The Soundcoat Company, Inc.

Posted on July 30, 2015

Client: The Soundcoat Company, Inc.
Location: Deer Park, NY

Major Components

  • Multimedia Environmental Compliance Audit
  • Corrective Action Program
  • Environmental Management System

Project Description

IntroductionEPA Section 313

The firm was retained by The Soundcoat Company, Inc. (“Soundcoat”) located in Deer Park, Suffolk County, New York, to  undertake an evaluation of the company’s manufacturing operations with respect to compliance with applicable federal, New York State and Suffolk County environmental statutes and regulations. The purpose of the assignment was threefold. First, the firm was charged with conducting a comprehensive multimedia environmental compliance audit of the manufacturing operations at its Deer Park facility. Secondly, once any areas of noncompliance or deficiencies were uncovered, the firm was directed to systematically correct and document the noncompliant situation Third, the firm was requested to develop an Environmental Management System (EMS) designed to not only maintain current compliance at the facility, but also to be responsive to changes in chemical usage, modifications to existing process operations and changes in personnel on a “going forward” basis.

The Soundcoat facility is located in the Hamlet of Deer Park, Town of Babylon, Suffolk County, New York. The facility manufactures noise attenuation and vibration dampening products. The product line is basically a composite material consisting of alternating layers of foam rubber in combination with a thin lead foil which is protected by silicon-based, coated-paper backing. Each layer of the composite material is held together with a specialty adhesive. Typically, the sound/vibration dampening product consists of two approximately 0.25-inch layers of foam rubber separated by a 14 gauge sheet of rolled lead. A 3 mil coating of specialty adhesive is used to adhere the layers of foam to the lead sheet. Lastly, a silicone-coated paper backing or liner is attached to one side, again utilizing an approximate 3 mil thick adhesive coating. In certain cases, the approximately 4 foot by 8 foot sheets of this composite material are cut into specific shapes as required by customer specifications.

Specific “operational” areas identified at the Deer Park facility during the inspections included:EPA form

The multimedia environmental compliance audit and environmental management system assignment consisted of the following phases:

  • Office Space, Cafeteria, Bathrooms
  • Loading Dock
  • Storage/Receiving Area
  • Solvent Room
  • Compressor Room
  • Former Mixing Room
  • Dyad Room
  • “Water-Jet” Machine Area
  • Shop Floor – containing various embossing, laminating and molding machines and cutting equipment
  • Spray/Coating Line
  • Template Storage Area
  • Spray Booths
  • Boiler Room
  • Engineering Test Laboratory
  • Empty Drum Trailer
  • 10,000-gallon Fuel Oil UST
  • 2,900-gallon UST
  • 550-gallon UST
  • Sanitary Leaching Field
  • Phase I – Multimedia Environmental Compliance – Audit Program
  • Phase II – Multimedia Environmental Compliance – Corrective Action Program
  • Phase III – Environmental Management System
  • Phase IV – Training Program

Phase I – Multimedia Environmental Compliance – Audit Program

In order to complete this assignment, the firm conducted a review of existing procedures, permit applications, permits, inspection reports and other appropriate records in the files in order to ensure that applicable environmental regulations were being adequately addressed. In addition, the audit team met with Soundcoat representatives for the purpose of conducting site inspections and interviews to clarify any questions regarding the manufacturing operations at the facility and to obtain information regarding the status of existing environmental programs.

The following major federal, New York State and Suffolk County environmental/regulatory programs were addressed as part of this environmental compliance audit:

  • Resource Conservation and Recovery Act (RCRA);
  • Hazardous and Solid Waste Amendments (HSWA);
  • Clean Air Act (CAA);
  • Clean Water Act (CWA), including the National Pollutant Discharge Elimination System (NPDES) requirements;
  • Superfund Amendments and Reauthorization Act (SARA) including the Emergency Planning and Community Right-to-Know Act (EPCRA);
  • Toxic Substances Control Act (TSCA);
  • Federal Insecticide, Fungicide and Rodenticide Act (FIFRA);
  • New York State Petroleum Bulk Storage (PBS) regulations;
  • New York State Chemical Bulk Storage (CBS) regulations; and
  • Suffolk County Article 12 – Toxic and Hazardous Materials Storage and Handling Controls.

Phase II – Multimedia Environmental Compliance – Corrective Action Program6 NYCRR sub-part sections list pertaining to chemical bulk storage

The second phase of the program consisted of the implementation of a corrective action program to address each of the environmental program areas identified as having deficiencies as a result of  the audit. To assist the company’s senior management with this phase of the program, a short- and long-term corrective action schedule was developed as a “blueprint” to track the progress of the compliance team with respect to each program area. The list presented below highlights a number of the program areas addressed as part of this phase of the program.

  • Resource Conservation and Recovery Act (RCRA)
    • Hazardous Waste Determination
    • Determine Generator Status
    • Develop Hazardous Waste Management Plan
      • Standard Operating Procedures
        • Solvent Storage Room Management
        • Solvent Storage Room Inspection Form
        • Solvent Storage Room Inventory Log
        • Fluorescent Light Bulb Management
        • Empty Drum Storage Container Management
        • Empty Drum Storage Container Inspection Form
        • ƒOn-site Accumulation/Staging of Hazardous Waste Prior to Shipment
        • Laboratory Chemical Disposal Management
      • Establish Point of Generation Accumulation Areas/Staging Areas
      • Training
  • Clean Air Act (CAA)
    • Develop Monthly Log for Solvent/Coating Usage Compliance with Cap-By-Rule Regulations
  • Clean Water Act (CWA)
    • Post SPDES Permit in a Conspicuous Location
    • Compliance of Engineering Test Laboratory with SPDES Permit
  • Superfund Amendments and Reauthorization Act (SARA)/ Emergency Planning and Community Right-to-Know Act (EPCRA)
    • Develop “Threshold Determination” Spreadsheet for SARA Form R’s and Tier I/II
    • Prepare Draft/Final SARA Form R’s for Reporting Year 2000
      • Toluene
      • Xylene
    • Prepare Draft/Final Tier I/II Forms (5 products)
  • Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
    • Ensure Contractor Compliance
  • Petroleum Bulk Storage (PBS)
    • Oil Pollution Prevention
    • Petroleum Bulk Storage (see Suffolk County Sanitary Code –
      Article 12, below
  • Chemical Bulk Storage (CBS)
  • Suffolk County Sanitary Code – Article 12
    • Closure/Report of Floor Drains/Grit Chamber — Closure/Report of 2,900-Gallon UST
    • Closure/Report of 550-Gallon UST
    • Limit Storage of GP-1 (Aquaplas DL-10) to less than 250 Gallons
    • Empty Drum Storage Container
    • Compressor Blowdown Room
    • Obtain Permit for Laminating Press Oil Reservoir Tank
    • Modify Permitting Storage Capacity of Solvent Storage Room
    • Standard Operating Procedures
      • 10,000-Gallon No. 2 Fuel Oil UST
        • Leak Detection System Inspection Form
        • Overfill Protection System Inspection Form
        • Product Level Form
        • Cathodic Protection System Form
        • Tank Integrity Test Form
      • Compressor Blowdown Management
        • Compressor Blowdown Inspection Form
      • Empty Drum Storage Container Management
        • Empty Drum Storage Container Inspection Form
      • “Water Jet” Machine Sump Pump and Drum Collection System
        • Sump Pump and Drum Collection Inspection Form

Phase III – Environmental Management System

In addition to undertaking and completing the self-audit process, as well as implementing a corrective action program to address compliance deficiencies, the firm was retained to institute an Environmental Management System at the company to address future compliance maintenance. Towards that end, the firm developed a chart identifying the organizational units at the company responsible for specific environmental compliance program areas. To support the environmental compliance-specific organization chart, “lead” and “backup” Team Leaders were identified for each major environmental program area. The cornerstone of the EMS was preparation and distribution of an environmental policy statement by the President of the company. The policy reaffirmed the commitment to environmental compliance and charged the individuals identified on the organization chart with responsibility for maintaining environmental compliance in the future. This organization chart and policy statement, in conjunction with the development of Standard Operating Procedures specific to each area of the company’s operations requiring ongoing environmental compliance, served as the foundation of the EMS.

Phase IV – Training Program

Once the Environmental Management System phase of the assignment was completed, a comprehensive training program at various levels within the organization was implemented. Utilizing the organization chart prepared as part of the EMS as a blueprint, a media-specific training program was developed to address ongoing compliance at various levels within the management structure. Utilizing the individuals identified as either “lead” or “backup” in the Environmental Management System, standard operating procedures targeting specific areas of environmental compliance were developed and formed the basis for “focused” training sessions.

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