Center for Industrial Services

In this issue ...

1. Tennessee Pollution Prevention Partnership Success Story - Lodge Manufacturing Company
2. Amended EPA Rule To Provide Relief To Facilities That Use Pollution Prevention
3. EPA And TDEC Establish Memorandum Agreement On NEPT And TP3.
4. Certified Hazardous Materials Manager (CHMM) 2003 Overview Course & Certification Exam to be Held in Nashville
5. Truckers No Longer Have To Idle Their Engine For Comfort.
6. Change To Workplace Chemical List Requirements.
7. Have Your Waste Anti Freeze Recycled On Site.
8. QUALITY, MANAGEMENT, AND ENVIRONMENTAL, HEALTH AND SAFETY WORKSHOPS – August 2003 through December 2003

1. TENNESSEE POLLUTION PREVENTION PARTNERSHIP SUCCESS STORY - LODGE MANUFACTURING COMPANY

Beneficial Reuse of Foundry Sand/Marion County Landfill

The Member

Lodge Manufacturing Company and Solid Waste Disposal, Inc. joined together in a beneficial reuse project in the construction of a new Subtitle D landfill expansion cell at the Marion County Landfill.

The Story

Mark Payne, Manager for Solid Waste Disposal, Inc. included a provision in the Marion County landfill permit that will allow foundry sand to be beneficially reused in the development of new cells. The Tennessee Department of Environment and Conservation, Division of Solid Waste has approved beneficial reuse of foundry sand in landfill construction projects in the TDEC Foundry Sand Beneficial Reuse Policy.

The Success

The Lofty Construction Company in Marion County screened and hauled 9,225 cubic yards of foundry sand to build the required 12 inch protective cover over the landfill liner, as an early step in the creation of two new disposal cells at the landfills. The project was completed by the middle of March, 2003.

By using the existing foundry sand, land and water conservation was served as other natural resources did not have to disturbed by removal. The foundry sand was a better choice than the local clay, available on-site, because screening was not required. Civil & Environmental Consultants, Inc. estimated the amount of material needed for the 12 inch protective layer and found that the county saved over $190,000 by using the sand. Lodge Manufacturing Company benefited by recovering 9,500 cubic yards of usable space in its Class II landfill. At current disposal rates, the Lodge Manufacturing Company landfill gained approximately 17 years of operational life in the existing landfill.

For more information, contact Ricky King (rking@lodgemfg.com) at Lodge Manufacturing Company, P.O. Box 380, South Pittsburg, TN, 37380 (423)837-7180

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2. AMENDED EPA RULE TO PROVIDE RELIEF TO FACILITIES THAT USE POLLUTION PREVENTION

On May 15, 2003, EPA announced in the Federal Register that it is seeking comment on proposed rule amendments that are designed to encourage and promote pollution prevention. In this action, EPA is proposing amendments that would provide regulatory relief to facilities that use pollution prevention (P2) to achieve emission reductions. Reducing hazardous air pollutant (HAP) emissions to the maximum achievable control technology (MACT) level of control or a better level. Required under applicable National Emission Standards for Hazardous Air Pollutants (NESHAPs), qualifies under this proposal. EPA is also proposing additional incentives specifically for, and only available to, facilities that are members of the National Environmental Performance Track Program.

These amendments are proposed in direct response to the perception that the current rule discourages the development and implementation of P2 measures after a MACT level of control has gone into effect, by mandating that a facility must continue to comply with specific source MACT requirements. The proposed amendments offer two options as alternatives:

1. If a facility uses P2 to completely eliminate all HAP emissions from all sources of emissions regulated by the NESHAP, it could request to no longer be subject to that NESHAP.
2. If a facility uses P2 to reduce HAP emissions either to the level required by the NESHAP or below, it could request “P2 alternative compliance requirements”. These “P2 alternative compliance requirements” would include monitoring, recordkeeping, reporting and/or other requirements that match the P2 measures implemented by the facility. If approved, the “P2 alternative compliance requirements” would replace specific requirements in the NESHAP.

These proposed amendments address the Part 63 General Provisions for all MACT-based NESHAPs. They are designed to reduce HAP emissions with alternative approaches that achieve results in innovative and sustained ways. Preventing Pollution at the source continues to be EPA’s strategy of first choice.

The full text of the proposed amendments can be found in the Federal Register (68FR26249). The public comment period closed July 14, 2003. For further information, please contact Steve Fruh, Office of Air Quality Planning and Standards at (919)541-2837 or Paul Matthai, Office of Pollution Prevention and Toxics at (202)564-8839.

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3. EPA AND TDEC ESTABLISH MEMORANDUM AGREEMENT ON NEPT AND TP3.

The Environmental Protection Agency (EPA) and the Tennessee Department of Environment and Conservation (TDEC) share a commitment to recognize and reward environmental leadership in the protection of air, water, and land. To that end, EPA created the National Environmental Performance Track (NEPT) and Tennessee created the Tennessee Pollution Prevention Partnership (TP3). These voluntary incentive and recognition initiatives encourage members to focus on issues important to their communities, to take a creative approach to solving local problems, and to employ partnerships and networking with neighborhood citizens to achieve environmental goals.

EPA and TDEC believe they can achieve more by working together than by pursuing their goals independently. Coordinating efforts will lead to increased efficiency and effectiveness. As membership increases, so do opportunities to encourage members to commit to practices that improve environmental management and ensure the higher level of environmental protection that EPA, TDEC, and the American public all seek.

Through this Memorandum of Agreement, EPA and TDEC commit to creating the best value for our customers; reducing the resource requirements of both the EPA and TDEC staff and the administrative burden of member organizations; creating the greatest number of incentives, flexibility, and recognition for members; and reinforcing and encouraging continual improvement in environmental performance. While encouraging each initiative to maintain its own identity, EPA and TDEC pledge to:

• Coordinate the application processes of NEPT and TP3 so eligible applicants can apply to both programs simultaneously.
• Work with facilities to identify ways to streamline and facilitate the application process.
• Provide to eligible facilities the assistance necessary to apply and be evaluated expeditiously for acceptance into both NEPT and TP3.
• Develop and coordinate incentives in recognition of their high levels of environmental performance.
• Identify for members a single point of contact in both NEPT and TP3.
• Produce co-marketing tools and conduct joint recruiting and recognition events.
• Identify regulatory innovation opportunities that comply with State and Federal statutes/rules.
• Communicate the measurable environmental results achieved by NEPT and TP3 to the public.

These are just the first of many steps EPA and TDEC will take together to enhance initiatives and reward members for their leadership in environmental protection. EPA and TDEC will continue to look for additional ways to align NEPT and TP3 so that members and the environment benefit. The focus will be to clarify the roles and responsibilities of all partners they work to align requirements and develop additional means to deliver recognition, flexibility, and incentives to our environmental leader members. Representatives at EPA and TDEC look forward to developing a detailed work plan that further defines how NEPT and TP3 will work together and anticipate a cleaner future for the American, and particularly the Tennessee environment as a result.

This Memorandum of Agreement is entered into this 14th day of March 2003.

For more information on TP3 or NEPT and how your company can participate, contact Harding Aslinger at haslinge@tennessee.edu or George Smelcer at gsmelcer@tennessee.edu.

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4. CERTIFIED HAZARDOUS MATERIALS MANAGER (CHMM) 2003 OVERVIEW COURSE & CERTIFICATION EXAM TO BE HELD IN NASHVILLE

The 2003 Comprehensive Environmental, Health & Safety and Transportation Overview course is coming to Nashville in November. This course is a valuable learning opportunity for:

• Environmental professionals and managers
• Hazardous materials transportation professionals
• Health and safety professionals

The CHMM credential has become one of the most widely recognized and specified credentials in federal agency (EPA, U.S. State Department, FDIC, etc.) request for proposal procurement documents. Many private organizations have implemented corporate policies that require or foster staff engaged in environmental management activities to have or acquire the CHMM credential. Additionally, the CHMM Program is endorsed by the U.S. National Park Service, U.S. Air Force, U.S. Department of Energy, U.S. Department of Defense, Corps of Engineers, and various regions of the U.S. Environmental Protection Agency.

The CHMM course will improve your understanding of hazardous materials management, help you perform your job duties and responsibilities, and prepare you for the optional Institute of Hazardous Materials Management CHMM certification examination. For currently certified CHMM's the course provides 24 hours of quality training that may be applied toward re-certification.

The course registration fee includes a course notebook and breaks, and the newly published Hazardous Materials Management Desk Reference will be available to attendees at a reduced rate.

Overview Course: November 4 - 6 (Registration deadline October 21)
Optional CHMM Examination: November 7
Location: Wyndham Nashville Airport Hotel, 1112 Airport Center Drive, Nashville (615)889-9090
Course Fee: $595

For more information about the CHMM course and exam, contact Mr. Steve Street at (865) 974-2009.

Register now! or download the Registration Form

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5. TRUCKERS NO LONGER HAVE TO IDLE THEIR ENGINE FOR COMFORT.

Traditionally, long haul truckers idle their engines whenever they park in order to heat or cool their cab and provide amenities without draining the batteries. An idling standard diesel-fueled truck produces more than 55,000 pounds per year of polluting emissions.

Now truckers have an option. IdleAire, headquartered in Knoxville, TN has equipped service areas so drivers can cut their engines and hook their cabs up to a system that provides heating and air conditioning, telephone access, 110-volt electrical hookups, high speed internet, email, satellite television, movies on demand, and computer based interactive training and learning opportunities. The system’s services are delivered to the truck cab by a window-mounted service module that is a Pentium-class computer with a color touch screen.

In 2002, IdleAire increased the parking spaces at its Watts Road location near Knoxville to 225 units. The company estimates these units will achieve annual local reductions of 81 tons of carbon monoxide, 15,000 tons of carbon dioxide, 109 tons of nitrogen oxides, 4 tons of particulate matter, and 10 tons of volatile organic compounds. The technology also provides a safety factor, as drivers who cut their engines and plug into the amenities of home can improve the quality of their rest time.

Drivers pay up to $1.50 per hour for services.

For more information on this technology, contact Mr. John Doty, Manager of Corporate Communications for IdleAire at (865)342-3659 or jdoty@idleaire.com

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6. CHANGE TO WORKPLACE CHEMICAL LIST REQUIREMENTS.

The Tennessee Hazardous Chemical Right-to-Know Law requires that employers prepare a list of hazardous chemicals present in the workplace. On the list must be each product name with all hazardous ingredients from the material safety data sheets listed, along with the quantity of the chemicals on hand. Previously it was required that each manufacturing employer and some non-manufacturing employers submit their list to TOSHA, with an annual update.

The law was recently amended to require the list be submitted to TOSHA “within 96 hours of request by an authorized representative of the commissioner”. Now, employers only submit their Workplace Chemical Lists to TOSHA when specifically requested by a TOSHA representative. All other requirements of the Tennessee Hazardous Chemical Right-to-Know Law remain in effect.

This change in the law continues to allow public access to chemical hazard information when needed, but reduces processing costs and improves the manner in which this information is managed. For additional information or answers to questions you may have about the Tennessee Hazardous Chemical Right-to-Know Law, contact Mike Maenza, TOSHA Manager of Standards and Procedures, at 615-741-7036

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7. HAVE YOUR WASTE ANTIFREEZE RECYCLED ON SITE.

Anti Freeze Recyclers International of Conover, NC reportedly provides the cleanest on-site recycled antifreeze available today. In business since December 5, 1995, they advertise that only a total distillation system, which cannot be done in the field using current technology, exceeds the product purity of their process.

Anti Freeze Recyclers International designs, develops, manufactures and operates the units used on their trucks. The equipment performs a fourteen/sixteen (14/16) unit step down ultra-filtration which takes approximately 12 minutes to recycle 60 gallons and rejuvenates the antifreeze. The antifreeze returned to the customer is complete with fortifiers, lubricants and inhibitors, and is ready for use.

The freezing point is usually set at -34° F, but it can be adjusted to meet customer specifications. The pH is adjusted to 10-12 to provide maximum corrosion, rust and pitting protection.

For more information, contact Donald L. Ferrell Sr., CEO, Anti Freeze Recyclers International, Conover, NC 28613 at 828-466-3670 or afri-co@earthlink.net.

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8. QUALITY, MANAGEMENT, AND ENVIRONMENTAL, HEALTH AND SAFETY WORKSHOPS – August through December 2003

For more information about the courses listed below, please visit our Web site. Or, call us: (615) 532-8657 or toll-free at (888) 763-7439. To register for any of these courses, please use this registration form.

Certain courses are underwritten by TDEC Division of Community Assistance funding under the Waste Reduction Assistance Program contract. Tennessee Pollution Prevention Partnership (TP3) Partners and Performer-level members receive a discount on registration fees for these open-enrollment courses. To learn more about TP3, please call George Smelcer at (615) 532-4912, e-mail: gsmelcer@tennessee.edu; or contact Don Stone at (615) 532-4924, dstone1@tennessee.edu. Or, you may visit the TDEC Web site at www.state.tn.us/environment/dca/tp3.htm.

** TP3 discount applies to Partner and Performer Level Members
† Government Employee Discount Available

In-plant courses on topics such as Lean Manufacturing, Quality Management, Human Performance Technology, Manufacturing Management and Operations, and Environment, Health and Safety also are available on your schedule. Please visit our Web site for course information, or call us at (615) 532-8657 or (888) 763-7439 to request a catalog.

SUBSCRIBE FREE: http://www.tmep.utk.edu/

Feedback by e-mail: gsmelcer@tennessee.edu or buggeln@tennessee.edu
Feedback by phone: (615) 532-8657 or (888) 763-7439
WRAP Sheet archive: http://www.tmep.utk.edu/
WRAP Sheet is published by the Tennessee Manufacturing Extension Program: http://www.tmep.utk.edu

The University of Tennessee Center for Industrial Services
Tennessee Manufacturing Extension Program
193 Polk Avenue, Suite C
Nashville, TN 37210
Phone: (615) 532-8657
Fax: (615) 532-4937

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