EES EXPERTISE

EPA Self-Audit Program

The USEPA is currently enforcing all of their Environmental Regulations as they apply to Hospitals under the auspices of the EPAs Audit Policy (60 Fed Reg 66706, 12/1995; updated 4/2000). The EPA Region 2 (NY, NJ, VI and PR) has been charged with this responsibility. They will eventually audit/inspect all Hospitals in this Region, including those owned by Private/City/State and Federal entities. Applicable rules are Clean Air Act (CAA), Clean Water Act (CWA), Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Resource Conservation and Recovery Act (RCRA), Community Right to Know (CERCLA), Toxic Substance Control Act (TSCA), etc. EPA notified all the CEOs of the Hospitals in this regard as early as December 27, 2002. Several outreach seminars were also conducted to disseminate the requirements of the audit and its potential impact on non-compliant facilities or areas.

The EPA encourages the Hospitals to perform a Self Audit in order to avoid EPAs unilateral enforcement actions. This requires a written agreement with EPA. Any violations discovered by the facility must be voluntarily disclosed within 21 days of finding and corrective actions must be taken within 60 days. Penalties for violations found during the Self Audit may be eliminated, provided there are no repeat violations. In the event of EPAs unannounced Audit, any violations discovered will be fined at the rate of $27,500 per violation per day, up to 180 days (maximum statute limit). A New York City based University was assessed with a penalty of $800,000 as a result of EPAs inspection conducted in March 2002.

In essence, the Audit will focus on all Departments, including but not limited to, the Pharmacy, Facilities Engineering, House Keeping, Laboratories, Radiation Safety, Risk Management, Infection Control, Chemical Safety/Hygiene, etc. Major areas of regulatory concern are Hazardous Waste (procurement, use, disposal, labeling, spill prevention, etc), UST (registration, testing, filling, monitoring, SPCC, etc), Air Issues (permits, boiler tune ups, Title V, reporting, testing, generators permits, ETO sterilizer permits, etc), Asbestos (management, notification, records), Lead Based Paint (removal, records etc), Waste Water (permits, testing, tanks, repair, etc), Toxic Substance (mercury disposal, fluorescent bulbs, thermometer disposal, etc), and others as may be applicable.

In order to perform a thorough Audit and assess the facilitys compliance status, effective communication, organization and a proactive approach are essential. To ensure a successful compliance management, a third party audit is recommended. This is a very serious issue that cannot and should not be ignored.

EES will be pleased to assist the facility in this regard. For further information, please contact Dr. Rengasamy Kasinathan (Kasi),MBA., P.E., DEE., RPIH at kasi@eespc.com

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Environmental Site Assessment – Phase I Audit

Environmental Site Assessment provides accurate evaluation of property for Recognized Environmental Conditions. A Site Assessment aids in appraising and identifying potential environmental liabilities of a parcel of land. An assessment can affect the economics of property transaction and help in recognizing significant environmental conditions that the future owner, seller or a lender should know.

Phase-I Site Assessment Includes:
  • Site visit of property and surrounding areas in order to assess general land use.
  • Visual inspection of the land for recognized environmental conditions such as fuel tank leakage, contamination of the land, etc.
  • Review of geological and hydrological data.
  • Assessment of the past and current usage of the property.
  • Review of local and state governmental records.
  • Summary report of findings, data and recommendations in accordance with ASTM guidelines

EES is fully capable of preparing the site assessment as required (either for real estate transaction or for any other purposes). EES staff are fully knowledgeable and have assisted many clients in this regard. For assistance, please contact Dr. Rengasamy Kasinathan (Kasi),MBA., P.E., DEE., RPIH at kasi@eespc.com

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Spill Prevention, Control and Countermeasures Plan (SPCC)

In accordance with the Federal Rules, 40 CFR 112.7 and 112.8, an SPCC Plan has to be developed and implemented if a hospital or any facility who operates more than 1320 gallons of aboveground storage tanks (ASTs) containing petroleum products including containers with capacity of 50 gallons or more or if the completely buried storage capacity of petroleum products exceeds 42,000 gallons except those that are subject to the technical requirements of 40 CFR Parts 280. SPCC Plan is required also due to a facility’s location, if it could reasonably be expected to discharge oil into or upon the navigable waters of the United States. The purpose of this plan is to properly manage any oil spill and to avoid potential future spills, ensuring environmental and human health and safety.

The plan comprises of responsible person’s contact information, hot line numbers for spill reporting(Local, State and EPA), description of the lay out of the facility indicating the tanks, products stored, capacity, direction and rate of the flow, predicted quantity of the spill, pipes and oil filling locations, drainage, secondary containments, spill control methods, procedure for preventing the discharge, response details including clean up procedure, disposal of waste oil, etc.

All of the petroleum containers must be tested for leaks. The plan must be signed by a licensed Professional Engineer. Periodic updating of the plan is required if any tanks were added or modified. Every 5 years, plan must be reviewed and, if required, amended. A comprehensive training must also be provided to oil handling personnel. EPA assesses hefty fines for non compliance with this rule

EES is fully capable of preparing detailed SPCC and providing training to the oil handling personnel as required. For assistance, please contact Dr. Rengasamy Kasinathan (Kasi),MBA., P.E., DEE., RPIH at kasi@eespc.com

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Annual Emission Statements (AES)

The USEPA, after the promulgation of the Title V of the Clean Air Act Amendment (CAAA), requires that all major emission sources comply with the fuel consumption and other operating patterns as agreed to in the permit. It is done via submitting an Annual Emission Statement incorporating actual operating conditions including emissions. Failing to comply with this requirement is a violation of Air Pollution ControlAct.

EES has performed hundreds of such AES for variety of emissions sources in several states. EES also has developed proprietary emissions calculations, which serve to save annual emissions fee.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Permit to Construct

No person in United States is allowed to emit any criteria or any hazardous pollutants from any air pollution source without first obtaining a permit. Such permit is obtained from federal, state and local environmental regulatory agencies depending upon the degree of delegation of authority. Some of the most popular emission sources are paint spray booths, boilers, emergency generators, incinerators, fume hoods, underground storage tanks, ethylene oxide sterilizers,power plants, co-generators and other chemical plants. The permit application (preparation) process involves thorough understanding of the process, design criteria and effective negotiation with respective regulatory agencies. Diversified, disciplined and qualified staff are required to handle such application process, including certification of licensed professional engineers, industrial hygienists, etc.

EES has secured several permits from almost all parts of the country in a short period of time. This is because of our outstanding experience and ability to analyze pertinent regulations and simplify the application requirements.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Certificate to Operate (CO)

Many emission sources (facilities) are constructed after obtaining permits which are based on engineering assumptions and estimated design conditions. The regulatory agencies require that the facility be built in accordance with applicable regulations and design criteria. The engineer-of-record is then required to inspect the facility and certify. Any deviations from the permit will need to be accounted for from the viewpoint of risk or no threat to the environmental health and safety (EH&S). US EPA approved risk assessments and other environmental studies are required to ensure EH&S. EES is quite capable of performing such field inspections, certifications, risk assessments and finally obtaining certificate to operate for all emission sources.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Environmental Impact Statement (EIS)

EIS is required for all Actions which may impact the environmental quality. Analysis of the existing (No Action) air, waste, water, traffic and other impact for a proposed real estate development, buildings, a new plant, highway constructions, etc (Action) should be made, and incremental impact due to the Action should be estimated. Use of dispersion modeling and other state-of-the-art software are required to prepare a comprehensive EIS. The founding principal of EES has performed several of these including one for White Oak Lab (WOL), located in Silverspring, Maryland when FDA planned to relocate some of their key operations to the Naval Warfare Center of WOL. This work was carried out under the auspices of General Service Administration (GSA), Washington D. C.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Emissions Inventory & Title V Permits

In June 1989, President George Bush proposed sweeping revisions to the clean air act amendments (CAAA). This is a most important centerpiece, US congress ever enacted for improving the air quality in United States which became law in 1990.This legislation was designed to curb three major threats to the nations environment and to the health of millions of Americans. These are acid rain, urban air pollution and toxic air emissions. A national permit program was therefore designed which is workable yet with effective enforcement steps.

Essentially, the operators/owners of all emissions sources are required to perform a facility wide emission inventory. Depending upon level of emissions, appropriate application (major or reduced versions) will have to be submitted to the delegated authority (state regulatory agency). Several emission calculations for various scenarios will need to be done in order to identify and agree to most cost-effective permit conditions. EES has assisted several private and governmental facilities to comply with this rule.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Air Quality Dispersion Modeling

The ambient air (concentration) is continuously affected by the pollution created by automobiles, industries, power plants and all stationary combustion sources, etc. These pollutions are identified as micrograms of any pollutants in one cubic meter of air. The US EPA, as a result of many years of research, set limits for each pollutant. The criteria pollutants are covered by the National Ambient Air Quality and the toxic pollutants with the level of incremental cancer risk.

Several versions of computer models were developed by the USEPA. These include Screen, ISCST, etc. Site specific, topographic, design/emission data (of plant under study), meteorological conditions, etc, will be utilized in predicting the impact of the facility. In general, modeling is required as a part of Permit to Construct or EIS or sometimes for public hearing situations. This study serves to scientifically and quantitatively justify the impact on ambient air quality, and modify (improve) the plant for proper compliance. In addition, this study enables to determine the required Stack Height in conformance with the requirements of Good Engineering Practice (GEP) stack height analysis.

The staff at EES is well trained to conduct any versions of the modeling study and have developed many supporting programs and calculations to accurately predict the ambient air quality.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Good Engineering Practice Stack Height Analysis

The ambient air quality from the vicinity of emission sources is affected by the nature of dispersion. Most essential components of this aspect is the height of the stack. The parameters of the stack are determined depending upon of the nearby structures(height, distance, type, etc). USEPA approved procedures as outlined in GEP manual should be followed for determining adequate height in order to avoid the “wake” and “cavity effect “.

The staff at EES are fully knowledgeable in this area, and has designed many stacks.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Medical Waste Management

Medical waste management is an essential requirement of the USEPA’s new medical waste disposal regulations (HMIWI). The waste generated at the healthcare facilities range from general, infectious, hazardous to radioactive materials. Based on a 1990 survey and report to the US congress, hospitals account for 70% of the medical waste generated in the United States. This consists of approximately 20% of infectious, 75% general and the rest are other wastes.Healthcare facilities should segregate wastes due to thecontamination by patients with highly infectious diseases. This is necessary in order to:

  • Reduce handling or mishandling
  • Reduce waste volume that are otherwise considered infectious
  • Protect the worker from exposure
  • Reduce the cost of disposal
  • Reduce the toxic emissions from the combustion of waste

The healthcare facilities are therefore environmentally and economically obliged to evaluate their waste generation and waste management practices.

Further, the enactment of 40CFR subpart Ce (the Hospital/Medical/Infectious Waste Incinerator (HMIWI) regulations) requires a waste management program to be incorporated (mandatory). This must be submitted to and approved by the respective state regulatory agencies. This program should,at a minimum, include management of sharps, summary of alternative medical waste treatment technologies, current and future trends relative to medical waste disposal costs, analysis of waste reduction initiatives, coordination with the medical waste product companies, interviews with the various department heads and follow up procedures. Segregation, minimization, source reduction, recycling and conversion of equipment and supplies,adoption of alternate disposal systems must be considered for an effective waste management program.

EES is fully familiar with the waste management programs and disposal methods. Thousands of dollars for the healthcare facilities can be saved by us with creative programs. The facility would be able to reduce, reuse and recycle the wastes in order to identify opportunities to control costs and minimize adverse environmental impacts.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Medical Waste Disposal & Incineration

Medical waste can be disposed of via methods such as mechanical, chemical, on site incineration,autoclaves, microwaves, etc.

The enactment of the EPA’s final HMIWI regulations forced require many healthcare facilities to seek alternate(i.e. other than the incinerator)technologies. These technologies are grouped into mechanical and chemical. Medical waste can be autoclaved and disposed of in a municipal landfill. Sometimes waste can be shredded in conjunction with other disposal technologies. There are advantages (cost) and disadvantages (capacity limitations) in pursuing the alternate technologies in comparison with incineration.

As to the incineration, all existing units are required to comply with the stringent regulations of HMIWI. These are summarized in 40 CFR part 60,subpart Ce. In addition, respective State regulations such as 6NYCRR part 219-3 is also required. In order to comply with the incinerator regulations, air pollution control device such as scrubber, continuous emission monitoring systems(CEMS),state-of-the-art burners are needed to achieve emission levelsand design conditions. As a first step to install any waste disposal unit, a permit is required to be submitted to the respective state environmental agency.

EES is fully capable of performing evaluations of waste disposal needs, design and construction management of any technologies including incineration. We also design and install animal and human crematory (pathological) units.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Risk Assessments & Management Plans

The incremental cancer risk dueto the exposure of toxic pollutnts discharged from any air pollution sources must be studied and compared with acceptable levels such as one-in-a-million standard. These standards and procedures are outlined in USEPA’s risk assessments documents. In general, air quality dispersion modeling, plant design data and emission information are required to perform risk assessments. A detailed study includes exposure analysis via soil ingestion,mother’s milk, dairy, vegetations, etc.

EES has performed several multi path health risk assessments and plans.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Regulatory Violations Negotiation & Mitigation

Any operating emission sources, which are non-complaint with applicable federal/state/local standards will be subject to enforcements. The enactment of the Title V Rule made it compulsory for every source to be extremely watchful of their operations and pre-determined permit restrictions. The violations and resulting penalties can be a $1000 to $25000 a day. EES has helped many clients to comply with the standards and prevented penalties and inconveniences.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Boiler Operations & NOx RACT Compliance

Many major sources of pollutants operate boilers whose NOx emissions are greater than 25 tons per year(Ozone non attainment). Reduction in fuel consumption, annual tune-up and opacity measurements are the essential components of record keeping. EES has developed specialized client specific software in order to keep track of the facility operations in conformance with regulatory requirements.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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CEMS Certification, Audit & QA/QC Plans

The subpart CE of 40CFR 60 requires that the continuous emission monitors be thoroughly checked and inspected.To ensure the quality assurance and control, quarterly, relative accuracy test audit (RATA) and CGA must be done.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Building, Code & Fire Protection Assistance

EES is assisting many of their clients to obtain necessary permits from the building and fire departments. We also negotiate and mitigate any violations issued by these agencies.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Dry Cleaning Facility Inspection(NYS-Third Party/P.E)

In May 1997, NYSDEC has promulgated a regulation called NYCRR Part 232 which primarily targeted the reduction of Perchloroethylene emissions from all dry cleaning facilities located through out the state of New York. This rule takes into consideration of EPA’s CAAA, OSHA,NFPA, NIOSH, RCRA, CERCLA, NESHAP and CWA. All facilities need to comply with this rule, failing which severe penalities are being imposed. In order to demonstrate complaince, a qualified (P.E),trained and NYSDEC certified individual must inspect and certify the facility as per Part 232.16.

EES staff is qualified to perform such inspection.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Lead Based Paint Sampling, Inspection and Risk Assessment

The Presence of Lead in Pre 1970, Federally Assisted Buildings (Housing Authorities) must be determined and appropriately removed as per Title X. EES is Certified by USEPA pursuant to 40 CFR Part 745.226 and HUD Guidelines to conduct lead-based paint activities. EES staff are certified Inspectors and Risk Assessors. EES is also licensed to own and operate XRF instruments.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Design Engineering & Contract Documents

EES can design, engineer the following equipments which are specific to meet the client requirements:

  • Boilers & Wood Burning Furnaces
  • Continous Emission Monitors
  • Emergency Generators
  • Fume hoods
  • Scrubbers
  • Medical Waste Treatment Systems
  • Underground Storage Tanks
  • Paint Spray Booths
  • Ethylene Oxide Sterilizers
  • Incinerators
  • Co-Generation Plants

We can prepare bidding documents, assist bidding process and contract award. We will also provide construction management support.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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CONTACT US


  EESPC - HQ
   Address : EES, P.C.,

1106 Main Street,
Peekskill, NY 10566

Reg : + 914-788-4165

Fax : + (914) 788-7121

Mail : kasi@eespc.com
Business Hours : 8:30AM - 5:00PM

   NORTH CAROLINA
   Address : 1150 Revolution Mills Drive

Greensboro, NC 27405

Reg : + 336-738-3410

Fax : + (336)-738-3411

Mail : muni@eespc.com
Business Hours : 8:30AM - 5:00PM

  INTERNATIONAL AFFILIATION
   RKEES Pvt. Ltd. - INDIA

Address : 1408, VBS Rajan Street Kanathur, Kanchipuram - 603 112, Tamil Nadu, India

Reg : + 914 600 5550

Fax : + (91) 2744 4378

Mail : lakshmi@rkees.com
Business Hours : 8:30AM - 5:00PM (EST)

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