The purpose of this article is to walk you through the Boiler MACT applicability, compliance dates and what regulations are applicable to your facility’s boiler and/or process heater. The full names of Boiler MACT and GACT as published in the Federal Register 40 CFR Part 63, is as follows: Boiler GACT (Generally Achievable Control Technologies), in short refers to the USEPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Source: Industrial, Commercial and Institutional Boilers. Boiler MACT (Maximum Achievable Control Technology) refers to the USEPA’s NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.
The Four Rules
To figure what rule applies to your facility, you first need to understand the Boiler MACT basic 4 rules. Boiler MACT is used in a generalized form to include the following specific rules: Continue reading “Meeting Compliance Schedule and Requirements of Boiler MACT”
Storm Water Violations Associated with Vehicle Washing
A common source of storm water pollution at industrial facilities is vehicle wash water. Any vehicle wash water that discharges from the facility to the outside would be in violation under the Storm Water Permit. In fact, Georgia Environmental Protection Division (EPD) has specifically mentioned that they will evaluate vehicle washing activities while conducting site inspections. Additionally, the U.S. EPA and the U.S. Justice Department have issued citations to several ready-mix concrete plants for failure to maintain best management practices associated with vehicle washing activities. Monetary penalties for these vehicle washing citations totaled $360,000. Continue reading “HANDLING OF VEHICLE WASH WATER”
Those familiar with the Process Safety Management (PSM) of Highly Hazardous Chemicals standard understand the importance of compliance audits of the program as well as the large scope of work the PSM program requires. The PSM standard is now over 20 years old. A proper PSM program will address the following areas: Continue reading “AUDITING OF THE PROCESS SAFETY MANAGEMENT (PSM) OF HIGHLY HAZARDOUS CHEMICALS PROGRAM”
Step #1: Identify
Ask the inspector for his/her business credentials (photo identification with a serial number), business card, and the reason for the visit. If the reason is an employee complaint then request a copy of the complaint that was made to the OSHA office. Continue reading “DEALING WITH AN OSHA INSPECTION”
Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the EPA or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random. Continue reading “STAYING IN COMPLIANCE WITH AIR QUALITY REGULATIONS”
NFPA 652, Standard on Fundamentals of Combustible Dust is a new combustible dust standard that is currently under development by the National Fire Protection Association’s Fundamentals of Combustible Dusts Committee. The committee will be holding its second Draft Meeting in St. Petersburg, FL, which Brian Edwards, PE will be attending to learn more about the direction of the standard.
In its current form, NFPA 652 is designed to be the single standard that will be used in addressing general combustible dust compliance at facilities. It will be the standard that all of the industry specific standards cite in regards to providing the specific properties and tests for determining whether a dust is combustible, as well as requirements for collection of the samples. Continue reading “New NFPA 652: Standard on Combustible Dust”
Flame resistant clothing (FRC) has been used for years in a number of industries to protect workers from flash fires, arc flash, embers, molten metal, and other potential sources of ignition to clothing. The reason FRC is so important is that many fatalities have occurred because a worker’s clothing has caught on fire, exposing him/her to burning heat for a much longer time than would have occurred during the initial event (e.g. arc flash, vapor flash fire). Continue reading “Conversion Technology engineers to wear FRC when conducting Combustible Dust Hazard Analysis”
OSHA has implemented a National Emphasis Program (NEP) to raise awareness of the dangers associated with isocyanate exposure.
Isocyanates are hazardous chemicals that are often found in activities using paints, foam insulation, polyurethane, surface coatings, rubber, and adhesives.
They are powerful irritants to the mucous membranes of the eyes, nose, and throat. Hazardous health effects associated with occupational exposure to isocyanates include irritation of the skin and mucous membranes, hypersensitivity pneumotitis (inflammation in the lungs), and chest tightness. A more serious hazardous health effect resulting from exposure to isocyanates is occupational asthma. Occupational asthma is an illness that can make it difficult to breath and causes chest tightness, wheezing, coughing, and shortness of breath. It is frequently serious and can be fatal. Isocyanates also include compounds that are classified as potential human carcinogens and have been known to cause cancer in animals.
Continue reading “Are your employees at risk of isocyanate exposure?”
The new Globally Harmonized System (GHS) is upon us. OSHA, with help from the U.N. and global community, has updated the HazCom Standard in an effort to standardize and simplify the communication of chemical hazards. Before this new system, a worker handling drums of flammable material from different manufacturers could notice an array of different warning labels. One manufacturer could have labeled the material as “Flammable”, while another could have labeled it as “Extremely Flammable” or even “Caution Flammable Vapors”. The material is all the same, but now there is confusion as to the level of the hazard present. It is for this reason why the GHS is here.
Continue reading “OSHA GHS Deadline Approaching Fast…Are You Ready?”
On January 31, 2013 the U.S. Environmental Protection Agency (EPA) published in the Federal Register the final rule 40 CFR Part 63: National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.
Continue reading “Regulatory Update for Major and Area Source Boilers (MACT/GACT)”