Document VJQxkOzzo7NYmpew8B92mVw78
U.S.A. REGULATIONS 1992 UPDATE
1. OSHA's Process Safety Management Act 1910.119
2. EPA's Clean Air Act Amendments (1990) Update
3. Stormwater Regulations
4. RCRA - Hazardous Waste Identification Rule
5. SARA Title III Form "R" Reporting
6. Louisiana Air Toxic Regulations
7. CFC's
8. Environmental Crimes Act of 1992
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ELEMENTS PROCESS SAFETY MANAGEMENT
1. Written Plan of Action for employee participation 2. Process Safety Information 3. Process hazard Analyses 4. Standard Operating Procedures 5. Training Program 6. Contractor Safety Awareness & Performance
Program 7. Pre-Startup Review Program 8. Mechanical Integrity Procedures 9. Hot Work Permits
10. Management of Change 11. Incident Investigation
12. Emergency Plan of Action 13. Compliance Audits
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14. Trade Secrets
CLEAN AIR ACT UPDATE
TITLE III: Air Toxics
Initial list of Categories of Sources - July 16, 1992
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174 industries requiring control of emissions of HAP
10 Tons per year of any HAP 25 Tons per year of any combination of HAP's
Polyvinyl Chloride and Copolymers Production Synthetic Organic Chemical Manufacturing 189 Substances - HAP Maximum Achievable Control Technology (MACT)
TITLE I: Provisions for Attainment and Maintenance of National Ambient Quality Standards
January 1993 - NJ Traffic Congestion & Air Pollution Control Act Companies with 100 plus employees at worksite 25% increase in average vehicle occupancy by November 1996
Approved plan by November 1994
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HAZARDOUS WASTE IDENTIFICATION RULE (HWIR)
BACKGROUND
Haz Waste - 1) 4 Characteristics 2) Listed F,K,U, or P
Broadened the universe of listed Haz Waste by:
"Mixture Rule" "Derived From Rule" "Contained-in Interpretation"
Example: K019/K020 Spill into waste water
Dec. 6, 1991 - Court Declared "Mixture Rule & Derived from Rule" unlawful
EPA temporarily reinstated Rule, April 1993
Proposed (HWIR) - EPA, May 1992 (CBEC) Concentration Based Exemption Criteria)
Tier 1 Soil EOC Soils
Leachate
Tier 2 EOC Leachate Leachate
EDC lOmg/kg .005 mg/kg (detection limit)
VCM 0.6
.05 mg/L .02 mg/L
.0005 mg/L 0.5 mg/L (detection limit)
0.2 mg/L
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LOUISIANA AIR LAWS UPDATE
DEQ ADOPTED AN AIR TOXICS PROGRAM ON 12/20/91
MOST INDUSTRIAL FACILITIES TO MEET TECHNOLOGY AND RISK-BASED CONTROL STANDARDS
STATE DEADLINES OUTPACE FEDERAL DEADLINES
97 CHEMICAL, INCLUDING AMMONIA, ON STATE LIST
FACILITIES MUST DEVELOP AN MACT STANDARD APPROVABLE BY DEQ
10 TPY/25 TPY "MAJOR SOURCE" DEFINITION
DEQ MOST DETERMINE PERMIT APPLICATION COMPLETENESS WITHIN 110 DAYS OF SUBMITTAL
NO "PERMIT SHIELD" FOR SOURCES NOT NAMED IN PERMIT
MODIFICATIONS MAY TRIGGER MACT NEW SOURCE REVIEW
COMPLIANCE PLAN MUST BE SUBMITTED By
EMISSION STANDARDS APPLY FOR:
- MERCURY - VINYL CHLORIDE - BENZENE EQUIPMENT LEAKS
- TRANSFER OPERATIONS - BENZENE WASTE OPERATIONS - ASBESTOS - BERYLLIUM - BERYLLIUM ROCKET MOTOR FIRING - VOLATILE LTAP EQUIPMENT LEAKS
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U.S.A. REGULATION 1992 UPDATE
Storm water Permit Application - October 1, 1992 CFC - July 1, 1992 CAA prohibits venting SARA Form "R" Reporting > Source Reduction and Recycling Activities > Energy Recovery > CFC's > RTKM > EPA Proposing to add 80 chemicals (RCRA Haz. Waste List)
Environmental Crimes Act of 1992
> Death or serious injury through environmental offence
$250,000 fine 15 years jail
> Environmental Audits by Court > $10,000 Rewards
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U.S.A. REGULATIONS
1992 UPDATE
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VINYL CHLORIDE SAFETY ASSOCIATION
OCTOBER 1-2, 1992 BALTIMORE, MARYLAND
Burley R. Melton Formosa Plastics Corporation
Livingston, New Jersey
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