Chem321:Acme EPA inspection

The following is the summary of a report resulting from the visit to the Acme Chemical Corp. facility in Acmetown, NY, by the US Environmental Protection Agency (EPA) on Friday, July 20th.

Plant inspection

In general, the inspector found most areas of the plant to be in compliance with the regulations. However, there was one major violation found - a set of four 55 gallon drums with inadequate labeling - as well as six minor violations. The paperwork tracking hazardous waste had everything listed correctly (except for the four drums), although the system for tracking waste could perhaps be made more transparent.

Major violation

Four drums were found in sector 7 of the drum park with inadequate labeling. The drums had labels saying "Batch B79 waste, failed batch" and nothing else. These were believed to contain waste from a failed batch of 2-methylhiazoline preparation (generated July 14, 2012) and containing mainly toluene, and this was later confirmed by analysis by the QC department. The contents are flammable but otherwise not especially hazardous or toxic, but being labeled as "waste" they should have been logged into the hazardous waste system. The labels should have included the main chemical constituents, as well as the waste ID number and the date. The fine for this would normally have been $80,000, but because this was clearly an isolated case, the inspector agreed to lower the fine to $40,000, on condition that the situation was immediately rectified (which it was).

Minor violations

1. Two drums of 1,2-dichloroethane were found to have the tops a little loose, leading to the potential for fugitive emissions (2)
2. Two vat filters were found to have inadequate fume extraction (2)
3. An unlabeled vial containing a clear, colorless liquid was noted on the bench at the south end of the R&D laboratory.
4. In the Quality Control laboratory, a wash bottle of acetone was left next to the sink, and it could have dripped acetone into the wastewater.

Other than these exceptions, the standards of work practices and labeling were deemed to be generally good. Items 1,3 and 4 were immediately fixed. As long as item 2 is dealt with within one month, the inspector agreed to waive the fines on this occasion.

Environmental strategy discussion

The EPA strongly advocates a proactive approach to environmental management, rather than a reactive approach - prevention, rather than cleaning up after a problem arises. The inspector was encouraged that an environmental committee had recently been formed, but this committee needs to be both long-lasting and active. The EPA encourages Acme to consider setting up an Environmental Management System, for example following the guidelines of ISO 14001. Such an approach may help to identify and eliminate systemic problems at Acme, reducing the likelihood of violations in the future. EPA also recommends that Acme consult with the Pollution Prevention Institute in Rochester, NY, to obtain expert advice on green approaches to manufacturing.

For the US EPA (Signature of Janice Smith, Senior Inspector)