Approaches to MACT Compliance

April 15, 2005
Managing environmental compliance becomes more complicated and cumbersome every year. Fortunately, there are experts available to help.

Beginning this year, the U.S. Environmental Protection Agency is conducting a three-year study of MACT compliance in association with the Clean Air Act.

For some companies, hiring an environmental consulting firm to manage all aspects of the details of the effort to bring a facility into compliance.

August Mack Environmental Services manages compliance efforts with a customized program known as eCAP (compliance assurance program). By managing the compliance process, August Mack engineers are responsible for every aspect — permit development, plan preparation, and routine report tracking — all without direct oversight and direction from the plant operators.

Most significant is this: August Mack guarantees its clients will achieve MACT compliance. Clients are not charged for those service costs if the plant fails to achieve compliance, the company stresses, nor will they pay any penalty for non-compliance. The client will not face the charges, or August Mack will pay the fine.

Here’s how eCAP works. The client customizes its program by selecting modules to suit the area environmental health and safety (EH&S) needs of its facilities. Each module addresses a distinct issue and can be implemented individually, or in conjunction with any number of eCAP modules.

The base of the eCAP contract is the OSHA and environmental inspection module. It’s standard for all clients and it identifies any problems and provides means to solve them. Through regular communication and work with the plant personnel, and via regular on-site presence, August Mack engineers ensure consistent regulatory compliance and program improvement.

eCAP is different from other environmental consulting programs, says August Mack: The client’s EH&S staff continue with their routine duties while the eCAP engineers take control of the project, updating and briefing the client with a monthly point-by-point report.

The eCAP process is a simple five-step plan, beginning with the Environmental and Safety Compliance Audit. In this initial phase, the regulatory programs for the facility are established. The audit includes a complete review of records and a comprehensive inspection of all facilities, using the same inspection strategy used by the EPA and OSHA. This provides the client with a detailed summary of the regulations with which it must comply, and the current compliance status August Mack must address.

The audit reviews all the applicable records at the facility, including permits, plans, EH&S documents, and related reports. The list depends on the facility and the modules selected. Typical foundry clients use modules such as base air emissions, hazardous waste issues, chemical management and reporting, wastewater/storm water, SPCC (spill prevention, control, and countermeasures),and all OHSA reporting and maintenance.

Past regulatory communications (violation notices, consent orders, inspection reports) and all records maintained by regulatory agencies are reviewed. Current employees with jobs related to plant engineering, maintenance, production, purchasing and EH&S are also interviewed. An electronic record-keeping system is developed to organize on-site records as the process continues. Anticipated capital projects and plant extensions are also discussed during the audit.

Next, comes eCAP Compliance Review and Planning. August Mack engineers meet with the client’s management team to review the compliance status and plan for the year ahead. A wide range of variables are evaluated, including potential new regulations, possible facility process changes, increases in production, capital improvements, reduced waste generation, increased energy efficiency, and improved raw materials usage. Customized audit protocols are developed for routine inspections throughout the eCAP process.

The Site Inspection is next. August Mack assigns one of its environmental specialists as the contact for each account. The specialist routinely inspects the foundry, performing a customized audit to ensure ongoing compliance with all environmental and safety requirements. A typical eCAP program includes monthly inspections, though newer eCAP sites require more frequent visits. The amount of inspections increases in cases of special circumstances at the site.

August Mack installs an Electronic Record Keeping and Reporting process as part of its five-step plan. The online web portal is customized to manage all the compliance activities, reporting requirements, and necessary documentation. Each facility’s information is available on a password-protected site. (For multi-site eCAP clients, corporate environmental managers have access to Web pages for each of their facilities.) In addition to real-time access to the data, clients receive easy-to-read monthly reports that advise them how to remain current with their compliance program.

The portal hosts the site’s library of MSDS (material data safety) sheets, as well as a linedrawn facility map and a site map of outbuildings and land surrounding the facility. After each inspection, the resulting reports and list of immediate action items are posted on the facility’s Web page.

Finally, 24-hour Technical Support is available for every client. Each eCAP manager is accessible around the clock to answer client’s questions. The assigned August Mack staffer will address emergencies or unscheduled inspections by regulatory agencies.

For the past 10 years, Gartland Foundry in Terre Haute, IN has been working with August Mack on its compliance issues. President Bill Grimes says a determining factor assigning the project to August Mack was its familiarity with regulatory issues and officials, and with the Gartland facility.

“We had been with a different company previously, which promised the type of coverage that August Mack provides. However, there were many gaps, and that other company wasn’t able to come through in the end.

“August Mack has proven themselves to be reliable, dependable, and knowledgeable. They were the first ones to present this process and I believe we were one of the first ones to sign on.”

Grimes cites a particular point about the eCAP program that he appreciates. “The insurance policy is big for us. We don’t have the resources to keep a full-time enviromental person on our staff, and right now, their familiarity with our company has allowed us this benefit. And because they’ve been with us for so long, they’ve grown our compliance program to what it is today over the past 10 years. If anything does come up, we are able to just turn the regulatory people over to August Mack.”

Still, some foundries may not outsource their compliance projects: may find a program that can be established by its own employees.

Technikon operates the Casting Emissions Reduction Program (CERP),and has built the world’s first independent applied research foundry designed to test new materials and processes in a real-world foundry environment.

CERP planned, constructed, tested and brought on-line a 60,000-ft2, state-of-the-art casting facility and laboratories to evaluate various aspects of foundry emissions data. CERP testing capabilities includes: pouring, cooling and shakeout air emission testing; core-room product and process testing; development of new foundry processes; and modeling parameters that impact emissions from iron and aluminum casting processes.

In addition to the testing, Technikon offers services like development of air-emission measurement technologies; evaluation and development of methods for HAP and VOC measurement; foundry-specific air emission testing and development of emission factors; and various foundry studies.

By using the information and services provided by Technikon, a foundry may be able to use its own EH&S staff without having to outsource the compliance work.

Another compliance-program developer is RMT Inc., which offers to develop and execute “solutions to help our industrial clients sustain the environment while meeting their business objectives.” Its project teams may include regulatory, engineering, maintenance, and operating personnel from its clients’ organizations and RMT. The company states it views its projects as “long-term client relationships” and that it develops “innovative solutions that integrate technical, regulatory, and business expertise.”

Still another specialist in environmental engineering is Keramida Environmental Inc. Its engineers will develop programs that encompass environmental consulting and engineering for air, water, hazardous and solid waste, landfilling problems; remediation and assessment of contaminated properties. The firm also develops health and safety programs; training programs; audit programs for management systems (ISO 14000/OHSAS 18000); and develops regulatory programs.