Gary Vegh Environmental Toxicologist ERA Environmental Consulting, Inc.

Gary Vegh's work with ERA Environmental Consulting, Inc. has been the study of the regulatory effects of the Clean Air Act Amendments (CAAA): National Emission Standards for Hazardous Air Pollutants (NESHAP) for various industry manufacturing operations, Control Technology Guidelines (CTG) for ozone nonattainment areas with respect to Volatile Organic Compounds (VOCs) and Volatile Hazardous Air Pollutants (VHAPs) from chemical usage. Mr. Vegh also provides training for ERA Environmental Consulting, Inc.'s web based program; ERA-EMSTM (Environmental Management System; “Virtual Manager”).

Recently Mr. Vegh has been involved in research and development of the Hazardous Waste Management and reduction in relation to environmental reporting with respect to “Virtual Manager” ” in a variety of industries including but not limited to automotive/truck/RV, oil & gas, reinforced plastics, aluminum/PVC/ styrene extrusion, metal, wood and any many others.

Today’s manufacturers are faced with a number of regulatory hurdles that can limit the numbers of units produced within the factory. Factories are built to achieve profitability at varying levels of manning and production levels. Permit rules placing specific amounts of allowable emissions on a facility may in fact restrain that sites ability to reach maximum profitability. In these environments good data management tools are not just an environmental imperative but can positively impact the profitability of the facility. A good EMS system may also reduce the fees paid to states and even provide for a lesser permit with much fewer restrictions.

Case 1
A manufacturer may have a Permit allowing for “x” pounds of HAPS/VOCs per hour, per 5 hour period or other time interval. With good data management & “real time monitoring” the manufacturer can produce up to the maximum number of units without exceeding the regulated ceiling. A good EMS system should receive information from the CEMS devices, data historian, etc. and constantly update the totals / averages for whatever is being regulated under the Permit. That same system will generate “Automated Alerts” for conditions that are in danger of exceeding the limits and notify the appropriate individuals.

Case 2
A manufacturer can use existing data and facility sources to model hypothetical changes to the current production schedule and the probable impacts to emissions---increase in units, change in material, addition of new production capacity through new plant or equipment, or any number of possibilities. The idea is to show where the existing information can be extrapolated to plan for future scenarios.

Case 3
In many cases a good data management system becomes the basis for cost saving material improvement. Product Design Engineers are notorious for designing new products and requiring specific materials from a specific Vendor. The same material may be in existing inventory for another product but under a different name. The chemical constituents are the same but no one will ever know this because the material is inventoried under a different name. A good data management system will search for specific chemicals and identify their location and use.
The data management system will identify opportunities for bringing in material substitutes that are more compliant. Of course the first step is identifying the greatest emissions contributors. Good software will do just that.

Case 4
Good data management may provide hard numbers to regulators justifying a reduction in reporting status with considerable savings in reporting time & fees.

Case 5
With the increased emphasis on EPA Enforcement and upcoming efforts to regulate Green House Gases the need for a data management system is obvious. And future efforts toward Cap & Trade will require that all facilities know their exact emissions. Failure to report correctly will mean heavy fines.