EMAweblog

EMA Dinner Meeting Focus Topic

2005-09-16T12:30:00.000-07:00

The following was the starting point for the focus topic at the September 15, 2005 dinner meeting. Each dinner meeting in addition to the main speaker we will have a similar focus topic that will assist others in keeping up to date with upcoming environmental issues.

National Emissions Standards for Hazardous Air Pollutants (NESHAP)
General overview of applicable requirements to the upcoming NESHAP deadlines

Compliance Options

Compliant Coatings
Weighted Average
Add-On Controls

Reporting Requirements

Initial Notification

Due 2 years before the compliance date for existing sources

Notification of Compliance Status

Methods used to demonstrate compliance
Results of monitoring procedures or methods used to demonstrate compliance (VE Stack Test, etc.)
Method that will be used to determine continuing compliance
Amount of HAP emitted from source during time period
Description of Air Pollution Control Equipment or method used to determine compliance
A statement by owner/operator that the source is or is not in compliance with the standard

Semi-Annual Compliance Report

Statement if there were any deviations during the reporting period
Information relating to any deviations including those relating to work practice standards

Ongoing Record Keeping

Must be able to document how compliance has been determined
All notifications, reports (including one time only reports and semi-annual reports)

The state of Indiana requires a significant permit modification to be submitted 9 months prior to the compliance date. The state is currently processing these modifications for NESHAP relating to Reinforced Plastic Composites Production 40 CFR 63 Subpart WWWW. Initial reports indicate that IDEM is incorporating the language directly from the Federal rule and not allowing for any paraphrasing or clarification of the rules.

IDEM inspection notice

2005-09-15T20:59:00.000-07:00

This post deals with a letter that a number of clients have received for IDEM. IDEM is sending out a notice of pending inspection “Notice of Potential Compliance Inspection(s) & Opportunity to Self-Disclose Potential Violations”.

The letter says that it serves as advanced notice that IDEM may choose to conduct a compliance inspection within 30 days of the letter. It indicates that the inspection may be a single media or multi media inspection.

IDEM offers an opportunity for targeted facilities to conduct their own audit and self disclose findings of the audit. IDEM indicates the by doing so, a facility may avoid inspection and certain penalties.

The question becomes, how do I respond to this notice?

My recommendation:

First: Make sure your house is in order by conducting a comprehensive environmental audit and implementing an aggressive compliance program in the next few weeks.

Second: Depending on the findings of the audit, you may wish to disclose the findings; then again you may not. A decision on whether to disclose or not is entirely dependent on the severity deviations find in the audit and the potential liability you are exposed to upon disclosure. Sounds like a discussion with your high priced attorney might be in order.

posted by Bruce Carter

Paint Booth Needed

2005-08-25T14:37:00.000-07:00

Does anyone have or know of a used paint booth? Booth must be OSHA, NFPA and NEC compliant or at least close to it.

EMAweblog

2005-08-15T12:17:00.000-07:00

This looks great and will hopefully be a great resource!

EMAweblog

Instructions and Guidelines for Using EMAweblog

2005-08-14T19:29:00.000-07:00

This weblog is designed to provide a readily accessable virtual discussion forum for EMA members and manufacturers on environmental issues that affect us. Using this site is pretty easy- I learned from scratch in just a few hours, which means that people with average computer skills can learn in a few minutes. This posting will provide some basic instructions and guidelines for use. So lets get started.

First, only users with the secret username and password can create a post on the site, but anyone can comment on the posting. EMA members will all be emailed the username and password so that any EMA member can post a message.

So, lets use an typical example of an incident where this EMAweblog may turn out to be useful.

Event:

An EMA member was inspected by an IDEM representative and found to be out of compliance because he/she didn't have a Title V air permit. The EMA member has never heard of a Title V permit and wants to ask members about the issue.

Procedure for Posting:

So he/she uses the following procedure to post a message on the EMAweblog.

Log on to this site
Click on the "Blogger" icon on the left side of the page.Type in the secret username and password
Click on "new post" icon on the EMAweblog line
Use the "dashboard" (don't know why they call this thing a dashboard) to enter the Title: "Title V permitting?"
Use the dashboard to enter the text of the message as follows: "What's the deal with this Title V stuff - does anyone know what a Title V air permit is?"
Go to the bottom of the page and click on "Publish Post" and voila- you have now disclosed your ineptitude to the entire internet world.

Note on alternative single click procedure:

Click on "Blog This" at the top of the screen
Enter username and password
Type title and text
Publish

Procedure for posting a comment:

Now, lets say you are an EMA member or other interested party and, after logging onto this site, you think "Boy, this person really needs help" and wants to answer his/her question. Your answer is really a "comment" and can be done by simply clicking on the comment section below the relevent post to answer. You don't have to be a registered "blogger" (new term I learned today) to comment. Enter the text of your answer in the box, click "other" radio button, type your name (optional) and publish, and voila - you look really smart and helpful to the internet world.

Guidelines:

This can be a really cool tool, but we are going to have to keep things organized; so here are a few guidelines:

It would be helpful to know who is posting and commenting; but there may be confidentiality or security issues that concern you. If you are comfortable doing so, please type at the end of a post "posted by ____(name)" so we know who you are. If you entering a comment, use the optional "name" entry before publishing your comment. If you are not comfortable with this, then keep your comment or post confidential by not typing your name.
No advertising. Some private sector offerings may be of general use to members (like some training classes), but this is not the forum to advertise a product or service.
Keep it clean- no offensive language or personal attacks
If you want to post a picture- reduce the resolution to internet size (no more than 50 kb)

Summary:

This site could evolve into a really useful tool if we all participate. Keep a shortcut on your desktop and check this site just as you check your email. My hope is that this site could be used as our newsletter, job postings, a repository for resumes and any number of other cool things.

Have fun!

Posted By Bruce Carter