Have you ever thought “Geez, getting an air permit in Washington State is way too complicated?”

Fotolia 68898096 Subscription Monthly M oil and gas refinery

The Washington Air Regulations are up for public comment and updating. There are two opportunities to comment open right now but closing soon!

This rulemaking is of interest to:

– Industrial and commercial business owners

– Air quality consultants

– Local governments

– Environmental, business, and civic organizations

– General public

Proposed changes to Controls for New Sources of Toxic Air Pollutants WAC 173-460  

– Updates the list of toxic air pollutants

– Recalculates some of the threshold values (acceptable source impact levels, small quantity emissions rates, and de minimis emission values)

– Comments are due by midnight on Tuesday, July 23, 2019. Click here to submit your comments online. 

Exploratory rulemaking for additional changes to Controls for New Sources of Toxic Air Pollutants

– Ecology is looking input on possible changes to its at its air quality program

– These rules are not open for revision very often, so it is a good opportunity to provide input.

– Comments are due by midnight on Thursday, August 8, 2019. Click here to submit your comments online.  

With TRI Data Facing Increased Scrutiny, Companies Should Consider an Audit to Ensure Compliance

Fotolia 68898096 Subscription Monthly M oil and gas refineryThe EPA’s Office of Inspector General (IG) recently issued a management alert related to inaccuracies in EPA’s publicly-available toxic substance release data. The IG discovered discrepancies between EPA’s public data and the internal data that the agency submitted to the IG related to the total number of pounds of toxic chemicals released between 2013 and 2017.

EPA collects data on toxic substance releases in part through the Toxic Release Inventory (TRI) program, through which industrial facilities report on their emissions and releases of chemicals and other hazardous substances.

Companies that submit TRI reports should take note of the IG’s audit and subsequent actions. In recent years, we’ve seen EPA take a more proactive approach in identifying and flagging errors found in TRI reports. With the IG’s audit ongoing and EPA itself facing scrutiny, the agency will likely increase its efforts to ensure that the data it receives via TRI Reports is accurate and sufficient.

In many cases, EPA has compared TRI reports to other submitted reports like emissions inventories and SARA 312 reports. When EPA comes across discrepancies in the pollutants emitted and/or the rate or volume of the pollutant, the agency will often give the source time to explain the discrepancy. However, oftentimes this investigation turns up more questions, so it’s best to stay ahead of the game and off of EPA’s radar.

It’s commonplace to treat annual reporting as a status quo procedure, which can lead to out-of-date emissions factors and faulty calculations. A third-party audit of your TRI report can help unearth these issues and ensure that you are meeting the latest regulatory requirements related to toxic substances. Have a third party look at the emissions factors to ensure they are the most accurate to use. Consultants can also compare all of your reports to ensure that process changes, changes to raw materials, and regulatory updates are all captured to ensure your facility is reporting the most accurate information.

SoundEarth frequently assists industrial facilities through the full process for TRI reporting. We help clients determine if a facility meets the requirements to submit a report, manage report preparation and data calculations, and review existing reports to ensure they stand up to recent regulatory changes.

If you have an existing TRI report or are currently working through your 2019 report, or if you’re unsure if you need a TRI report in the first place, contact Chris Kitchen or Annika Wallendahl. As a reminder, the deadline to submit 2019 TRI Reports is July 1.

Washington is Cracking Down on Respirable Silica Exposure. Is Your Company Prepared?

In April 2018, Washington State adopted a rule that further regulates employee exposure to respirable crystalline silica (RCS), following OSHA’s publication of a similar—but less stringent—rule in 2016. Washington’s rule went into effect for the construction industry in October 2018 and will go into effect for occupations outside of construction on July 1, 2019.

Many companies are familiar with OSHA’s version of these rules and the general issues surrounding employee exposure to RCS. But with tighter regulation looming in Washington, here’s what you should know.

AdobeStock 32650255 concrete silica dustFirst, A Brief Introduction to RCS and Its Health Effects

Crystalline silica is a mineral found in stone, soil, sand, concrete, brick, paints, plaster, and other materials often used in construction and industrial activities. It becomes respirable when those materials are cut, ground, drilled, crushed, or otherwise manipulated in a way that creates dust.

Inhaling dust that contains crystalline silica particles can lead to several health issues, including silicosis (an incurable lung disease), lung cancer, pulmonary disease, and kidney disease.

Who is at Risk for RCS Exposure?

According to OSHA, 2.3 million people in the U.S. are exposed to silica in the workplace. Industries with high exposure risk include construction, refining, mining, and manufacturing.

Washington State Regulation of RCS

Washington State’s rule is similar to the federal rule, but more stringent in some ways. In addition to setting standards on what concentration of RCS employees can be exposed to, the rule also lays out specific requirements related to:

  • Required assessment of employee exposure to RCS, including personal air sampling.
  • Exposure control methods, which define engineering controls and work practices related to 18 specific work tasks with high RCS exposure risk, including use of certain tools.
  • Required respiratory protection for employees.
  • Housekeeping/cleaning practices to minimize exposure risk.
  • Medical surveillance.
  • Training and recordkeeping.

What This All Means in Practice

Not only should companies operating in Washington consider a review to ensure that they are in compliance with the new rule, but there are permitting issues at hand as well. New permits may be required if a company is installing pollution control devices in response to the rule, or additional reporting on related emissions may be necessary.

SoundEarth frequently helps clients assess regulatory compliance related to RCS exposure and advises on needed workplace adjustments, permitting considerations, and other related issues. For more information on RCS regulation, how it might affect your business, and what you can do to protect your employees and your business interests, please contact Corey League, Chris Kitchen, or Annika Wallendahl.

The South Sound Environmental Managers Forum

SoundEarth covered the risks of RCS and the details of the new regulations at a recent presentation in our Tacoma office. This presentation was part of a series of events we host monthly, called the South Sound Environmental Managers Forum, aimed at providing timely information on topics affecting environmental professionals and providing an open dialogue and networking opportunity amongst industry peers. If you’re in Tacoma or the surrounding areas and work in a capacity similar to an environmental manager, please join us for the next Forum! Email us for more information.

SoundEarth’s Chris Kitchen Takes Home Excellence in Presentation Award for Young Professionals at AWMA Pacific Northwest Annual Conference

CJK Award Banner

Congratulations to SoundEarth’s Chris Kitchen, who won the Excellence in Presentation Award for Young Professionals at the Air & Waste Management Association’s Pacific Northwest International Section Annual Conference! Chris gave two presentations at the conference – one on developing dynamic Environmental Management Systems and one on keeping industrial facilities inspection-ready.

His presentation on keeping industrial facilities inspection-ready was the award winner. The focus was about being proactive, working with government regulators, and how to stay organized for the inevitable inspection.

The presentation started with an outline focusing on how to prepare for regulatory inspections, preparing all employees, and staying prepared from that point on. He went into the details of what basic information a facility manager would need to know before any inspection takes place, how to act during the inspection itself, how to procure pertinent information through self- and third-party audits, how to utilize the entire team at the facility, and ways to stay organized for future visits.

All in all a wonderful weekend full of useful presentations, and once again, great job Chris!

We Can Help You Care For Your Air

Fotolia 68898096 Subscription Monthly M oil and gas refinery

Good news!  SoundEarth has been Accredited as a Verification Body by the California Air Resources Board. Our team includes trained greenhouse gas verifiers, ready to perform verification services for greenhouse gas emissions data reports. 

Our air services team prides itself in being at the forefront of the ever-changing air quality regulations and having the capability to implement and ensure best practices that can impact all types of companies. SoundEarth provides comprehensive air permitting and compliance services. Some of these service areas include emissions of greenhouse gases, criteria pollutants, odors, and many more!