Breitling Consulting, LLC

Texas Medical Waste: Compliance Guidelines for Generators

Click the link above to review compliance guidelines for medical waste generators. 

Breitling Consulting specializes in pollution prevention services. Through a multidisciplinary team of accomplished senior level professionals backed by a strong technical staff, Breitling Consulting provides broad programmatic assistance and regulatory expertise to deliver comprehensive environmental pollution prevention services. Our staff has successfully completed projects for clients representing a wide range of industries, including automotive, chemical, food, hazardous waste processing, iron and steel, medical products, petroleum, printing, pulp and paper, semi-conductor, surface coating and wood products.

Industrial Storm Water Pollution Prevention Plans (SWPPP)

Breitling Consulting has experience creating and reviewing Industrial Storm Water Pollution Prevention Plans (SWPPP) for a variety of clients. The Industrial SWPPP will provide the plans and documentation necessary to meet the Texas Commission on Environmental Quality (TCEQ) Industrial Multi-Sector General Permit (MSGP)/TPDES General Permit No. TXR050000 requirements. Breitling will prepare a report that contains a site description, owner/operator information, Notice of Intent (NOI), project description, soils, topography, climate, runoff coefficients, receiving waters, monitoring and sampling locations and procedures, best management practices (BMPs) to be implemented on-site, and inspection/maintenance requirements. Breitling will assist the client with implementing the Industrial SWPPP by conducting routine inspections and water quality monitoring on a quarterly/annual basis. We will also prepare reports to be filed with the SWPPP to be submitted to the TCEQ as needed. Once per year, Breitling will also conduct an annual comprehensive site evaluation. Pollution prevention training is provided as well to ensure employee compliance and awareness of elements of the plan.

We pride ourselves in the excellent reputation we’ve built providing pollution prevention services to our clients.

Breitling Consulting wants to be your EHS compliance partner!

Texas Medical Waste: Is My Facility Regulated?

View our infographic to determine whether your facility is regulated.

Texas Medical Waste: 2016 Regulatory Revisions

Our new series covers the 2016 regulatory revisions affecting Texas Medical Waste. The revisions resulted from a directive of Texas HB2244, which was signed by the Governor last year. The revised rules were adopted on April 27, 2016 and became effective May 26, 2016. Click the link above for more details regarding the changes.

Upcoming Emissions Testing Changes: NSPS Subpart JJJJ

In this infographic we will review what a VOC is, what FTIR does not do, the Technical Memo from the Office of Air Quality Planning and Standards, how Table 2 will change, and Table 1.

Upcoming Emissions Testing Changes: NSPS Subpart A

Title 40 CFR 60.8(f) will be revised to require the reporting of specific emissions test data in test reports. These data elements will be required regardless of whether the report is submitted electronically or in paper format. These modifications are proposed to ensure that emissions test reporting includes all data necessary to assess and assure the quality of the reported emissions data and appropriately describes and identifies the specific unit covered by the emissions test report.

Over the past several years EPA has been cataloging needed revisions to test methods such as typographical errors, technical errors in equations and diagrams, updates to procedures, and acceptable alternative equipment and methods. Last year these revisions were compiled into a single proposed rule and comments were collected. The final rule was originally anticipated in June 2016. It has yet to be published in the Federal Register. Over the coming weeks we will dive deeper into the effects on performance testing for NSPS Subpart JJJJ and Subpart A. 

When greater certainty is required, the most common additional investigations are Phase II Environmental Site Assessments (ESA) and Vapor Intrusion Assessments (VIA). Both are voluntary supplements to ASTM E1527. View our infographic to learn more about the NEXT STEPS in our Phase I ESA series.

No Phase I ESA can wholly eliminate uncertainty regarding the potential for recognized environmental conditions (REC) in connection with a Subject Property. Conducting a Phase I ESA is intended to reduce, but not eliminate, uncertainty regarding the potential for REC in connection with a Subject Property. Having met the conditions of AAI does not mean an exhaustive assessment of a Subject Property has been conducted. View part six of our Phase I series to learn more about LIMITATIONS.

The Environmental Professional is required to provide an opinion as to whether recognized environmental conditions (REC) were identified in connection with a Subject Property. View part five of our Phase I ESA series to learn more about these FINDINGS.