1. Environmental Environmental Health & Safety Environmental Protection Program

2. CAA regulations are estimated to produce the following impacts: 200 fewer expected cases of post neonatal mortality; 10,000 fewer asthma hospitalizations in children 1-16 years old, with estimated benefits ranging from $20 million to $46 million (1990 U.S.$); 40,000 fewer emergency department visits in children 1-16 years old, with estimated benefits ranging from $1.3 million to $5.8 million; 20 million school absences avoided by children 6-11 years old, with estimated benefits of $0.7-1.8 billion; and 10,000 fewer infants of low birth weight, with estimated benefits of $230 million. Slide 2 of Public Health Significance

3. Medium of Releases Air Water Land

4. Environmental Releases Generally are: –Permitted –Permit by rule –Exempt –de minimus –Spills –Uncontrolled releases (upset event)

5. Air Releases Clean Air Act promulgated in 40 CFR Part 50 – 99 TCEQ 30 TAC Chapter 101 - 122 Includes provisions for attaining and maintaining the national ambient air quality standards (“NAAQS”). Identifies six criteria pollutants (sulfur oxides, particulate matter, nitrogen oxides, VOC (ozone), carbon monoxide, and lead). Identifies non-attainment areas for criteria pollutants and requirements for SIP to achieve NAAQS.

6. Major Source Thresholds Attainment areas –Criteria Pollutants 100 tpy –Other pollutants 250 tpy –HAPs (NESHAPs) 10 tpy for any single chemical; 25 tpy total Non Attainment Areas –Emission limits vary by area classification

7. Major Source Thresholds (NAAQS)

8. Potential to Emit Potential to emit (PTE) - amount of pollution a source, or group or sources are physically capable of emitting in a year. –Based upon maximum hours of use –Total amount of fuel –Total amounts of chemical Emission Factors can be obtained from AP-42 documents

9. Major Source Permits and Authorizations Permit or authorization required before construction begins Permits include: –New source review –Prevention of significant deterioration –Flexible –Standard –Title V (federal operation permit)

10. Exempt Air Sources De Minimis facilities/Sources 30 TAC § 116.119(a) Permits by rule 30 TAC Ch. 106 –Covers sources including: Emergency Generators Boilers Print shops Wood working Laboratory Equipment Domestic heating & cooling Refrigeration units Pathological waste incinerators

11. Permit By Rule Source Limitations NOx 100 tpy & CO 250 tpy All other pollutants 25 tpy May require registration with TCEQ Documentation – 12 month rolling averages Pollution limits Apply to all sources in contiguous locations (common ownership & with ¼ mile)

12. Air Emissions Compliance Worksheets PTE Worksheet 12 Month Rolling Average Emergency Generator Use Log

13. Upset Events Applies to air releases in amounts greater than Reportable Quantity listed in –40 CFR 302.4 –Butanes, hexanes, propane 5000 pounds Emissions event - Any upset event or unscheduled maintenance, startup, or shutdown activity that results in unauthorized emissions from an emissions point

14. Water Releases Sanitary Sewer Laboratories Storm Water Facilities

15. Regulations Clean Water Act –Enforced by Environmental Protection Agency (EPA) and Texas Commission on Environmental Quality (TCEQ) –Includes: National Pollution Discharge Elimination Program (NPDES) or equivalent state program Surface Water Quality Standards Storm Water Pollution Prevention Plan (SWPPP)

16. National Pollution Discharge Elimination System Water permitting program Applies to point and non- point source discharges to navigable waters, e.g., POTWs, animal Feed lots, SWPP Permit requirements are based on TMDL and use classification of the receiving water body

17. Storm Water Pollution Prevent Permits A SWPPP is required for any project that disturbs one acre of soil or more SWPPP elements include training, key personnel identification, emergency response measures, and regular or special site inspections and maintenance of "Best Management Practices" (BMPs)

18. Storm Water Quality Management Plans Part of MS4 regulations Universities may be small MS4’s permitted by the state, or be co-permit holders with local municipalities Requires: –Identification of storm water conveyances –Structural controls –Best management practices to reduce pollutants e.g., litter

19. Spill Prevention Control and Countermeasures 40 CFR § 112 Capacity thresholds: –1,320 gal aboveground –42,000 gal completely buried Exemptions: –Completely buried tanks subject to UST regulation –Containers < 55 gal –Wastewater treatment facilities –Permanently closed containers –Motive power containers December 2006 Amendments AST <10,000 gal and meets discharge history may: –Self certify SPCC plan –Meet security and tank integrity without PE certification Oil-filled operational equipment –Inspection & monitoring program in lieu of secondary containment Program designed to prevent oil releases into navigable waterways by requiring certain facilities prepare oil spill control, countermeasures, and contingency plans Covers facilities that use, store, transfer, or consume oil or oil products

20. Exempt Water Releases Sanitary sewer discharges to a permitted POTW, or waste water treatment plant Gray water systems for onsite irrigation

21. Spills or Uncontrolled Releases Reportable Quantity list - 40 CFR 302.4 and 30 TAC Chapter 327 Diesel & Used oil – 25 gallons on land or amount sufficient to cause a sheen in a waterway Sodium hypochlorite – 100 lbs Bulked hazardous waste – 1 lb or 1 quart Solid hazardous waste – 40 CFR 302.4 Radioactive materials – 40 CFR 302.4 appendix B Biological/infectious waste – 100 lbs

22. Asset Releases

23. Why Worry About Asset Releases? Institutional assets represent significant liability issues –environmental releases –occupational exposures Regulatory requirements –Texas Health & Safety Code, Title 6, Subtitle C Substance Abuse Registration and Crimes, Chapter 481 Texas Controlled Substances Act, Section 481.077 (Chemical Laboratory Apparatus) –40 CFR part 82 Protection of Stratospheric Ozone –25 TAC chapter 289 Radiation Control –40 CFR part 61.150 National Emission Standards for Hazardous Air Pollutants –Memorandum of Understanding between DPS and THECB

24. Things to Consider Assets may possess hazardous characteristics –Biological, chemical, radioactive or physical –Non-Hazardous furniture –Inherently hazardous LS counters, mass spectrometers, monitors –Hazardous characteristic added Refrigerators, incubators, centrifuges –Chemical Laboratory Apparatus and precursor chemicals (compliance with MOU)

25. Chemical Laboratory Apparatus Condensers Distilling apparatus Vacuum dryers Three-neck flasks Distilling flask Tableting machines Encapsulating machines Funnels - filter, buchner, separatory Flask - Erlenmeyer, two- necked, single neck, round bottom, thermometer, filtering Soxhlet extractors Transformers Flask heaters Heating mantles Adapter tubes

26. Environmental Accounting and Communication

27. The more removed from “safety” –The idea becomes more abstract & requires better communication and accounting –Complex regulations –Must be put into “Context” for communicating to upper management In Addition –Public concern, outrage can be high –Involuntarily encountered –Little apparent benefit –Controlled by others –Unknown or substantial consequences Adding Perspective Free from identified hazards Immediate harm OSHA 300 Log Injury/inspection reports Exposures that could result in harm Possible precursor to safety concern Levels/limits Releases that could result in health or safety concerns Could affect health Ultimately affect safety

28. Environmental Reports Useful for communicating results with: –Upper management –Regulators –Safety committees –Public –Fellow employees Graphs vs. Excel Spreadsheets ?

29. Environmental Reports Define Waste Streams or Process Identify Waste Disposal Cost Obligations (disposal liability) Calculate Disposal Expenditures Calculate Cost Avoidances

30. Environmental Report Examples… Chemical Waste Programs Biological Waste Programs Radioactive Waste Programs Environmental Protection Program Summary Graphical Summaries

31. Expenditures Disposal Transportation Stop Fees Competitive Bids Packaging

32. Cost Avoidance Monetary value associated with an environmental program’s activities Increases with: –Large number of hazardous material users –Multiple satellite accumulation areas Accounts for intangible activities such as: –Personalized services –Emergency response –Historical knowledge –Value of compliance

33. Chemical Purchases Reports can be utilized to show cost of disposing unused portions Support just-in-time purchasing Segregate by chemical Total cost of purchases Cost of disposal

34. Important Undertones... Relate to business plan or mission statement Show environmental activities that enable the organization to accomplish goals Tying your environmental product to the bottom line Non compliance ramifications Embarrassment to the organization Public scrutiny Monetary fines

35. Parting Thoughts...at the end of the day...... Safety Committee and CEO Wish lists Losses Personnel Property Compliance External Internal Fiscal/Budget Over/under – How much does your program cost Service or satisfaction Happiness

36. Alan Lucas 1851 Crosspoint Ave. OCB 1.330 Houston, TX 77054 713-500-8104 Alan.Lucas@uth.tmc.edu Questions ?