Chemical & Pharmaceutical
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
EPA OIG’s Research on High Risk Chemicals Reported in TRI and RMP - Jun 15, 2016
Does your facility submit Form Rs or Form As for Toxic Release Inventory (TRI) reporting every year? Is your facility subject to the requirements under the Risk Management Program (RMP)? If your answer is yes to both questions, now is a good time to review the data reported to these two programs for consistency; if your answer is yes to one of questions, now is a good time to consider if the other program is applicable to your facility.
A recent memorandum revealed that the Office of Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) plans to begin preliminary research to identify unregulated facilities using data from the TRI. For the annual TRI reporting, facilities supply various data on toxic chemical releases and other waste management activities in Form R and/or Form A. These data then become public available. Due to the overlap of the regulated chemicals under different programs, the published TRI data can be utilized to identify deficiencies in other environmental programs such as RMP, National Pollutant Discharge Elimination System (NPDES) permitting and etc. Learn more.
EPA National Enforcement Initiatives Expanded to Include RCRA LDAR - Jun 15, 2016
If your plant operations include hazardous waste treatment, storage, or disposal facilities regulated under the Resource Conservation and Recovery Act (RCRA), now is the time for you to tune in! U.S. EPA’s on-going National Enforcement Initiatives (NEIs) targeting leaks, flares and excess emissions from refineries, oil and gas, and chemical plants are expanding to specifically address air emissions from hazardous waste generator and treatment, storage and disposal facilities and large product storage tanks. Under the expanded NEIs, EPA will emphasize enforcement for violations of the RCRA Subpart BB leak detection and repair (LDAR) requirements for the above mentioned RCRA facilities. Learn more.
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.
Adam Colt, Senior Consultant - Since joining Trinity in 2012, Adam has worked with a variety of industries and regulatory requirements. His projects have included third-party LDAR audits for refineries and chemical facilities, NSPS modification and reconstruction applicability analyses for chemical and natural gas processing facilities, detailed LDAR applicability for chemical sites, fugitive VOC/HAP emission calculations, Title V permitting, and compliance reporting under MON and MACT Subpart UU.
On one recent project, Adam assisted a chemical facility with LDAR program compliance under MACT Subpart UU. The project was high-resolution, down to specific P&IDs and components, and involved detailed regulatory determinations as well as program- and facility-specific recommendations for greater efficiency and compliance. For another client, Adam performed LDAR gap assessments at two natural gas processing facilities under NSPS Subparts KKK and OOOO and MACT Subpart HH. The project included process unit boundary evaluations, past project review for NSPS modification and reconstruction, VOC and HAP service evaluations, and regulatory applicability to process areas of the facilities.
Adam received a Bachelor’s degree in Chemistry from Tufts University and Master’s degree in Civil & Environmental Engineering from Carnegie Mellon University. Outside of work, Adam is an avid Ultimate Frisbee player and enjoys running the trails at the U.S. National Whitewater Center in Charlotte, NC.
- 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.