Environmental Compliance Archives - BCA Environmental Consultants, LLC https://bcacaribe.com/category/environmental_compliance/ Environmental Consultant Fri, 30 Oct 2020 20:34:59 +0000 en-US hourly 1 https://wordpress.org/?v=7.0.2 183541680 RCRA Episodic Event https://bcacaribe.com/rcra-episodic-event-2/ Fri, 30 Oct 2020 20:34:58 +0000 https://bcacaribe.com/?p=829 Another component of the RCRA updates that has been of interest to some of our clients are the Episodiic Event clauses. 40 CFR 262.232 allows VSQGs and SQGs to generate waste from one (1) episodic event per calendar year. Or, may apply for a petition to generate waste from multiple episodic events in a calendar year.

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Another component of the RCRA updates that has been of interest to some of our clients are the Episodiic Event clauses.

40 CFR 262.232 allows VSQGs and SQGs to generate waste from one (1) episodic event per calendar year. Or, may apply for a petition to generate waste from multiple episodic events in a calendar year.

An episodic event is defined as an activity or activities, either planned or unplanned, that does not normally occur during generator operations, resulting in an increase in generation of hazardous wastes that exceeds the calendar month quantity limits for the generator’s usual category. The most common episodic events are from tank clean ours or specialized waste streams generated during plant shutdowns.

You may clean out tanks or shutdown more than once per year. If this is the case the EPA may grant a petition pursuant to 40 CFR 262.232(a)(1) and (b)(1). Under 40 CFR 262.233 a facility may petition to manage one additional episodic event per calendar year. This means at this time you may be allowed up to two (2) episodic events per year.

If this applies to you 40 CFR 262.233 identifies that the petition must include the following:

  1. The reason(s) why an additional episodic event is needed and the nature of the episodic event;
  2. The estimated amount of hazardous waste to be managed from the event;
  3. How the hazardous waste is to be managed;
  4. The estimated length of time needed to complete management of the hazardous waste generated from theepisodic event – not to exceed sixty (60) days; and
  5. Information regarding the previous episodic event managed by the generator, including the nature of the event, whether it was a planned or unplanned event, and how the generator complied with the conditions.

Publication Date: October 2, 2017
Version: 01
Author: Tony DeMarco, Vice President of Consulting Services

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]]> 829 Waters of the US Rule Update https://bcacaribe.com/wotus-2/ Fri, 30 Oct 2020 20:34:58 +0000 https://bcacaribe.com/?p=1817 The range of waterways subject to federal pollution regulations would be narrower under a hotly anticipated proposal released Dec. 11, but the Trump administration said it did not know the on-the-ground impact. The proposal is the administration's attempt to replace an Obama-era rule to better define waters of the U.S., or WOTUS, which are subject to Clean Water Act requirements.

The policy states that NPDES permits may be issued for any release of a pollutant from a pipe, drain or any distinct and discrete point source (such as an injection well) into groundwater that reaches federally protected waterway.

The post Waters of the US Rule Update appeared first on BCA Environmental Consultants, LLC.

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Source: Bloomberg Environment Quarterly Outlook

 

Defining Waters of the US is still under debate. As we stand the breadth of waterways subject to the federal pollution regulation could still narrow under a proposal released December 11, 2018. As of quarter four our current administration is unsure what the on the ground impact will ultimately be or should be. The proposal is the administration’s attempt to replace an Obama-era rule to better define waters of the U.S., or WOTUS, which are subject to Clean Water Act requirements.

 

The goal of the new proposal is to make it easier for a landowner to determine if a waterway on their property is subject to permitting requirements. Simultaneously the administration attempted to delay the WOTUS rule for two years, but this effort was struck down in several courts. It was rejected by several district court judges, who ruled that the administration did not follow proper procedures to suspend the implementation of an existing regulation. After an appeal attempt the Trump administration drop its challenges on March 8, 2019.

 

The existing Obama-era proposal from 2015 can be ambiguous on what the view of a WOTUS is, as it takes a broad view of which waters are and could be covered. The Trump administration wanted to take a narrower approach. At this point both the administration and opponents to the Trump-era proposal have not been able to narrowly define how many waterways would lose federal protection under the new definition.

 

“There is no nationwide map that estimates WOTUS,” Wheeler told reporters. Rivers, lakes, and estuaries still would be protected under the proposal (RIN:2040-AF75), while isolated ponds and wetlands that don’t connect to larger bodies of water would not, which was a hot topic when the Obama-era WOTUS rule was being proposed and discussed.

 

What is still not clear in either proposal is the status for “intermittent stream”, which are streams that only flow during some parts of the year and possibly only under certain weather conditions. Dave Ross, head of the EPA’s Office of Water, said the agency had developed a new way to determine whether these streams are eligible for federal protection. If a stream regularly flows into a larger body of water in “a typical year,” that stream is in, he told reporters. According to Blan Holman, attorney with the Southern Environmental Law Center has stated this “typical year” concept accomplishes the opposite of the administrations goal of simplification and narrowing the definitions. The reason this attempt of simplification could become burdensome is that Mr. Holman is stating it would require a landowner to measure a stream’s flow based on a 30-year rolling hydrological average. “Maybe if you have a statistics Ph.D you can do that, but I don’t think for the average person you can do that,” Holman, who has litigated in defense of the Obama administration’s WOTUS rule, told Bloomberg Environment.

 

In February the administration began a 60-day public comment period. After the comment each comment received will need to be analyzed before any movement may be made towards issuing a final rule. Even if the final rule is accepted and issued, it is expected by legal experts that the Trump-era WOTUS rule will be challenged in courts.

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]]> 1817 2020 Lead Auditor ISO 14001 and/or 45001 Courses https://bcacaribe.com/lead-auditor/ Mon, 18 May 2020 19:00:25 +0000 https://bcacaribe.com/?p=1556 This course utilizes Exemplar Global certified materials and satisfies the requirements for ISO 14001:2015 and ISO 45001 Lead Auditor Certification. The course is designed to improve your skills by bettering your understanding of 14001 and 45001, provide insights on how to prepare, perform and lead an audit and evaluate and communicate audit findings. This is a unique opportunity to receive two certificates in 4.5 days. Attendees may choose to complete one certificate in 3 days.

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Our ISO 14001 and 45001 Lead Auditor courses utilize Exemplar Global certified materials provided by Pillar Management Associates. Attendees may choose to earn one certificate in three days or both in as little as four days, making this a unique opportunity for EHS managers.

Register Here: Jasper

On site training is available if you prefer to set up a training at your own facility. Inquire at ademarco@bcacaribe.com 

Dates and Locations: 

  • August 3 – August 7 in Jasper, IN
  • Q1 2021 TBD in South Bend, IN

What will you gain?:

  • Understand the benefits of both ISO 14001 and ISO 45001 systems
  • Learn how to prepare, perform, and lead an audit
  • Learn how to evaluate and report audit findings
  • Satisfy the training requirements for two certifications in 1 week

Agenda:

DAY 1 (8:00 AM – 4:00 PM)

  • Course Overview
  • Environmental Management Systems
    • Understand the application of environmental management principles
    • Understand the application of environmental science and technology
    • Understand the application of environmental systems to different operational processes
    • Assess the risk of significant environmental aspects and impacts identified in the context of the organization’s EMS management system
    • Assess the effectiveness of methodologies to control environmental hazards
    • Understand the requirements of ISO 14001:2015
    • Operational control & legal compliance
    • Assess the EMS roles and responsibilities within the context of the organizational environment
    • Determine the adequacy and effectiveness of the EMS

Day 2 (8:00 AM – 4:00 PM)

  • Occupational Health and Safety Management Systems
    • Understand the application of OH&S management principles in the context of ISO 45001
    • Relate the OH&S management system to the organizational products, including services and operational processes
    • Understand the application of OH&S management principles
  • Evaluations; retesting as necessary

DAY 3 (8:00 AM – 4:00 PM)

  • Auditing
    • Understand the application of the principles, procedures and techniques of auditing
    • The conduct of an effective audit in the context of the auditee’s organizational situation
    • Personal attributes necessary for the effective and efficient conduct of a management system audit

DAY 4 (8:00 AM – 4:00 PM)

  • Mock Audit
  • Lead Auditing
    • Establish, plan and task the activities of an audit team
    • Communicate effectively with the auditee and audit client
    • Organize and direct audit team members
    • Prevent and resolve conflict with the auditee and/or within the audit team

DAY 5 (tbd: MAXIMUM 8:00 am – 12:00 pm)

  • Evaluations; re-testing as necessary. Note: there is no final exam. Competencies are tested throughout the course.

Deliverable: Handouts and attendees successfully completing the examinations provided in conjunction with this course receive a Certificate of Attainment for these Exemplar Global knowledge competency units:

  • EM – Environmental Management Systems; and/or
  • OH – Occupational Health and Safety Management Systems

Cost: $1,950 for dual certification and $1,500 for single certification

Early Bird Pricing of $1,750 for dual certification and $1,300 for single certification

Contact: Tony DeMarco | ademarco@bcacosultants.com | 574-213-3873

Register Here: Jasper

ABOUT THE INSTRUCTOR: 

Elizabeth J. Hill is a Senior Project Manager at BCA Environmental Consultants.  Since joining the firm in March of 2003 Beth has been involved in a wide range of project work. The primary focus has been managing the ISO 14001 program at a highly complex facility since 2006 and the Safety Management System at the same facility since 2011. The daily management of both systems including ongoing continual improvement exercise, management of internal audit teams, developing audit scopes, tracking corrective action records, management of objectives, conducting management review, identifying significant environmental aspects, hazard identification and reviewing and updating compliance obligations and procedures. Program management has also included implantation of OSHAS 18001 as well as transitioning ISO 14001 from 2004 to 2015 version of the standard. Beth has also provided primary support for facilities during their annual ISO 14001 3rd party audits since 2007 and for 6-month OHSAS 18001 cycle audits since 2011. These 3rd party audits have included transition, initial certification, surveillance, recertification and upgrade audits. Ms. Hill has, also conducted internal audits for OHSAS 18001 and ISO 14001 for a variety of clients totally over 1000 audit hours.

Beth has been providing Lead Auditor training since 2018. 

In addition to extensive Management System work she has been involved with compliance activities.  These projects have included emission inventories, compliance certifications and emissions recordkeeping and reporting.  Miss Hill has also prepared Emergency Planning Community Right to Know Act (EPCRA) Section 313 Form R and Tier II Reports.  Miss Hill has experience with a broad range of manufacturing operations including surface coatings, RV and mobile homes, pianos, diesel engines, fiberglass, meat rendering, biodiesel, automotive, steel mills, coke and coal handling facilities and foundries.   She has facilitated air permit activities including modifications, renewals, amendments, Plantwide Applicability Limits (PAL), Maximum Achievable Control Technology (MACT) and Best Available Control Technology (BACT) analysis.  Miss Hill has also done extensive work with GAP analysis for a variety of National Emission Standards for Hazardous Air Pollutants (NESHAP), NESHAP implementation, compliance programs and required reporting and recordkeeping.

In addition to practical experience Beth has also taught in the following training courses: ISO 14001:2015 Certified Lead Auditor, ISO 9001:2015 Certified Lead Auditor, ISO 45001:2018 Certified Lead Audits, ISO 14001:2015 Transition Training Course, and participated in the following training courses: ISO 14001:2007 40-hour Lead Auditor Training, Understanding and Implementing OHSAS 18001 16-hour Training, OHSAS 18001 40-hour Lead Auditor Training,  Elkhart Chamber of Commerce Environmental Health and Safety Conference, Indiana Chamber Practical Compliance with EPA Regulations and 10-hour OSHA

Miss Hill graduated with degrees in Environmental Administration and Political Science from the University of Evansville in Evansville, Indiana.

The post 2020 Lead Auditor ISO 14001 and/or 45001 Courses appeared first on BCA Environmental Consultants, LLC.

]]> 1556 ISO 14001 Podcast with Encamp https://bcacaribe.com/iso-14001-podcast-22320/ Wed, 29 Apr 2020 01:13:20 +0000 https://bcacaribe.com/?p=1794 The post ISO 14001 Podcast with Encamp appeared first on BCA Environmental Consultants, LLC.

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Encamp graciously invited us to join their podcast series to discuss ISO 14001. BCA has an extensive background in implementing, managing and auditing ISO systems including ISO 14001, 45001 and 9001, so we were happy to provide an overview of what ISO programs are and what the benefits are. This podcast is a good introductory for those that may be considering implementing an ISO 14001 program or are new to their companies existing program.

In this podcast we talk about where to start if you are implementing, the costs and time frame for implementation, the benefits of having a program and a general discussion about some key components of the ISO 14001 standard including Management of Change, Aspects and Impacts, Internal and External Issues, Operational Control and more. We also discuss the implications of COVID-19 and how a management system could be used to combat the affects the stay at home order is having on companies. It is an external issue that not many of us had plans ready to be implemented, but that will change for many companies moving forward after this experience. There may also be regulatory changes at OSHA in the future. We do not know what those hold yet, but many of us would not be surprised if there are distancing and sanitation standards that come out of this in the months and years to come. 

We hope you enjoy. This summer and fall BCA is hosting two Lead Auditor courses that utilize Exemplar Global certified materials. This course is a deep dive into ISO and is beneficial for those of you that are new to ISO and those with years of experience.

Our ISO 14001 and 45001 Lead Auditor courses utilize Exemplar Global certified materials provided by Pillar Management Associates. Attendees may choose to earn one certificate in three days or both in as little as four days, making this a unique opportunity for EHS managers.

Register Here: Jasper
Register Here: South Bend

The post ISO 14001 Podcast with Encamp appeared first on BCA Environmental Consultants, LLC.

]]> 1794 BCA Training Sessions https://bcacaribe.com/training/ Wed, 15 Jan 2020 22:25:08 +0000 https://bcacaribe.com/?p=797 In 2018 BCA has scheduled training events for air permitting, ISO 14001:2015, ISO 14001 Lead Auditing and ISO 45001 Lead Auditing. As events are added they will be posted.

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Exemplar Global Certified ISO 14001 and/or 45001 Lead Auditor Course

This course utilizes Exemplar Global certified materials and satisfies the requirements for ISO 14001:2015 and ISO 45001 Lead Auditor Certification. The course is designed to improve your skills by bettering your understanding of 14001 and 45001, provide insights on how to prepare, perform and lead an audit and evaluate and communicate audit findings. This is a unique opportunity to receive two certificates in 4.5 days. Attendees may choose to complete one certificate in 3 days.

Classes will be held the week of August 3, 2020 in Jasper, IN and a week to be determined in Q1 2021 for South Bed, IN.

Click here for more information and to register.

The post BCA Training Sessions appeared first on BCA Environmental Consultants, LLC.

]]> 797 Waters of the US Rule Update https://bcacaribe.com/wotus/ Wed, 16 Jan 2019 19:23:23 +0000 https://bcacaribe.com/?p=1555 The range of waterways subject to federal pollution regulations would be narrower under a hotly anticipated proposal released Dec. 11, but the Trump administration said it did not know the on-the-ground impact. The proposal is the administration's attempt to replace an Obama-era rule to better define waters of the U.S., or WOTUS, which are subject to Clean Water Act requirements.

The policy states that NPDES permits may be issued for any release of a pollutant from a pipe, drain or any distinct and discrete point source (such as an injection well) into groundwater that reaches federally protected waterway.

The post Waters of the US Rule Update appeared first on BCA Environmental Consultants, LLC.

]]>

Source: Bloomberg Environment Quarterly Outlook

 

Defining Waters of the US is still under debate. As we stand the breadth of waterways subject to the federal pollution regulation could still narrow under a proposal released December 11, 2018. As of quarter four our current administration is unsure what the on the ground impact will ultimately be or should be. The proposal is the administration’s attempt to replace an Obama-era rule to better define waters of the U.S., or WOTUS, which are subject to Clean Water Act requirements.

 

The goal of the new proposal is to make it easier for a landowner to determine if a waterway on their property is subject to permitting requirements. Simultaneously the administration attempted to delay the WOTUS rule for two years, but this effort was struck down in several courts. It was rejected by several district court judges, who ruled that the administration did not follow proper procedures to suspend the implementation of an existing regulation. After an appeal attempt the Trump administration drop its challenges on March 8, 2019.

 

The existing Obama-era proposal from 2015 can be ambiguous on what the view of a WOTUS is, as it takes a broad view of which waters are and could be covered. The Trump administration wanted to take a narrower approach. At this point both the administration and opponents to the Trump-era proposal have not been able to narrowly define how many waterways would lose federal protection under the new definition.

 

“There is no nationwide map that estimates WOTUS,” Wheeler told reporters. Rivers, lakes, and estuaries still would be protected under the proposal (RIN:2040-AF75), while isolated ponds and wetlands that don’t connect to larger bodies of water would not, which was a hot topic when the Obama-era WOTUS rule was being proposed and discussed.

 

What is still not clear in either proposal is the status for “intermittent stream”, which are streams that only flow during some parts of the year and possibly only under certain weather conditions. Dave Ross, head of the EPA’s Office of Water, said the agency had developed a new way to determine whether these streams are eligible for federal protection. If a stream regularly flows into a larger body of water in “a typical year,” that stream is in, he told reporters. According to Blan Holman, attorney with the Southern Environmental Law Center has stated this “typical year” concept accomplishes the opposite of the administrations goal of simplification and narrowing the definitions. The reason this attempt of simplification could become burdensome is that Mr. Holman is stating it would require a landowner to measure a stream’s flow based on a 30-year rolling hydrological average. “Maybe if you have a statistics Ph.D you can do that, but I don’t think for the average person you can do that,” Holman, who has litigated in defense of the Obama administration’s WOTUS rule, told Bloomberg Environment.

 

In February the administration began a 60-day public comment period. After the comment each comment received will need to be analyzed before any movement may be made towards issuing a final rule. Even if the final rule is accepted and issued, it is expected by legal experts that the Trump-era WOTUS rule will be challenged in courts.

The post Waters of the US Rule Update appeared first on BCA Environmental Consultants, LLC.

]]> 1555 HWGIR Overview https://bcacaribe.com/hwgir-presentation/ https://bcacaribe.com/hwgir-presentation/#respond Wed, 16 Jan 2019 16:38:14 +0000 https://bcacaribe.com/?p=1564 There were over sixty (60 changes made to the hazardous waste rule, some of which are more stringent and others that are less stringent. Changes can be broken down into three categories: provide greater flexibility, fill in gaps to strengthen environmental protection, and clarify certain components and address ambiguities.

The post HWGIR Overview appeared first on BCA Environmental Consultants, LLC.

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Based on conversations with IDEM we are expecting Indiana to adopt the HWGIR in its entirety in Q1 or early Q2 of 2019.

The Hazardous Waste Generator Improvement Rule (HWGIR) was signed on October 28, 2016 and published in the Federal Register on November 28, 2016 with an effective date of May 30, 2017. The HWGIR authorized states are able to go through adoptions and authorization processes but must adopt more stringent components of the rule. More stringent components must be adopted by July 1, 2018 or July 1, 2019, depending on if the state requires a law change. Indiana requires a law change so the deadline in Indiana is July 1, 2019. Authorized states may choose to pick up less stringent components of the rule.

Download [870.24 KB]

For additional information visit the EPA’ Frequently Asked Questions for  the Hazardous Waste Generator Improvement Rule. 

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]]> https://bcacaribe.com/hwgir-presentation/feed/ 0 1564 Exemplar Global 14001 and/or 45001 Lead Auditor Courses https://bcacaribe.com/14001-45001-lead-auditor/ Fri, 11 Jan 2019 03:08:05 +0000 https://bcacaribe.com/?p=887 This course utilizes Exemplar Global certified materials and satisfies the requirements for ISO 14001:2015 and ISO 45001 Lead Auditor Certification. The course is designed to improve your skills by bettering your understanding of 14001 and 45001, provide insights on how to prepare, perform and lead an audit and evaluate and communicate audit findings. This is a unique opportunity to receive two certificates in 4.5 days. Attendees may choose to complete one certificate in 3 days.

The post Exemplar Global 14001 and/or 45001 Lead Auditor Courses appeared first on BCA Environmental Consultants, LLC.

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DEADLINE FOR SOUTH BEND REGISTRATION – June 18, 2019


South Bend, IN, June 24 – 28, Register Here
Louisville, KY, October 7 – 11, Register Here

Overview: This course utilizes Exemplar Global certified training materials provided by Pillar Management Associates. This is a unique opportunity to earn two certificates at one time in 4.5 days. Attendees may choose to earn a certification in one of the standards in 3 days.

In March 2018 ISO published ISO 45001 OH&S Management Systems to replace OHSAS 18001.

What will you gain?:

  • Understand the benefits of both ISO 14001 and ISO 45001 systems
  • Learn how to prepare, perform, and lead an audit
  • Learn how to evaluate and report audit findings
  • Satisfy the training requirements for two certifications in 1 week

Agenda:

DAY 1 (8:00 AM – 4:00 PM)

  • Course Overview
  • Environmental Management Systems
    • Understand the application of environmental management principles
    • Understand the application of environmental science and technology
    • Understand the application of environmental systems to different operational processes
    • Assess the risk of significant environmental aspects and impacts identified in the context of the organization’s EMS management system
    • Assess the effectiveness of methodologies to control environmental hazards
    • Understand the requirements of ISO 14001:2015
    • Operational control & legal compliance
    • Assess the EMS roles and responsibilities within the context of the organizational environment
    • Determine the adequacy and effectiveness of the EMS

DAY 2 (8:00 AM – 4:00 PM)

  • Auditing
    • Understand the application of the principles, procedures and techniques of auditing
    • The conduct of an effective audit in the context of the auditee’s organizational situation
    • Personal attributes necessary for the effective and efficient conduct of a management system audit

DAY 3 (8:00 AM – 4:00 PM)

  • Mock Audit
  • Lead Auditing
    • Establish, plan and task the activities of an audit team
    • Communicate effectively with the auditee and audit client
    • Organize and direct audit team members
    • Prevent and resolve conflict with the auditee and/or within the audit team

Day 4 (8:00 AM – 4:00 PM)

  • Occupational Health and Safety Management Systems
    • Understand the application of OH&S management principles in the context of ISO 45001
    • Relate the OH&S management system to the organizational products, including services and operational processes
    • Understand the application of OH&S management principles
  • Evaluations; retesting as necessary

DAY 5 (tbd: MAXIMUM 8:00 am – 12:00 pm)

  • Evaluations; re-testing as necessary. Note: there is no final exam. Competencies are tested throughout the course.

Dates and Locations: 

  1. Jasper – July 30 through August 3 @ Hampton Inn Jasper, 355 3rd Ave., Jasper, IN 47546
  2. South Bend – October 15 through October 19 @ BCA Office, 224 West Jefferson Blvd., Suite 204, South Bend, IN 46601

Deliverable: Handouts and attendees successfully completing the examinations provided in conjunction with this course receive a Certificate of Attainment for these Exemplar Global knowledge competency units:

  • EM – Environmental Management Systems; and/or
  • OH – Occupational Health and Safety Management Systems

Cost: $1,950 for dual certification, $1,500 for single certification (Includes $500 for training materials)

South Bend, IN, June 24 – 28, Register Here
Louisville, KY, October 7 – 11, Register Here

Contact: Tony DeMarco | ademarco@bcacosultants.com | 574-213-3873

ABOUT THE INSTRUCTOR: 

Elizabeth J. Hill is a Senior Project Manager at BCA Environmental Consultants.  Since joining the firm in March of 2003 Beth has been involved in a wide range of project work. The primary focus has been managing the ISO 14001 program at a highly complex facility since 2006 and the Safety Management System at the same facility since 2011. The daily management of both systems including ongoing continual improvement exercise, management of internal audit teams, developing audit scopes, tracking corrective action records, management of objectives, conducting management review, identifying significant environmental aspects, hazard identification and reviewing and updating compliance obligations and procedures. Program management has also included implantation of OSHAS 18001 as well as transitioning ISO 14001 from 2004 to 2015 version of the standard. Beth has also provided primary support for facilities during their annual ISO 14001 3rd party audits since 2007 and for 6-month OHSAS 18001 cycle audits since 2011. These 3rd party audits have included transition, initial certification, surveillance, recertification and upgrade audits. Ms. Hill has, also conducted internal audits for OHSAS 18001 and ISO 14001 for a variety of clients totally over 1000 audit hours.

In addition to extensive Management System work she has been involved with compliance activities.  These projects have included emission inventories, compliance certifications and emissions recordkeeping and reporting.  Miss Hill has also prepared Emergency Planning Community Right to Know Act (EPCRA) Section 313 Form R and Tier II Reports.  Miss Hill has experience with a broad range of manufacturing operations including surface coatings, RV and mobile homes, pianos, diesel engines, fiberglass, meat rendering, biodiesel, automotive, steel mills, coke and coal handling facilities and foundries.   She has facilitated air permit activities including modifications, renewals, amendments, Plantwide Applicability Limits (PAL), Maximum Achievable Control Technology (MACT) and Best Available Control Technology (BACT) analysis.  Miss Hill has also done extensive work with GAP analysis for a variety of National Emission Standards for Hazardous Air Pollutants (NESHAP), NESHAP implementation, compliance programs and required reporting and recordkeeping.

In addition to practical experience Beth has also taught in the following training courses: ISO 14001:2015 Certified Lead Auditor, ISO 9001:2015 Certified Lead Auditor, ISO 45001:2018 Certified Lead Audits, ISO 14001:2015 Transition Training Course, and participated in the following training courses: ISO 14001:2007 40-hour Lead Auditor Training, Understanding and Implementing OHSAS 18001 16-hour Training, OHSAS 18001 40-hour Lead Auditor Training,  Elkhart Chamber of Commerce Environmental Health and Safety Conference, Indiana Chamber Practical Compliance with EPA Regulations and 10-hour OSHA

Miss Hill graduated with degrees in Environmental Administration and Political Science from the University of Evansville in Evansville, Indiana.

The post Exemplar Global 14001 and/or 45001 Lead Auditor Courses appeared first on BCA Environmental Consultants, LLC.

]]> 887 Groundwater Discharges https://bcacaribe.com/groundwater/ Thu, 30 Aug 2018 18:02:37 +0000 https://bcacaribe.com/?p=1504 EPA Policy 83 Fed. Reg. 7126, Feb. 20, 2018 regulates pollutants discharged from point sources to jurisdictional surface water via groundwater or other subsurface flow that has a direct hydrologic connection to the surface water.

The policy states that NPDES permits may be issued for any release of a pollutant from a pipe, drain or any distinct and discrete point source (such as an injection well) into groundwater that reaches federally protected waterway.

The post Groundwater Discharges appeared first on BCA Environmental Consultants, LLC.

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Groundwater Discharges

EPA Policy 83 Fed. Reg. 7126, Feb. 20, 2018 regulates pollutants discharged from point sources to jurisdictional surface water via groundwater or other subsurface flow that has a direct hydrologic connection to the surface water.

The policy states that NPDES permits may be issued for any release of a pollutant from a pipe, drain or any distinct and discrete point source (such as an injection well) into groundwater that reaches federally protected waterway.

The EPA requested comment through May 21, 2018 regarding whether EPA should review and potentially revise its previous statements concerning the applicability of the CWA NPDES permit program to pollutant discharges from point sources that reach surface waters via groundwater or other subsurface flow. Many comments were focused on the CWA and that on its face it does not regulate pollutant discharges into, through or from groundwater into surface water, regardless of hydrologic connection, and that the policy is outside the scope of the national permitting program.

Now, the Senate Environment and Public Works Committee Chairman John Barasso (R-Wyo.) is considering a bill that would overturn EPA policy 83 Fed. Reg. 7126.

Both sides of the debate are currently focused on the The Ninth Circuit February ruling in Hawaii Wildlife Fund v. County of Maui that said the county was responsible for wastewater pollutants found in the Pacific Ocean that had traveled from underground injection wells via groundwater. Maui County has already asked for an extension to petition to the US Supreme Court.

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]]> 1504 OSHA Update – Hazard Communication https://bcacaribe.com/hazard-communication/ Thu, 30 Aug 2018 17:51:38 +0000 https://bcacaribe.com/?p=1502 In 2019 OSHA will update how companies must communicate the hazards of chemicals they sell and export. The update will align OSHA requirements with the most recent version of GHS, released in July 2017.

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Hazard Communication

In 2019 OSHA will update how companies must communicate the hazards of chemicals they sell and export. The update will align OSHA requirements with the most recent version of GHS, released in July 2017. The update to GHS included changes to a variety of definitions and categories for chemical hazards, including new rules for how flammable gases should be classified.

OSHA aligned the two systems in 2012, but the United Nations program is updated every two years.

The agency plans to initiate the revisions by February 2019 (RIN:1218-AC93), according to the spring 2018 regulatory agenda.

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