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Hello fellow environmental professionals!
I have been in the environmental field for 20 years now, starting with my first internship at the Ohio EPA while still at BGSU (1991-1992), followed by 10 years as an environmental specialist 2 (1993-2003), and this month, I am celebrating 8 years as an environmental consultant/contractor (and small business owner)! As a result of this milestone (and my rapidly approaching 40th birthday), I have been evaluating the distinction between being a consultant vs a contractor (see "What is an Environmental Consultant" below) in an ongoing effort to ensure that I am developing in my career while providing the best possible service to you.
The environmental field has changed a lot in the past 20 years but not much is different as often the old becomes new again. Recall "man-made global warming", now repackaged as "man-made global climate change"-- just as bogus but a great way to impose new regulations on non-pollutants like carbon dioxide. Consider the Ohio EPA, Division of Materials and Waste Management (see below). Nuff said!
While my newsletter is issued quarterly, I do post updates to my website (www.endlish.com) as rules become finalized or just in general "things you should know". I am also still developing the "environmental toolbox", which makes a trip to the website worthwhile as well. If you hear of any environmental news or find a good tool online that might be of interest or use to others, please let me know-- sometimes you hear things from the industry associations before they trickle down to everyone else! Working together helps everyone be more productive! Kumbaya!
If you need assistance, I am here to help! ~Tammy
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Reminders
Ohio EPA Reports
07/20/2011, 08/20/2011, 09/20/2011: Monthly DSW discharge monitoring reports are due.
07/20/2011: Semi-annual DSW discharge monitoring reports are due.
07/20/2011: eGGRT registration required for companies required to start reporting GHG emissions. More details below.
07/31/2011: Second quarter (April through June) 2011 DAPC reports are due.
Past Due:
Miss your Toxics Release Inventory (TRI) deadline on 07/01/2011? Better late than never!
Other:
Remember to update your SPCC plan every 5 years (from the date of the last revision) or whenever something significant changes (even a change in responsible personnel warrants a revision). SWP3 need to be updated whenever something significant changes as well!
The SPCC plans also need to be updated to comply with the new rules by November for most facilities.
Worried that you missed a report deadline? Check out our website at http://www.endlish.com for a list of past due reports.
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Environmental News
I aim to make the news fun!
"A Lesson in Efficiency"
In an effort to improve efficiency, Ohio EPA has combined the Division of Hazardous Waste Management (DHWM) and the Division of Solid and Infectious Waste Management (DSIWM) into the new Division of Materials and Waste Management (DMWM), not to be confused with the previous version DSHWM from years past before they were separated to be more efficient. Guess the party in office gets to define 'efficiency'-- more people to do the job or less people on the payroll. I'm just sayin'... ;D "GAG... ahem, GHG Reporting"
EPA issued a final rule that extends the deadline for reporting 2010 data under the Greenhouse Gas (GHG) Reporting Program to September 20, 2011. Under the GHG Reporting Program, entities required to submit data must register with the electronic GHG reporting tool (e-GGRT) no later than 60 days prior to the reporting deadline = July 20, 2011 (although I've seen August 1, 2011 cited as a deadline too). For more information on the GHG Reporting Program, www.epa.gov/climatechange/emissions/ghgrulemaking.html. EPA has released the 16th annual U.S. Greenhouse Gas (GHG) inventory. The final report shows overall emissions during 2009 decreased by 6.1% from 2008. This downward trend was attributed to a decrease in fuel and electricity consumption across all U.S. economic sectors. Total emissions of the six main greenhouse gases in 2009 were equivalent to 6,633 million metric tons of carbon dioxide. These gases include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride. For more information, go to: www.epa.gov/climatechange/emissions/usinventoryreport.html
"I Don't Know What This Is But It Sounds Important"
Draft Pretreatment (OAC 3745-3) and Indirect Discharge (OAC 3745-36) Program Rules At this time, the Agency is soliciting comments on draft revisions to the pretreatment and indirect discharge program rules. Minor revisions are planned to these rules as part of the five year review process. The comment deadline for these rules is July 20, 2011. For more information, please go to www.epa.ohio.gov/dsw/rules/draft_pretreatment_jun11.aspx. "Who Is Qualified To Qualify The Qualified Individual?" EPA's final rule on Protocol Gas Verification Program and Minimum Competency Requirements for Air Emission Testing was finally published in the Federal Register on March 28, 2010. The final rule requires that all 40 CFR Part 75 CEMS audits and certain other quality assurance testing be performed by Stack Testers and Stack Testing Companies (Air Emission Testing Bodies (AETB)) that meet specific competency standards, including experience and knowledge of test methods for individuals conducting the tests. This rule requires having at least one Qualified Individual (QI) on site conducting or overseeing the applicable tests being performed. A QI must pass the appropriate exam(s), described in ASTM D 7036-04, covering the test methods the QI will perform on site.
"Power Grab"
On March 16 the U.S. EPA proposed the first-ever national standards for mercury, arsenic and other toxic air pollution from power plants. The new power plant mercury and air toxics standards-which eliminate 20 years of uncertainty across industry-would require many power plants to install widely available, proven pollution control technologies to cut harmful emissions of mercury, arsenic, chromium, nickel and acid gases. It will also level the playing field for power plants nationwide making overpaying for utilities a national pastime. For more information, http://www.epa.gov/airquality/powerplanttoxics.
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What is an Environmental Consultant?
Contractor or Consultant?
I am often asked to define the difference between an environmental consultant and an environmental contractor in relation to my career choice and business services. This 4th of July weekend, during hours of kayaking on Lake Erie and roaming the beaches before the crowds hit, I have been considering this more thoughtfully, wondering where I truly fit in. So I did what any reasonable person would do-- I googled it! An environmental consultant is often a compliance consultant, ensuring that the client maintains an appropriate measure of compliance with environmental regulations. An environmental contractor completes various environmental projects (e.g., permit applications, reports) for the client. Endlish Environmental & Energy provides both services but more commonly the latter even though many clients could benefit from the former. As your environmental consultant, Endlish will meet with you (the client) and assess your facility's needs with respect to environmental compliance. This typically occurs through the environmental compliance assessment. Endlish will then provide a written report outlining the major environmental areas (air, waste, water), the applicable requirements, the facility's compliance status, and recommendations for improvement. If you need Endlish to complete the applications or reports necessary to achieve environmental compliance, Endlish then serves as an environmental contractor to complete the process. Often, a client will call and ask for help with a specific project. Typically these clients have well-established environmental programs but are too busy to complete the project in the timeframe required. Other times, a client will call when they are neck-deep in Ohio EPA or USEPA compliance issues and they need some help digging out. Endlish serves as a contractor for both but the latter would have benefitted from hiring a consultant early on to identify compliance issues, assess the record keeping systems, and ensure that all required applications and reports had been submitted. Violations identified and corrected prior to discovery by the regulatory agency still have potential for notices of violation (NOV) or even enforcement action but it is always preferable to have been proactive and have compliance achieved or well underway before the Agency discovers it. This can have a positive impact on whether enforcement action is pursued and any resultant penalties. The Agency does have enforcement discretion and they are not afraid to use it! |
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Environmental Compliance Assessment (ECA)
The purpose of the ECA is to ascertain the Air, Water, Hazardous Waste, and Solid Waste permitting and operating requirements for the client, to evaluate the client's current compliance status, to determine whether an SPCC plan (or update to current plan) is required, and to provide (and help implement) recommendations to achieve and maximize compliance. The annual follow-up ECA provides an opportunity to assess the environmental compliance program and to update the primary ECA report, as needed. If you are interested in setting up an ECA, please contact us. |
Energy Audit
Let's get "squiggy" with it!
Whether you are a homeowner or business owner, I can help you find ways to improve energy efficiency and save money! This service is not geared toward my industrial clients as most can get a free assessment from the utility company. Editorial Comment: Truthfully I am so disheartened by the SHORT lifespan of the squiggy bulbs that I am almost ready to change the company name again. I mean REALLY! My incandescents, put in at the same time as the squiggies, lasted longer! They're like little Energizer bunnies! I'm going to put 2 in the basement and hope they multiply since no one in the US is making these anymore. |
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Safety Audit
OSHA or MSHA
Currently, Endlish is not providing this service but I plan to hire someone if there is enough interest and need for this type of service. If you need assistance with your safety issues, please call and I can bring someone in to assist or provide a referral.
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By remaining a subscriber of my e-newsletter, you will be kept informed about changes in environmental & energy regulations, environmental & energy news, upcoming deadlines, and more.
If you have any questions about Endlish Environmental & Energy, would like a quote, or need environmental consulting (or contractor) services, please contact us!
Thank you for the opportunity to serve you and your company!
Sincerely,
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Tammy Endlish,Owner/Consultant
Endlish Environmental & Energy,
A Division of Endlish Enterprises LLC
Certified Energy Consultant
In support of our paper industry, please print out this newsletter a whole bunch of times... remember, kill a tree = save a job!
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