Going Green

Many companies think about going green. Some even talk about going green. But still only a small percentage of companies today are taking that leap. Why? In most cases, the trepidation stems from a fear of the process. What is it going to cost? Will it bring me unwanted attention from regulatory agencies? Will it increase my liability?

D&W Incorporated, a company that supplies glass and mirrors to the recreational vehicles industry, had the same questions. The story of their going green is not a miracle story. It didn’t put them in the limelight in front of government regulators, and it didn’t cost them money. In fact, it had the direct opposite effect. It saved the company money, reduced their regulatory profile, and increased their operational efficiencies.

The company capitalized on the fact that it had made some process changes in order to make it more efficient. That, in conjunction with a reduction in the amount of Volatile Organic Compounds (VOCs) in their coating resulted in them being able to apply for and receive a transition to a lower air permit level, which reduced their regulatory profile substantially. This meant lower annual regulatory cost, red tape, and less cause for costly audits that can halt production unexpectedly.

The success story doesn’t stop there, however. This decrease changed business inside the four walls at D&W. It made cleanup easier at the end of the day, enabling the factory to reliably shut down every night—something they hadn’t done in years. They reduced their energy costs, solvent use, and other raw material consumption. And, low and behold, the product itself actually improved in quality.

The story isn’t finished, either. Going green is not just a one-time event. It involves adopting a process of identifying and taking advantage of green opportunities, which in many cases can help the bottom line as well.

If you’ve thought about going green but just couldn’t imagine that there would be any substantial impact to be gained, think again. As the story of D&W shows, even the slightest edge can make a huge difference in today’s highly competitive manufacturing industry.

Waste Profiling

Do you profile your waste? Believe it or not, this is a high-priority task for many manufacturing companies. And, unfortunately, it is one environmental issue that commonly slips through the cracks. Profiling means to determine the characteristics of the waste, and determine whether it is hazardous waste or non-hazardous waste. Profiling can be done using the MSDS to inform the landfill what is in the waste or by using a laboratory to analyze the waste.

Many industrial waste streams are categorized and disposed of as non-hazardous waste. This is fine as long as the generator is diligently keeping up with the requirement to profile the waste stream at appropriate times. It is the responsibility of the generator to ensure that the waste is being disposed of properly. Many waste management companies are very helpful in helping the generator assure this, but it is ultimately the generator's responsibility. In other words, if you placed your trust in a helpful hint or educated guess, the fault still falls back on you.

What's more, once a waste is improperly disposed of, it is much too late to change course. This may result in fines at the very least, and in egregious cases, criminal prosecution. That is why it is essential to be proactive and stay on top of all waste streams at your facility.

What follows is an actual account of one customer that DECA Environmental recently engaged.

A manufacturer had been using the same paint for years, and disposing of non-hazardous filters with a nearby landfill. As is customary, the landfill required companies to profile their waste every three years. The manufacturer's previous two samples had determined the waste to be non-hazardous. Why expect any different this time around?

But this year, the sample that was submitted was found to contain chromium (Cr) greater than the regulatory limit of 5 mg/l. After the results were received an immediate investigation was conducted to determine the source of the increased Cr. The manufacturer kept detailed records of the paint usage and subsequent emissions of VOCs and hazardous air pollutants (HAPs) as was required for compliance with their Air Permit.

DECA gathered purchase records from the paint supplier, and using their custom-built database software, determined the emissions. To date, no purchase records with new paints had been added to the source. However, the paint used to fill in sanded stainless steel parts was being used as a trial paint. Luckily, the filters were all still onsite and had not been disposed of in the non-hazardous landfill.

The potential issues if the filters were shipped off could have been very expensive. Let's go down the trail: The manufacturer (generator) would have offered filters (hazardous waste) to a non-hazardous waste permitted transporter. The transporter would have then transported the waste to a non-hazardous waste permitted landfill. The waste would have been improperly characterized to determine if it is hazardous waste or not.

Furthermore, improper labeling would have been on the containers. There would have also been Land Disposal notification and proper manifesting requirements. All of these issues would have been indicated on the citation and subsequent Agreed Order. This would have lead to a fine from the Indiana Department of Environmental Management (IDEM) Office of Land Quality. A typical fine could be as high as $25,000 for this type of issue.

As a generator, what should you be paying attention to? The following is a short list:

• Process changes such as changes in material usage or production techniques
• Changes in maintenance procedures
• Increases in production
• Changes in the utilization of production equipment that produces waste
  

These are just a few examples. Having a laboratory analyze your waste can be costly and is not always necessary. If the generator can conclusively demonstrate that nothing in the process has changed which would have caused the waste material in question to become hazardous, they may see much lower analysis costs. The operative word, however, is conclusively.

Could you be at risk? The costs of ignorance may be more than you can afford. A quick call to DECA may be just what you need to find out what, if any, risks you might have looming and what you can do to mitigate them.

Welcome to New Website

Welcome to our new website. We've always been a service-based company, so naturally we wanted our website to be a simple extension of our ultimate mission to serve you best. On our new site, you can now find valuable information including a library of relevant website links and news articles.

Coming soon, you will be able to access automated online tools online. We have developed and used these tools in-house for years. Once published online, purchasing agents, vendors, production personnel, and other stakeholders in your company will have access to valuable tools for meeting and maintaining environmental & safety compliance. Some of the features will include:

• Air Permitting records and reports online;
• NESHAP records and reports online;
• Calculations for EPCRA reports such as Form R and Tier II online;
• Regulatory Calendars online; and,
• An MSDS Library.

Finally, we're most excited about our new blog. We want to share our expertise, experience, and insights as we provide fresh content on up-to-date environmental issues facing your business. Please feel free to read, share, and even comment as you feel comfortable. We look forward to your feedback.

Reasonable Estimates for Woodworking PTE

The Indiana Department of Environmental Management (IDEM) Air Permitting section, in my opinion, has made some great strides. Currently, they have been hiring excellent people at all levels of the organization. This is resulted in more reasonable and technically correct permitting determinations. We recently had some success working with an IDEM permit writer. The process being controlled was a wood milling operation. The control device was a cyclone as the first stage, and a baghouse as the second stage. The company which manufactured the control device and their local distributor had excellent documentation of control efficiency for various sized particles. They also had a well described methodology for determining the outlet grain loading for their equipment, based on the amount of material collected in the hopper of the second stage, which the IDEM liked very much.

Only particles less than 100 microns are defined as "Particulate Matter" in the rules. This means that the IDEM has no legal jurisdiction to issue air permits based on the amount of particles present which are greater than 100 microns. Sawdust from woodworking operations contains only a very small percentage of Particulate Matter (particles under 100 microns). In the past there have been administrative barriers to getting reasonable estimates for PM/PM10 PTE from woodworking operations, but DECA is beginning to have some success in eliminating those barriers. We are dedicated to doing this for our clients, because DECA is committed to representing its clients in the regulated community well, and to obtaining reasonable, technically correct permitting decisions. This is good news for those industries who are currently suffering from unreasonable determinations made by the IDEM in the past.

Many industries that have woodworking operations are frustrated by the fact that the IDEM has historically over estimated their PM/PM10 PTE. Many companies are Title V or FESOP based solely on woodworking operations. In some cases, had a proper permitting determination been made, they would have only needed an Exemption Letter or a Registration. Instead they have to pay $3000 to get a Federally Enforceable State Operating Permit (FESOP) and then $1500 per year after that; or $1500 per year and $33 per ton for a Title V Permit. Many times, in order to get a reasonable estimate for PM/PM10, companies have had to do stack testing. DECA is leading the fight to gain reasonable estimates from the IDEM for PM/PM10 from woodworking operations without having to do stack testing. We are gaining ground, thanks to some good permit writers and administrators at the IDEM.

Integrated Air Toxics

EPA is close to promulgating the first national emission standards for hazardous air pollutants (NESHAP) for area sources engaged in paint stripping, surface coating of motor vehicles and mobile equipment, and miscellaneous surface coating operations. We predict this will go into the Federal Register early next year. This NESHAP potentially could apply to everyone in the above industry categories regardless of whether they are a major source of Hazardous Air Pollutants (HAPs) or not. (A major source of HAPs is one that produces more than 10 tons per year of one individual HAP, or more than 25 tons per year of all HAPs combined.)

This rule will be applicable only if methylene chloride (MeCl) is used for paint stripping; or, if coatings using any of the "target HAPs;" which include compounds of Chromium (Cr), Lead (Pb), Manganese (Mn), Nickel (Ni), or Cadmium (Cd); are used in the motor vehicle and mobile equipment or miscellaneous surface coating operations.

There will be an initial notification requirement, a notice of compliance status report, a MeCl minimization plan with an annual review for paint stripping operations, an annual notification of changes report, training for employees within 180 days and every 5 years, a requirement to keep records of the training, a requirement to keep records on the paint booth filters and documentation of the transfer efficiency of the sprayers, and records of any deviations from the standards.

DECA can help you evaluate whether this rule applies to your facility, submit the required reports, generate the proper records and plans, implement training, and track training. Please contact for us at deca@indy.net for more information.

Extension on FESOP and MSOP Permit Terms

The Indiana Department of Environmental Management (IDEM) is finalizing a rulemaking which will extend the permit term for Federally Enforceable State Operating Permit (FESOP) renewals and Minor Source Operating Permit (MSOP) renewals from 5 years to 10 years. The permit term for initial MSOPs and FESOPs will remain the same.

You can choose to implement this change only if you are on your second or subsequent renewal. This will be processed by the IDEM as either an Administrative Amendment (AA) for FESOPs, or as a Notice Only Change (NOC) for MSOPs. This basically means that the process for changing is relatively simple and no public notice period is necessary. Please contact DECA. We will be glad to help you apply for this change to your permit.

Notes on NFPA 33

Recently a client wanted to know why he had to ventilate his paint booth outdoors instead of back into the building. Off the top of my head I told him that it was a safety issue more than an environmental issue, and that the concentration of flammable vapors should not exceed 25% of the Lower Flammability Limit (LFL). This answer was only partially correct. Recently I viewed NFPA 33 (Spray Application Using Flammable or Combustible Materials 2007 ). This publication, and many others, as well as interpretations of various standards, can be purchased or viewed for free online at NFPA's website (http://www.nfpa.org/). Of course I added it to our handy dandy links page (http://www.decaenvironmental.com/LINKS.htm). You might want to bookmark our links page. It has a lot of useful links which are indexed for quick access and we are continuously updating it.

I learned many things, and I will be watching for these things the next time I visit a client who has a paint booth that they need to have permitted. Here are some of the things I discovered:

• You cannot use aluminum anywhere in the paint booth.
• You cannot make the paintbooth out of sheet metal less than 1.2 mm thick.
• There has to be a 3 foot buffer zone around the paint booth. The only exceptions are fireproof walls and ceilings. No flammable materials can be stored less than 3 feet away.
• You cannot move vehicles in and out of the paint booth without first stopping the painting operation.
• The paint booth ventilation cannot be recirculated if the paint booth is to be manned.
• If it is unmanned, air may be allowed to be recirculated, as long as certain conditions are met.
• Vapors must not exceed 25% of the LFL.
• Mixing rooms have to meet the same construction requirements as paint booths.
• Mixing rooms cannot exceed 150 square feet and must have containment.
• Air flow must be the least of either 1 cubic foot per minute per square foot or 150 cubic feet per minute in mixing rooms.
• There are many special requirements for electrostatic coating and powder coating, such as there must be optical flame detection with a 0.5 second response time.
• Miscellaneous spraying operations outside of a paint booth must have no spark producing equipment within 20 feet.
• There are many other interesting requirements. If you have a painting operation, you should check out the standard.

DECA Environmental

At DECA, our approach to environmental compliance is fundamentally different than the industry norm. We believe an environmental consultant should be a business partner who not only works to mitigate risk, but also reduces your expenses and increases your bottom line. Count on our expert consultants for all of your environmental compliance needs.

Environmental Compliance

Environmental Permitting

Data Management

Links

AIR LINKS

Rules
40 CFR-Federal Environmental Rules
326 IAC-Indiana Air Rules

Federal SIPs
SIP Rules Alabama-Louisiana
SIP Rules Maine-Appendixes

Permitting
IDEM Air Permitting Main Page
IDEM Air Permit Instructions
IDEM Air Permit Forms
IDEM Air Permit Status
R5-Indiana Permits

Non-rule Policy Documents
326 IAC 2

Industry Standards
NSPS Rules
NESHAP Rules
RACT, BACT, LAER Clearinghouse

Emission Statements
ISTEPs Software - Indiana
CHIEF

Emission Factors
AP42
WEBFIRE

Compliance
EnviroFacts Compliance
ECHO Online
ACC Forms and Guidance
OPPTA

Stack Testing
Emission Measurement Center
Promulgated Methods
Proposed Methods



LAND, WASTE, EMERGENCY PLANNING, AND SAFETY

Land
Phase 1 and 2
Superfund Acadamy
Brownfields Partnerships

Waste

Hazardous
RCRA Online
IDEM Hazardous Waste Information
Reporting Requirements

Non Hazardous Waste
IDEM Industrial, Special, and Restricted
Solid Waste

Other Wastes
Universal Waste
Used Oil

Recycling
Recycle Indiana
Recyclers World

Emergency Planning

Form R
Form R (TRIS) Reporting Material
TRI Explorer
Form R Query Form
IDEM Form R Page

Tier 2
Tier 2 Submit Software
IDEM Community Right to Know

Risk Management Plans (RMP)
EPA Main RMP Page
EPA CEPPO RMP Page
IDEM Community Right to Know

Safety

Chemical Safety
Fire Safety
NFPA
Other Safety

WATER LINKS

Wastewater Permits
IDEM Wastewater Permits
EPA Water Discharge Permits

Drinking Water Permits
IDEM Drinking Water Permits
EPA SDWA

Wet Weather Permits

Stormwater Plans SWP3
EPA Electronic NOI Submittal
Search NOIs
International BMPs DatabaseNFPA

Industrial
Rule 6
EPA Industrial Stormwater Guidance
State BMP Guidance

Construction
EPA Construction Guidance
IDEM Stormwater Quality Manual

Phase 2 Stormwater Requirements

Stormwater Plan Resources
EPA Resources
Web Soil Survey
Terra Server
Scorecard for Chemical Hazards

Combined Sewer Overflow (CSO)
Water Quality Certification Program

Environmental News

Contact Us

DECA Environmental & Associates, Inc.
410 1^st. Avenue NE
Carmel, IN 46032

p. 317.575.0095
f. 317.575.0096
sales@decaenvironmental.com

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DECA Associates

Environmental Attorneys
Plews, Shadley, Racher, and Braun
Bose, McKinney, and Evans

Environmental/Industrial Services
Mosner Energy Services
RS Used Oil (No Flash)
RS Used Oil (Flash)
CIM-Tech, Inc.
Bolin Enterprises

Stack Testers
Almega Environmental, Inc.
Air Analysis, Inc.

Industrial Hygienists
Workplace Safety and Health Company

Other DECA Associates
Air Applications, Inc.

Clients

• Adesa Auto Auctions
• ADM Asphalt Mixers
• Aluminum Recovery Technologies
• AMACOR
• Cathay Pigments
• Da-Lite Screen Company
• D&W Incorporate
• Elkhart County Landfill
• Floyd Crim and Sons Asphalt Paving
• Forest River
• Freudenberg Group
• GAF Materials Corporation
• Gerrisheimer Glass
• G&S Metal Consultants
• Kamic Corporation
• Metal Shred Industries
• MiTech Metals, Inc.
• Niblock Excavating Inc.
• Rieter Automotive
• Skyline Corporation
• Standard Asphalt Inc.
• The Braun Corporation
• UGN USA
• VIM Recycling
• Walsh & Kelly Asphalt

Contact us to learn how you can add your name to the list.

About DECA

Since 1994, DECA Environmental & Associates has provided clients with customized and cost-effective environmental compliance services. In November of 2000, the company underwent a change of ownership and expanded its risk mitigation service offerings to include chemical, fire, and other safety services.

Environmental Compliance

Avoid the fines and penalties caused by non-compliance.

At DECA, your success is our priority. We understand the importance of environmental compliance to a company's overall profitability and success. Our consultants will ensure your company avoids costly non-compliance fines and penalties by providing services that match your unique business operations and requirements. A few of the compliance services we frequently provide include:

• Recordkeeping;
• Reporting;
• Employee Training;
• NESHAP Evaluations; and,
• ISO 14001/Legal Requirement Audits.

Contact us today to discuss your environmental compliance needs and concerns.

Environmental and Compliance Training

Our consultants have years of experience in environmental compliance training. Our courses are designed to pass our valuable field knowledge directly to your staff. Our goal is to ensure your staff is up-to-date on necessary environmental requirements and have the knowledge to protect your company. We offer complete training in the following areas:

Annual RCRA Training
OSHA 40 Hour
OSHA Written Programs
Storm Water Plan Training
General HAZCOM Training
Chemical Specific HAZCOM Training

Contact us today to schedule a customized training session.

Environmental Permitting

Allow our experts to handle all of your permitting needs. We will coordinate the entire acquisition process. For many permits, our consultants will even provide inspection support and attend enforcement meetings. Below are some of the permits we frequently help clients obtain:

• Air Permits (Construction, Initial, Renewals, and Modifications);
• NPDES Permits; and,
• Marketing and Distribution Permits
• Stormwater Permitting
  
• SPCC Plans
  

To learn more about our permitting services, contact us today.

Services

Our consultants are experienced in a variety of environmental compliance areas. Based on your unique needs, we will assemble a plan that puts your safety, business goals, and profitability first.

Our Approach

Our experts have developed a unique, value-added approach to environmental compliance. While our forte is keeping clients environmentally compliant, we are also proud of our ability to eliminate unnecessary expenses and increase our client's profitability. Click below to learn more about each step of our value-added approach.

Investigate
We begin by performing a comprehensive assessment of your facility and processes. Understanding your unique operations, goals, and future plans is essential in developing a strategy for environmental compliance and increased profitability.

Innovate
We understand that environmental regulations may not have your company's best interest in mind. That's why we take a creative approach to helping your company achieve total environmental compliance while making sure not to compromise your business goals and initiatives.

Implement
Our goal is to deliver high-value services that match your exact needs while eliminating unnecessary services that result in over-inflated consultant fees. In short, we deliver everything you need and only what you need.

Insure
We are a partner you can rely on over the long-term. Our knowledge, experience, and proactive approach to environmental compliance allow us to meet your company's needs today and into the future as your company evolves.

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