Many small Texas manufacturers really struggle to manage environmental and TCEQ rules, regulations and laws.
Unfortunately this not only puts the environment and local community at risk, but also the company at risk for major TCEQ and EPA environmental fines and penalties that can run into the $hundreds of thousands of dollars, and can exceed a $million in some cases.
We recently conducted a brief environmental assessment for a Texas manufacturer and identified the following compliance failures and risks. This summary information is a great reference guide for Texas manufacturers concerned about their environmental compliance condition:
Environmental Related Risks:
- Texas Commission on Environmental Quality (TCEQ) registration review:
- No Storm Water Permit or Authorizations: Virtually all manufacturing SIC codes trigger a Storm Water Permit and Storm Water Pollution Prevention Plan (SWPPP)
- No Surface Coating Permit By Rule authorization: Paint booths often trigger this PBR and the following maintenance requirements:
- Maintain records of all paint usage
- Emissions calculations to ensure not exceeding PBR lbs. per hour and annual tons per year
- Control requirements, such as routine filter change-outs, use of 95% efficient filters
- Identify if any “HAPS’ (hazardous Air Polluants)
- Opacity: no visible emissions
- If using ovens for drying, there are other requirements.
- Hazardous Waste Management:
- EPA and State ID#’s not current or deactivated
- Waste determination for all wastes not created
- Drum Labeling issues
- Waste water discharge to drain: Company was illegally dumping wastes down the drain without authorization.
- TRI: No assessment conducted to determine if TRI or Tier II reporting required
- SPCC plan:
- Is the total aggregate capacity of above ground oil storage containers greater than 1,320 gallons of oil? (Do not include containers less than 55 gallons, permanently closed container, motive power containers, or storage containers used exclusively for wastewater treatment.) Do include transformers, belly tanks in generators, cooking oils, hydraulic fluid, lubes, fuels (gasoline/kerosene), oils, etc. if they are 55 gallons or greater.
- Employee training:
- DOT Hazardous Materials: Companies who ship any hazardous materials, including any quantity of hazardous waste, must conduct this employee training
- RCRA: Small Quantity Generators and Large Quantity Generators must conduct routine waste training
- Storm Water: Stormwater Pollution Prevention Plans require extensive employee training requirements
Are you a small Texas manufacturer worried about your environmental, TCEQ or EPA compliance condition?
Call 512-457-0374 or Click Here To Schedule Your Free Consultation