necessary to control the concentration of contaminants before returning the water to the process or reused directly. View the EPA’s Guidelines for Water Reuse here
  • Checking Permits: In all cases, facilities should contact their local water or wastewater utility for technical assistance before making process changes that would affect the discharges or effluent of the facility. Wastewater discharges from all industrial facilities are regulated under the Clean Water Act through the National Pollutant Discharge Elimination System (NPDES). Each NPDES permit incorporates limits on specific pollutants set in effluent guidelines and/or pretreatment standards for a facility. Changes in the quality or quantity of water released could cause a facility to violate the terms of discharge permits issued under the Clean Water Act or other state, regional, or local codes or requirements.
  • Accessing Incentives: Some water, wastewater, and energy utilities offer incentive programs for facilities to make process changes that improve water or energy efficiency. In addition, some state pollution prevention programs and universities provide subsidized auditing services for industrial facilities.
PWGC has provided this newsletter solely for informational purposes; we make no warranties or certifications for a specific matter. If you require further information on a subject of this newsletter, would like to discuss your particular circumstances or would like to provide comments, please feel free to contact us.
Copyright © 2014 P.W. Grosser Consulting, All rights reserved.

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