KPA Blog

Environmental

Now is the time to prepare, evaluate, update and implement your SPCC Plan

Sunday, August 1st, 2010

Compliance Tip of the Month

This year brings the hottest climate to the current state of environmental issues, and with the current focus of disasters such as the BP oil spill, enforcement is increasing and the consequences of non-compliance are expensive and potentially devastating.

The SPCC Rule essentially requires specific facilities to prepare, amend, certify, and implement an SPCC plan, thereby ensuring containment and countermeasures that will prevent oil discharges. Some elements of an SPCC plan include ensuring staff has undergone SPCC specific training, preparation of monthly self-inspection procedures and documentation, and a Five-year Plan review.

For more information, please see http://www.epa.gov/emergencies/content/spcc/index.htm

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New Underground Storage Tank Operator Training Requirements

Thursday, April 29th, 2010

The US Energy Policy Act requires all States that receive federal grant money for their UST programs to ensure that all operators of UST systems demonstrate competency on how to comply with UST rules so environmental releases can be prevented. These new rules have created a training and registration program requirement for underground storage tank operators.

Operator training will require owners and their designated employees to undergo training to become certified UST operators. Once the deadline has passed, refuelers will not be allowed to deliver to facilities that have not met the new requirements. The type of training an operator receives depends on the job functions they perform at their facilities.

The deadlines and specific requirements are going to vary from one state to another, but most states seem to be looking at a 2012 deadline. Some states, like California and Louisiana, already require UST Operators to meet similar training and certification requirements. Other states, like Florida, are choosing not to take the Federal money and may look at developing their own training requirements. For more information on the upcoming requirements you can review the Energy Policy Act, check with your state’s Environmental Protection Agency or contact your local KPA Representative.

A national UST operator training firm, PASS, has also prepared a summary of the latest regulations that can be used as a reference for your state.

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Green-Washing

Tuesday, April 13th, 2010

I was just reviewing an article on how the Federal government audited the Energy Star program and found that it suffered from a common trend these days referred to as “green-washing”.  “Green-washing” is where a corporation represents its products as being environmentally friendly even when they may not be.  This can be done by applying a little “Green-Spin”, or heavily weighting the benefits of a single feature without looking at the entire picture.  In the case of the Energy Star label the congressional audit submitted a Gasoline powered alarm clock that was the most energy efficient version on the market, not to mention the only version – what’s most alarming is that the government bought it!  The article from the New York Times is can be found here:  http://www.nytimes.com/2010/03/26/science/earth/26star.html

KPA has long had a practice of representing a metrics driven approach to rating the compliance of your facility and we believe that any submission for a “green” or “safe” program should be verified by a 3rd party to ensure the validity of the claim.  If you are approached by someone selling you a “Green” certification for your facility, ask the following questions:  Under who’s authority is the organization issuing this certificate?  Who verifies that my facility has met the qualification criteria?  What percentage of applicants are certified as Green?  If you don’t like the answers to these questions ask yourself how the public will respond if the certificate issuer makes news like the Energy Star program.  I do believe there is a great benefit in Green certification, but not until standards are developed that can be independently verified.

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Halogenated Solvent Cleaning Rule – How Does it impact me?

Friday, April 9th, 2010

The Federal Halogenated Solvent Cleaning Rule compliance deadline is coming up on May 3, 2010.    I’ve heard of some mis-information among clients using parts washers, and an incorrect interpretation that all parts washers now have to be aqueous. In fact, I hear there is a waste hauler trying to use this rule as a way to sell very expensive aqueous parts washers.  Please read below for a quick analysis or review the final rule. 

What does the rule say?

The rule is designed to limit the emissions of Halogenated Solvents from parts cleaning operations.  The rule sets the following limits for Halogenated Solvents:

Solvents emitted Emission limits in kg
PCE (Perchloroethlene aka Tetrachloroethylene) 4,800
TCE (Trichloroethylene) 14,100
MC (Methylene Chloride) 60,000

 

What does this mean to me?

In most cases… Nothing.  Unless you are actually using halogenated solvents in your parts washers, you will not be affected by this rule.  Most solvents in parts washers are mineral spirits/stoddard solvent and do not contain halogenated solvents.

For instance here are Safety Kleen’s listings

You may notice that their recycled 105 solvent does contain PCE, however it is .2% by volume, meaning in order to get to 10,500 lbs of emissions for the year would take A LOT of solvent (think cleaning off a cruise ship).

If you are in fact using halogenated solvents in your parts washers… Yikes! Complying with this particular rule is the least of your problems… It’s really time  to change your parts washer solvents as using these solvents is very harmful to your employees.

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Secure Oil Distribution Pumps Daily to Avoid Slippery Situations

Monday, March 1st, 2010

Recently a dealership experienced a 500-gallon release of new lube oil when overnight one of the overhead lube oil distribution lines sprang a leak. The air powered pump at the oil tank detected a pressure drop and fired off. With no one around to see the oil spewing out of the broken line, it kept operating until the entire contents of the tank had been pumped out onto the shop floor, creating a tremendous mess. Many dealerships fail to secure the supply of compressed air to these pumps at the end of each workday. Thus any pipeline failure could result in a similar incident.

If your dealership operates these air driven oil distribution pumps it is important to ensure that, after hours, the supply of compressed air to these pumps is secured. A common way to achieve this is to shut off power to your air compressor and bleed your air lines. You may have other procedures that would work as well but the key is having an employee in charge of the process every day.

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Top Three Myths about Workplace Injuries

Thursday, February 4th, 2010

I just read this great article “Top Three Myths about Workplace Injuries” in EHS Today. A summary of the Myths:

Myth #3 – You cannot create a hazard-free workplace – It requires discipline and diligence to recognize and mitigate every hazard.

Myth #2 – Being safe takes too much time and money – If you feel that being safe takes too much time and money, you have an attitude problem.

Myth #1 – Accidents just happen – Research shows that over 99 percent of all accidents are preventable.

I completely agree that these are major myths. Wayne Curtis wrote an article in our latest newsletter about two shining examples of Group 1 Automotive and Penske Automotive Group how these issues can be managed. Though both groups consist of nearly 100 dealer rooftops, these Groups have effectively managed their compliance scores of environmental and safety issues to an unbelievable 97 – 98% and have held this level of compliance consistently. To put this in perspective, we target approximately 85% to be the average compliance score for a new facility prior to getting started with KPA. Both Group 1 and Penske Automotive Group are not only reaching high level of compliance across one store, they are doing it for all stores, across all States. Essentially, Group 1 and Penske have managed their compliance program to virtually spot free facilities in less than one year. This once more shows that all it requires is discipline and diligence to recognize and mitigate every hazard.

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Tip of the month: check if you meet the new SPCC rule compliance dates

Friday, January 1st, 2010

Self Certification An Option Starting January 14th 2010

Compliance-TipAfter an 11 month delay for additional public comment the EPA has finalized the December 2008 amendments to the Spill Control and Countermeasures Plan (SPCC) rules. If you recall, last year’s amendments were to reduce some of the regulatory burden on smaller oil handling facilities such as yours. As it turns out, the changes resulting from the extended public comment period have not had any impact on the amendments in your business sector. As with the previous rules if your facility has an aggregate storage capacity of over 1,320 gallons (including 55 gallon drums) of petroleum products, these amendments will affect your facility.

For more information about this upcoming rule change, read more in our January newsletter or join our SPPC webinar on January 14.

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Tip of the month: every facility conducting spray coating must file notification with EPA before January 10

Monday, December 7th, 2009

compliance tip of the month

An initial notification letter or a petition for exemption has to be filed with EPA regarding compliance with 40 CFR Part 63, Subpart HHHHHH (also referred to as the 6H rule). Every facility conducting vehicle spray coating operations must file an initial notification of compliance or a petition for exemption with the EPA by January 10, 2010. The initial notification is ordinarily submitted to both the EPA region where the facility resides, and the delegated regulatory authority, if any. Consult the list of delegated regulatory authorities (PDF) (2pp, 21k).

A free recorded webinar about the 6H rule is available to find out:

  • If you qualify for an exemption, and why you are probably better off not trying to claim the exemption.
  • Requirements for new facilities, and why your definition of a new facility is probably not the same as the EPA’s definition. For example, if you install new paint equipment the EPA may reclassify your shop as a “New Facility”

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