RE: RCRA enforcement;

COVID 19 should not be an excuse for failure to comply with RCRA regulations
nor should it be an excuse for failure to enforce them. The days of climbing
a chimney with an air sample pump are long gone. Although grab sampling and
laboratory analysis is necessary in some cases and to verify and process
monitoring accuracy; The majority of industrial and municipal effluent
monitoring is largely performed in situ process instrumentation with signals
sent to computers.

Moreover, This data can be made available for at home analysis by the
company EHS staff and reported to the responsible regulatory agency who
should also be able to view reports in a work-at-home situation if required..

I worked for Arizona State University 25 years ago and even back then much
of our central plant effluent and water chemistry monitoring, both
operational and pollution control was in situ. Process signals were
continuously transmitted to our DDS Computer, some data were transmitted to
Germany where it was organized for reporting. Required chemical addition was
also managed with that computer in Germany by remotely opening, closing and
adjusting applicable valves.

Industry as well as government should not get away with using COVID 19 to
avoid either compliance or enforcement - we can mail or Email citations.

Every cloud has a silver lining. The realization that many of us can
efficiently Work-at-Home will hopefully continue engender more of the
practice. This can result in substantial greenhouse gas production from
unnecessary daily commuting.

Jim Keating


-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On
Behalf Of Stuart, Ralph
Sent: Friday, March 27, 2020 1:46 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] U.S. stops enforcing many environmental laws, citing
pandemic

>But industries are largely given a pass if they can document that they
could not perform an activity due to COVID-19 impacts, i.e. stack testing,
fence line monitoring, etc.

I would note that 48 states have enforcement responsibilities as well as
those at the Federal level. For example, our NH state regulators said that
they expect to continue to enforce RCRA inspection requirements for
hazardous waste accumulation areas. So, the federal policy will have varied
impacts from state to state, much as we are seeing with the Covid response
policies and practices.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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