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HRP was retained to assist in the environmental engineering and health & safety compliance effort to convert manufacturing operations to a “green” facility by changing the chemical formulations of the foaming process to one utilizing non-HCFC’s. Specifically, HRP was asked to secure Mexican air quality permits for a flammable VOC source, as well as to provide safety management planning according to both Mexican SEMARNET Risk Planning and US-OSHA Regulation 29 CFR 1910.119 Process Safety Management. HRP conducted this project to meet all requirements of the Mexican authorities including: local/state Fire Marshals, SEMARNET Environmental Regulations, NFPA and NEC electrical and safety codes.

The Environmental Impact Assessment (EIA) was prepared and approved prior to the initiation of the projected activity. The requirement for preparing and submitting an EIA lies on Mexico’s General Law of Ecological Equilibrium and Environmental Protection (LGEEPA). The complexity of the EIA depended on the characteristics of the project, called Preliminary Environmental Impact Assessment (PEIA). With HRP’s assistance, the Rheem facility was required to notify the environmental agency of the production modifications and expansions involving the flammable chemical substitution.

A Risk Assessment (RA) was necessary as operations involved the use/storage in Reportable Quantities (RQs) of a cyclopentane considered High-Risk (Primero y Segundo Listados de Actividades Altamente Riesgosas). The RA was submitted and approved prior to installation of the projected high-risk operation at each plant. The evaluation and approval of high-risk operations was completed under Federal jurisdiction (i.e. SEMARNAT) in Mexico, and the individual States (Baja California and Tamaulipas). Each facility submitted a Program for Prevention of Accidents (PPA), a comprehensive document that reflected the risk conditions at the site and the appropriate response actions that were to be taken during an emergency event, to SEMARNET.

Air emission sources under Federal jurisdiction were required to obtain a Single Environmental License (LAU). The License application was presented to the regional office of the Federal environmental agency SEMARMAT. The LAU application included: general information of the company, description and flow charts of manufacturing processes, air emissions data, stack configurations, site layouts, information on the generation of hazardous waste, information on water usage and generation of wastewater, etc. The requirement for obtaining the LAU was prepared in accordance with Mexico’s General Law of Ecological Equilibrium and Environmental Protection (LGEEPA).

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