Chemical & Pharmaceutical

Chemical

Trinity helps chemical and pharmaceutical manufacturers to achieve regulatory and environmental compliance with complex environmental regulatory requirements while producing the chemicals and pharmaceuticals on which people depend.  We have completed nearly 400 projects for chemical and pharmaceutical clients in the last two years.  These project experiences, combined with our individual involvement with various associations and support groups, keep us informed about the many issues facing these industries.

Regulatory Round Up

Both chemical and pharmaceutical facilities recently have been burdened with a number of additional emission control requirements, in the form of Maximum Achievable Control Technology (MACT) standards.  The cost of the emission control equipment, in conjunction with the necessary administrative systems, has placed additional financial burden on the already strapped resources of these companies.

A significant regulatory concern for both of these industries includes the Miscellaneous Organic Chemical Manufacturing and Coating NESHAP (MON) and particularly for the chemical industry, the Organic Liquid Distribution MACT.  The MON is projected to impact several thousand facilities with batch processing operations.  Older facilities will be most significantly impacted through the required controls of wastewater streams.  Modifications to the proposed MON to modify the requirements for soluble Hazardous Air Pollutants (HAPs) is an important change to minimize the potential impacts of this regulation.

With the promulgation of the New Source Review reform elements and the implementation of MACT requirements, the chemical and pharmaceutical industries will have to assess their compliance status in order to minimize future production costs while increasing production responsiveness to market demands.

Project Profiles:
  • For a multi-national chemical company, T3, a division of Trinity Consultants, developed an EMIS to obtain the production data, laboratory data, and inventory information from existing data management systems.  These consolidated data were used to prepare regulatory reports for air, water, waste and community right-to-know environmental programs.
  • For a polyether/polyols chemical production facility, Trinity helped to implement a start-up, shutdown, and malfunction (SSM) monitoring tool.  With the change in the 40 CFR 63 Subpart A requirements for the reporting of SSM events, this tool enables the facility to easily track, record and report SSM events as required by the MACT requirements.
  • For a chemical manufacturing facility, Trinity characterized the emissions and waste discharge from production activities at the site.  The facility used this analysis to evaluate its compliance status with regard to a number of environmental programs. In an unforeseen side benefit, the organization identified operational improvements to improve the efficiency of emission control equipment and other processes at the facility.