writing a report about alcohol regulations
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RegulatoryEnvironmentLecture1.pptxENCH 4300 – Chemical System Design
University of Tennessee - Chattanooga
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1
Outline
Introduction
EPA and State Roles
Pollution “Categories”
“Right to Know”
Process Safety Management (PSM)
2
Introduction
Environmental pollution – not a new problem
Natural vs. man-made
Strategies to reduce pollution
Prevention – unlikely
Remediation – your job
“Outside factors”
Once in the air, forget it
Piccadilly Circus in Pea-Soup Fog, 1952, unknown photographer
Environmental Law/Regulation in the U.S.
Sources of Environmental Directives
Federal statutes
State statutes
Executive orders
Judicial decisions
Implementation
Federal and state regulations
Hierarchy of Authority in Federal System
ISRP Iowa City, IA 2017
EPA and State Roles
Conduct research
Perform risk assessments
Set national standards
Monitor compliance
Enforce national standards
Develop state-level standards
Monitor compliance
Enforce state and national standards
Issue permits
EPA
States
Pollution “Categories”
Air
Water
Hazardous Waste
Toxics & Pesticides
Air Pollution Control - History
ISRP Iowa City, IA 2017
CAA & CAAA – Key Provisions
Clean Air Act (CAA) – 1970
National Ambient Air Quality Standards (NAAQS)
Emissions standards for vehicles and fuels
Clean Air Act Amendments (CAAA) – 1990
Air toxics
Stratospheric ozone layer
Acid rain
Commission on Risk Assessment and Risk Management (CRARM)
NAAQS and HAPs
NAAQS for criteria air pollutants
Pb, CO, PM, SO2, NOx, O3
Emissions standards based on human health and ecological risks
Standards reviewed every 5 years
Hazardous Air Pollutants (HAPs)
187 toxic air pollutants (e.g., benzene, asbestos)
Technology-based standards (MACT)
Potential to Emit (PTE)
Potential to emit – “maximum capacity”
Major source
PTE 100 ton/yr of criteria pollutants, 10 ton/yr of HAP or 25 ton/yr total HAPs
Very involved permitting requirements (public comments, MACT)
Minor source – everyone else
Synthetic minor source
Clean Air Act - Example
Your process generates 100 ton/yr dust -> this is your “Potential to Emit”
You are therefore a major source
You have a baghouse that is 99.9% efficient
Your actual emissions (pollution) are 0.1 ton/yr
You can apply to be a “Synthetic Minor Source”
Process
Pollution Control Device
Uncontrolled Emissions
Pollution
Water Pollution Control - History
ISRP Iowa City, IA 2017
CWA – Key Provisions
Establish effluent limitations
States and tribes set water quality standards based on EPA’s ambient water quality criteria
Create control technology standards for new industrial point sources
Publish list of toxic substances and associated effluent limitations
Establish the National Pollutant Discharge Elimination System (NPDES)
Clean Water Rule (CWR)
Clean Water Act
Overall concept: all discharges into nation’s water are unlawful unless authorized by permit
Point source pollution: discrete sources (e.g, pipes/spillways, culverts, raw sewage discharges)
Non-point source: (e.g., stormwater runoff from agriculture, construction, mining, city streets)
Obtain permits from EPA through National Pollutant Discharge Elimination System (NPDES) program
SDWA – Key Provisions
Establish national drinking water standards
Set Maximum Contaminant Level Goals (MCLGs) and Maximum Contaminant Levels (MCLs)
Regulate underground injections
Protect wellheads and aquifers
Ban lead-content plumbing materials
Water Pollutants
Conventional
Nutrients, solids, organic waste, conductivity, acidity (pH), salts, pathogens, oil and grease, dissolved oxygen, BOD, heat
Toxic
Mercury, zinc, chromium, nickel, cadmium, copper, silver, lead
Non-Toxic
Ammonia, chlorine, color, iron, total phenols
NPDES Permit Program
All point source dischargers need permits
Based on “standards of performance”
Technology-based or water quality/health-based
EPA criteria and permit guidelines
(Delegated) states issue permits
Effluent limits
Monitoring
Extensive recordkeeping and reporting
POTWs
“Publicly Owned Treatment Works”
Municipal sewage: residences, businesses, industry
Primary Treatment: physical removal
Secondary: Biological process: microbial oxidation (like self purification of a stream)
Tertiary: Chemical treatment; allows direct reuse; very costly, therefore rare
Hazardous Waste Regulation - History
ISRP Iowa City, IA 2017
RCRA Overview
Characteristic Hazardous Waste
I Can’t Remember Them
Ignitable: Flash point less than 140°F, or which readily burns
Corrosive: Substance that dissolves metals or burns skin, aqueous solutions with pH ≤ 2, or ≥ 12
Reactive: Substance that is unstable or undergoes rapid or violent chemical reaction with water or other substances
Toxic: those that exceed specific levels of heavy metals or pesticides
Listed Waste
Waste on one of several specific lists (“F”, “K”, “P”, “U”)
Usually defined by process: steelmaking, toluene, etc.
RCRA (cont.)
Generator Status
Large Quantity: 1,000 kg/mo of haz. waste or 1 kg/mo of acutely haz. waste
Can only store waste for 90 days
Keep someone on-site to respond to issues
Biannual reports, written contingency plans
Small Quantity
Can store waste for 180 days
Keep someone on-site to respond to issues
No requirement for written plans
Conditionally Exempt Small Quantity: generate less than 100 kg/mo
Cannot accumulate more than 1,000 kg of waste
Permitting
Treating, Disposing, or Storage
Exemptions for “elementary neutralization”
CERCLA/SARA Superfunds
Comprehensive – EPA can respond to “release” or “substantial threat” of release into environment of hazardous substance or pollutant/chemical that will endanger health or welfare
Environmental Response – EPA can remove the contaminant or remediate the site or both
Compensation – Superfund established $1.6 billion in 1980, increased to $8.5 billion in 1986 under SARA (Superfund Amendments and Reauthorization Act)
Liability Act – Potentially responsible parties pay. EPA can clean up first by accessing Superfund
CERCLA also established Agency for Toxic Substances and Disease Registry.
Pesticide Regulation – History
ISRP Iowa City, IA 2017
FIFRA – Key Provisions
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) –
Requires registration of pesticides
Regulates pesticide use
Gives EPA authority to remove pesticides from the market (suspend/cancel a product’s registration)
Toxic Substances Regulation - History
ISRP Iowa City, IA 2017
TSCA – Key Provisions
Toxic Substances Control Act (TSCA) includes –
Title I: Control of Toxic Substances
Title II: Asbestos Hazard Emergency Response Act
(AHERA)*
Title III: Indoor Radon Abatement Act*
Title IV: Lead-Based Paint Exposure Reduction Act*
Title V: Healthy High-Performance Schools*
* TSCA Amendments
Summary of Acts
ISRP Iowa City, IA 2017
Hazard Communication
Emergency Planning and Community Right-to-Know Act (EPCRA)
Facilities give details of hazardous chemicals to local emergency responders
Form “R” Annual Toxic Release Inventory
Engineers estimate emissions and report to state annually
Hazard Communications
Material Safety and Data Sheets (SDSs)
16 sections covering everything from composition to firefighting
Need MSDS for every chemical in workplace
Labels, Pictograms
Employees have a “Right to Know” about workplace hazards
NH4OH MSDS
Corrosive
Irritant
Toxic to aquatic life
8 pages of information
Precautionary measures
First aid
Firefighting
Accidental release
Handling and storage
Physical, chemical props
Etc.
Process Safety Management
Process Safety Info (PSI)
General Info
Toxicity information
Permissible exposure limit
Physical data
Reactivity data
Corrosivity data
Thermal and chemical stability data
Hazardous effects of inadvertent mixing of different materials that could foreseeably occur.
Process Safety Info (cont.)
Process technology info
BFD or simplified PFD
Process chemistry, properties
Max intended inventory
Safety upper/lower limits for temps, pressures, flows, and/or compositions
Evaluation of consequences of deviations, including those affecting employee safety and health
Process Safety Info (cont.)
Process equipment info
Materials of construction (MOC)
P&IDs
Electrical classification
Relief system design and design basis
Ventilation system design
Design codes, standards employed
Material/energy balances for process (for those built after May 26, 1992)
Safety system (e.g. interlocks, detection/suppression)
