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SUBJECT: Environmental Systems

ALPHANUMERIC IDENTIFIER:

BRIEF DESCRIPTION: Every manufacturing facility is affected by environmental laws and regulations. These laws and regulations are promulgated and enforced at the local, state, and federal level. Companies must be aware of the regulations which apply to their facility and insure that the facility operates in compliance with the regulations. The Environmental Systems section describes the primary laws and regulations which apply to manufacturing facilities and how facilities can insure compliance through environmental audits.

KEYWORDS: Environmental, compliance, air, water, waste, audit

OVERVIEW:

Environmental systems, and regulations, are generally divided into three sections: air, water, and waste. Audits are conducted to verify compliance with regulations.

Air

This section applies to the air emissions that are emitted to the exterior of the facility. Typical processes and equipment found in manufacturing facilities that generate air emissions include: paint spray booths, paint bake ovens, parts washer tanks, and boilers. Under the Federal Clean Air Act of 1990, every regulated piece of equipment must have an air emissions permit. The Clean Air Act gives each individual state the authority to issue permits and to enforce their conditions. The permits contain conditions regarding hours of operation, emission limits, and recordkeeping requirements.

Water

Water is classified into one of two categories, process waste water or stormwater. Water that is required by a manufacturing process is classified as process waste water. Examples of processes include: water curtain in paint spray booth, water in cooling towers, water-cooled welding equipment, and cleaning. Permits must be obtained from the local sewer authority which regulates the discharge of the process waste water. The permit will contain conditions related to the amount of waste water that can be discharged, contaminant levels, and sampling and reporting requirements. Stormwater run-off is also regulated. If the stormwater is held onsite in a retention basin prior to being discharged to a receiving water or wetland, a federal National Pollution Discharge Elimination System (NPDES) permit must be obtained. If the stormwater is discharged to a storm sewer, a stormwater pollution prevention plan must be developed and someone onsite at the facility must be certified as a stormwater operator.

Waste

Waste generated by a facility is classified as hazardous or non-hazardous, depending on the operation generating the waste and its toxicity. Hazardous waste is primarily regulated by federal regulations. Hazardous waste must be properly identified, labeled, and stored. Anyone generating or handling hazardous waste must be trained in proper handling techniques. Every facility that generates hazardous waste must have a Hazardous Waste Identification Number that is issued by the United States Environmental Protection Agency. Generators of hazardous waste have 90 days to dispose of the waste after it is generated. Only permitted and licensed transporters and disposal companies should be used by the generator to dispose of the waste as the generator bears "cradle-to-grave" liability for the waste. Industrial waste, while not as toxic, should likewise be handled by trained employees and disposed of by permitted and licensed companies.

Audits

An effective environmental audit is comprised of three parts: record review, facility walk-through, and employee interviews. A thorough record review is required to verify compliance with the recordkeeping requirements of the permits issued to the facility. A walk-through provides verification that the equipment is maintained and operating properly and that all processes in the plant are covered by permits. Finally, employee interviews provide the opportunity to verify systems are in place and are followed by the employees in the facility.

REFERENCES: 40 CFR 60, 63, 82; 40 CFR 110, 112, 122, 136, 261, 361, 403, 413, 433, 461, 463, 464, 466-469; 40 CFR 60, 261-266, 268, 270, 279, 761. Environmental Auditing, 7th Edition.

ACKNOWLEDGEMENT: This is a March 29, 1999 revision by Gene Goodson of an assignment for OM742 contributed by XXX Kurth.