STC Provides Hazardous Materials Management Compliance Support
Curt Johnson, CPEA - Richmond, TX
 Imagine if your company operated scores of facilities located throughout the country, many without fulltime staff, but most if not all of them having sufficient hazardous materials to be subject to certain permitting, emergency response and inventory requirements. How would you provide the resources to implement your hazardous materials management compliance program? Since 2003, STC's Curt Johnson has assisted Global Crossing with just such a situation.
Underneath Global Crossing's telecommunications services for onsite phone, data and internet access is the offsite global network hardware of intercity and intercontinental cables, servers, routers - and their backup power systems. "With STC managing our domestic hazardous materials requirements, it allows our network and systems engineers to do what they do best and keep the networks and internet traffic moving smoothly" says Lincoln Romain, Assistant Risk Management Director and Senior Manager EHS for Global Crossing.
STC has arranged for air permits for diesel generators, and helped set up easy-to-implement compliance plans. We have obtained permits for fuel tanks from state agencies and hazardous materials permits from fire departments. We have also prepared emergency response plans to meet the requirements of local fire codes.
The big push, however, is annual preparation of EPCRA Tier 2 Hazardous Materials Inventory Reports to reflect diesel fuel and the lead and sulfuric acid in back-up battery systems. Not that big a deal you say? Not if you're only handling one or a few facilities. STC's Project Manager, Curt Johnson estimates that a third of the states have unique reporting systems and 10 to 15 states change their reporting or fee requirements every year. "The trend had been towards standardized use of EPA's Tier 2 Submit software. Over the past few years, however, more states have migrated to internet-based systems specific to their state, and cities like Philadelphia and New York have their own unique reporting system as well."
There are literally thousands of different battery designs and models, each having a different weight of acid and lead, and a different volume of electrolyte, and the average life of a back-up power system is under 7 years. "As few as 9 of the larger batteries can put you over the 500-pound reporting threshold for sulfuric acid," says Johnson, "and spill containment requirements under the fire codes are based on volume of total electrolyte. We put together a reference library of battery information and manufacturer contacts. All the facilities have to do is tell us how many of what type of batteries they have and our database computes the rest."
"The first two years that STC's Curt Johnson took over our Tier 2 Reporting, our costs to produce the Tier 2 Reports were cut in half - twice," says Romain "and now, STC has been training my assistant, so that we can take over some of the reporting functions and reduce our costs even more."
Curt Johnson, CPEA, is a Senior Program Director located in Richmond, TX. He has more than 30 years experience in the development and implementation of environmental, health and safety compliance and management systems.
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