Workshop V Successful Integration into Established Environmental - PDF document

Workshop V Successful Integration into Established Environmental Program Tuesday, March 26, 2019 3:30 p.m. to 4:45 p.m.

Biographical Information Anita Evenson, Senior Consultant, Trinity Consultants, Inc. 1717 Dixie Highway Suite 900, Covington, Kentucky (859) 341-8100 x 116 aevenson@trinityconsultants.com Anita serves as a senior consultant in Trinity’s Covington/Greater Cincinnati office as an experienced air permitting and compliance expert with more than 15 years of high-level performance in the environmental consulting and engineering fields. This includes project management and technical experience in air quality permitting, emission inventories, regulatory compliance support, multi-media environmental assessments, and complex permitting compliance efforts surrounding CAM plans, several MACTs, Title V renewals, synthetic minor permits (including NSR and PSD analysis), and other engineering projects. Routinely assists clients in complying with complex environmental regulations. Develops air emission inventories for plastics, resins, coating, steel mills, automotive, food and flavoring clients that involves site evaluations, process analysis, extensive records review, and detailed calculations of potential and actual emissions. Anita is a graduate of Rose-Hulman Institute of Technology with a B.S. in Chemical Engineering. Hannah Fanzini, Environmental Engineer SABIC Innovative Plastics Mt. Vernon, LLC 1 Lexan Lane, Mt. Vernon, Indiana 47620 (812)831-7047 Hannah.Fanzini@sabic.com Hannah started her environmental career with SABIC Innovative Plastics in August 2011 as a engineering co-op student. During her undergraduate career, she progressed through 5 rotations across plant site within production units. After graduation, she joined SABIC Innovative Plastics in Mt. Vernon, Indiana in 2015 with the Rotational Engineering Program (SEeD). These rotations covered production, process, reliability, and EHS roles across two SABIC sites in Alabama and Indiana. Some of her projects include creating process control narratives, orchestrating the replacement of obsolete PLC’s on a critical system, and leading the start-up phase for the site Cogeneration CEMS/DAHS. In 2017, Hannah joined the environmental team at the Mount Vernon. Her primary responsibilities for include supporting operations to comply with the site NPDES permit, CERCLA/EPCRA, and the site infrastructure section of the Title V permit. Hannah is a graduate of Purdue University with a B.S. in Chemical Engineering.

Biographical Information Tuyen Nguyen, Senior Environmental Engineer SABIC Innovative Plastics Mt. Vernon, LLC 1 Lexan Lane, Mt. Vernon, Indiana 47620 (812)831-7539 Tuyen.Nguyen@sabic.com Tuyen’s environmental career began in 1992 as a Waste and Air Compliance Coordinator. She went on to gain extensive experience in environmental, health, and safety management that includes over 20 years of combined experience in the private and governmental sectors utilizing technological and methodological advancements to ensure better compliance results. Tuyen joined SABIC in Mt. Vernon, Indiana in 2015 as a Senior Environmental Engineer. Tuyen’s areas of expertise range from management and support operation site to comply with Title V permit requirements, the implementation of standards, performance and prevention in Environmental, Health, and Safety function according to federal environmental laws and industry standards, and leading team efforts in various initiatives. Tuyen is a graduate of University Louisiana of Monroe with a B.S. in Toxicology and minor in Chemistry. Jennifer Thompson, Partner, Bingham Greenbaum Doll LLP 2700 Market Tower 10 West Market Street, Indianapolis, Indiana 46204 (317) 968-5305 jthomspon@bgdlegal.com Jennifer is a partner in the Firm's Environmental Practice Group. She has practiced environmental law for over twenty years with experience both in the public and private sector. She provides environmental legal services to industrial, commercial, agricultural and governmental clients. Services include compliance and transactional assistance, regulatory analysis, defense of enforcement actions, assistance in obtaining, negotiating, and appealing environmental permits, and assistance with contaminated properties.

S uccessful Integration into an Established Environmental Program March 27, 2019 S ession V

Introductions Anita Evenson – Senior Consultant ˃ Trinity Consultants Covington, KY / Greater Cincinnati office ˃ Overview of environmental programs ˃ Recordkeeping best practices Tuyen Nugyen – Senior Environmental Engineer ˃ S ABIC Innovative Plastics Mt. Vernon, LLC (S ABIC) ˃ Regulatory programs at S ABIC ˃ Experience brought from other industries

Introductions Hannah Fanzini – Environmental Engineer ˃ S ABIC ˃ Experience at multiple S ABIC facilities ˃ Co-op and new graduate Jennifer Thompson – Partner ˃ Bingham Greenbaum Doll LLP ˃ Experiences of clients changing roles ˃ S topping knowledge loss during transitions

Introductions Anita Evenson– Senior Consultant ˃ S tarted at Trinity December 2017 via acquisition of QS EM ˃ Experience serving a wide range of industries and clients across Indiana and Ohio ˃ B.S . Chemical Engineering Rose-Hulman ˃ Based out of the Covington, KY / Greater Cincinnati office 1717 Dixie Hwy, Suite 900 Covington KY 41011 Office: (859) 341-8100 x 116 Cell: (513)391-0521 aevenson@ trinityconsultants.com

Evolution of Trinity Consultants 1974 ˃ One person, one office ˃ Air quality specialty 2018 ˃ Approximately 600 employees ˃ 55 offices in North America, Europe, China, and the Middle East ˃ S erve more than 2,500 clients annually ˃ EHS consulting services with a focus on air quality ˃ IS O 9001-based Quality Management S ystem, certified in Dallas, TX ˃ ~35% Employee owned

Trinity’s Services ˃ EHS Regulatory Consulting  NEP A/ EIA support  Noise and odor analysis  Air quality services  Risk Management ♦ Air permitting and compliance Planning/ Process S afety ♦ Air dispersion modeling Management (RMP/ PS M) ♦ S ource testing/emissions monitoring  Environmental reporting support  Industrial siting ♦ Ambient and meteorological monitoring  Client advocacy  Waste management  Litigation support ♦ Industrial and solid waste management  Professional Training ♦ Beneficial use and alternate fuels  EHS Performance & Risk MGMT  Water quality services ♦ Water quality permitting and compliance ♦ Water monitoring, sampling, and treatment analyses 7

Presentation Agenda ˃ Trinity  Resources  Regulatory programs  Recordkeeping best practices ˃ S ABIC  Transitioning between industries  Reporting system  Understanding regulations  Learning on the j ob ˃ BGD Legal  Misconceptions of established environmental programs

The Big Picture Federal Laws U.S. Environmental & Regulations Protection Agency State Laws State Agencies & Regulations (IDEM, OH EPA, KY DEP) Program Enforcement/ Permits Administration Compliance

Facility Resources ˃ Internal ˃ Corporate ˃ Environmental management system ˃ File review at local/ state level

Federal Resources ˃ Environmental Compliance History Online (ECHO)/ Envirofacts ˃ Federal Register (FR) ˃ Electronic Code of Federal Regulations (eCFR) ˃ TRI Explorer ˃ RS EI Model

Ohio Digital Resources ˃ Electronic permits ˃ Engineering Guides ˃ Ohio eBusiness

Indiana Digital Resources ˃ Electronic permits ˃ Virtual Filing Cabinet ˃ Electronic reports  EMITS  Tier II Manager  NetDMR

Kentucky Digital Resources ˃ New website and forms ˃ KY One S top Business Portal  Electronic S ubmittals  EEC eForms ˃ DEP S earch Online  Permit status  Rules under review ˃ NetDMR

Louisville Digital Resources ˃ Louisville Metro Air Pollution Control District “ The District” ˃ S eparate regulatory entity ˃ Title V permits online ˃ No electronic submittal portal

Regulatory Environmental Programs ˃ What programs apply to my facility? ˃ How are programs managed? ˃ Overlap between programs.

Air Regulatory Programs ˃ Title V facility ˃ S ynthetic minor source ˃ Minor source ˃ Permit-by- rule/ exemption

Wastewater Regulatory Programs ˃ Individual ˃ General ˃ S tormwater ˃ No exposure

Waste Regulatory Programs ˃ Hazardous Waste Generators Improvement Rule ˃ Hazardous waste category ˃ Keys to compliance  Recordkeeping  Training

Facility Plans ˃ S PCC- S pill Prevention, Control, and Countermeasure Plan ˃ S WPPP- S tormwater Pollution Prevention Plan ˃ FRP- Facility Response Plan ˃ RMP- Risk Management Plan

Community-Right-to-Know Programs ˃ S ection 302 Emergency Planning Notification ˃ S ection 311 S DS reporting ˃ S ection 312 Inventory (Tier I/ II) Reporting ˃ S ection 313 Toxic Release Inventory Reporting (TRI)

Site-Specific Compliance Calendar ˃ Crucial to environmental compliance ˃ Include all permit requirements ˃ Components maybe out of your control ˃ Plan extra time for agency submittals  S ignatory availability  S ystems down ˃ Environmental management systems

Site-Specific Deadlines ˃ Emergencies/ Malfunctions ˃ S ampling requirements ˃ S pills/ Releases ˃ Renewals