Environmental Management and Compliance News, Tips and Tools

May 9, 2012

Are you ready for TRI Form R Reporting?

image: chemical storage area

Yep, it’s that time of year again. Toxic Release Inventory (TRI) Form R (or Form A, under certain conditions) reports for 2011 are due to the US Environmental Protection Agency by July 1. EPA prefers, of course, that you file electronically, and has proposed a rule requiring electronic filing – but the rule, if finalized, won’t take effect until next year (for the 2012 reporting year). Look to our TRI reporting page to determine if your facility must prepare and submit Form R or Form A reports for calendar year 2011.

Some rule changes will affect reporting requirements for this year:
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Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Toxic Chemicals,Toxics Release Inventory Form R,USEPA — TCozzie @ 10:38 pm

April 4, 2012

EPA revises TPQ… meaning what, now?

On March 22, the Environmental Protection Agency quietly revised 40 CFR Part 355, with respect to how the threshold planning quantities (TPQs) should be derived for Extremely Hazardous Substances (EHSs) that are non-reactive solids in solution. Effective April 23, 2012, a facility should first multiply the weight of the solid EHS in solution by 0.2 and then compare that quantity to the lower published TPQ. Formerly, 100% of the weight of the solid in solution would be compared to the TPQ.

In a regulatory landscape littered with TPQs, RQs (reportable quantities), TRI Thresholds and Clean Air Act TQs (threshold quantities) applied to EHSs, CERCLA Hazardous Substances, Section 313 Toxic Chemicals and Section 112(r) Substances for Accidental Release Prevention among other chemical lists, what is the actual impact of this change? Where do we find regulatory relief?
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Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Tier Two Hazardous Chemical Inventory,USEPA — TCozzie @ 6:34 pm

March 31, 2012

And so it begins…

image: power plant emissions

It’s what you can’t see that is causing all the fuss…

The US Environmental Protection Agency has formally proposed the first national limits on emissions of greenhouse gases, specifically carbon dioxide. The Carbon Pollution Standard, proposed on March 27, will apply to new fossil-fuel electric utility generating units (EGUs). Affected units include boilers, integrated gasification combined cycle (IGCC) units and combined cycle turbine units larger than 25 megawatts. “New” excludes existing units and permitted units that begin construction within the next 12 months. The standard also will not apply to new EGUs that do not burn fossil fuels (for example, facilities that use biomass as fuel).

The proposed standard limits carbon dioxide emissions to 1,000 pounds of carbon dioxide per megawatt-hour of power output. EPA believes that new natural gas fired power plants will be able to meet the standard without add-on emission controls, but coal or petroleum coke units would need to incorporate additional control technologies, such as carbon capture and storage. While the standard does not explicitly forbid the construction of new coal-fired plants, the prohibitive costs for these carbon control technologies will arguably result in a de facto ban on new coal-burning facilities.
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Filed under: Air Pollution,Climate Change,Compliance,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 2:11 pm

March 22, 2012

Joining the Globally Harmonized System for Chemicals

image: a globally harmonized system

Um, no, this is not exactly what we meant by global harmonization…

The Occupational Health and Safety Administration (OSHA) has finalized its rule intended to conform the Hazard Communication Standard to the UN Globally Harmonized System for Classification and Labeling of Chemicals (GHS). The 858-page (gah!) rule can be downloaded here. It is expected to be published in the March 26 Federal Register.

The revisions introduce several important changes to the Hazard Communication Standard:

  • Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • The new format for Safety Data Sheets (no longer Material Safety Data Sheets, or MSDS) requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Workers must be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to current training requirements.

The implementation schedule for the revised Hazard Communication Standard is as follows:
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Filed under: Compliance,Hazard Communication Standard,Health and Safety,OSHA — TCozzie @ 5:05 pm

February 8, 2012

Deadlines and Commitments – February 2012

image: time, gentlemen!
Important compliance deadlines are fast approaching:

March 1 – Hazardous Chemical Inventory reports (“Tier Two reports”) are due for all facilities that store more than 10,000 pounds of hazardous chemicals (loosely defined as any chemical for which a Material Safety Data Sheet is required) or more than the threshold planning quantity of an Extremely Hazardous Substance (EHS).
Reporting requirements, forms and procedures are found at this EPA site.
In Florida, visit the State Emergency Response Commission site.
In Georgia, visit this Environmental Protection Division page.

Also by March 1 – The 2011 Biennial Hazardous Waste Report is due for any large quantity generator of hazardous waste or hazardous waste treatment, storage, disposal or recycling facility. Visit the EPA Hazardous Waste reporting site for forms and instructions.

April 1 – Coming up in Florida, Annual Air Permit Operating Reports will be due. Reporting information can be found at the Department of Environmental Protection website.

For further information and assistance, you can also contact us, of course.

Filed under: Compliance,EPCRA,Florida,Hazardous Waste,RCRA,Reporting,Tier Two Hazardous Chemical Inventory,USEPA — admin @ 11:37 am

January 30, 2012

Global warming worries? Just, relax…

image: snowstorm

Perhaps we’ll be enjoying these scenes for a long time yet…

Are concerns over man-made global warming (i.e., anthropogenic global climate change) overblown? So says this January 27 opinion piece in the Wall Street Journal online, written by sixteen eminent physical scientists. They argue that predictive computer models have exaggerated the potential effects of continued emissions of carbon dioxide, and point to the documented halt (or pause, depending on your perspective) in rising global temperatures over the last decade or so as evidence supporting their position.

Not to be outdone, the UK Daily Mail waded into the global warming debate with two seemingly contradictory articles: First, theorizing that global cooling, not warming, may be a more immediate concern on the global temperature front, based on solar energy cycles – and then, on the same day, reporting that the British government’s national risk assessment on climate change warns that increasing temperatures will lead to “major increases in flooding, heatwaves and water shortages that could kill thousands of people a year.”

What should we make of the current state of anthropogenic climate change science?
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Filed under: Air Pollution,Climate Change,Greenhouse Gases — TCozzie @ 11:03 am

September 7, 2011

Your SPCC Plan – Is it up-to-date?

image: fuel storage tanks in containment

SPCC requirements apply to fuel and oil storage tanks…

By November 10 of this year, all regulated facilities storing more than 1,320 gallons of oil or fuel in above ground tanks and containers must comply with recently amended federal requirements for development and implementation of written Spill Prevention, Control and Countermeasure (SPCC) Plans. If you have existing SPCC Plans for your facilities, you should review them to make sure that they meet the amended rule (40 CFR part 112). If a plan has not been prepared, it should be completed and in use by the November deadline. Note that these federal requirements may be in addition to State regulations governing above ground fuel storage tanks.
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Filed under: Compliance,Rules and Regulations,Spill Prevention Plans,Uncategorized,USEPA — TCozzie @ 12:37 pm

August 29, 2011

Emissions standards for existing boilers at area sources – It’s time to comply!

Photo of Emissions from Boilers and Other Sources

(A little snow in the picture to alleviate the Florida August heat…)

The initial notification date for the National Emission Standards for Hazardous Air Pollutants (NESHAPs) from boilers at area sources (40 CFR part 63 subpart JJJJJJ) is September 17, 2011. By that date, owners or operators of existing, regulated boilers must complete and submit the Initial Notification of Applicability to the appropriate authority (EPA or State environmental agency).

The rule applies to industrial, institutional and commercial boilers located at “area” sources that burn solid fossil fuels, biomass or liquid fuels – e.g., coal, wood, or oil – if not already regulated under another NESHAP standard. An area source is one with the potential to emit less than 10 tons per year of any one Hazardous Air Pollutant and less than 25 tons per year of total HAPs.

Requirements for work practices or the management standard practice of a tune-up must be met by March 21, 2012. Existing sources subject to emissions limits or an energy assessment requirement must comply by March 21, 2014. Emission standards, applicable to existing coal-fired boilers, include Maximum Achievable Control Technology (MACT) standards for mercury and carbon monoxide and Generally Achievable Control Technology (GACT) limits for particulate matter.

Here’s a general guidance on how to comply:  http://www.epa.gov/ttn/atw/boiler/imptools/area_sm_biz_compli_guide_appx.pdf

Here’s more on the boiler MACT rules: http://www.epa.gov/ttn/atw/boiler/boilerpg.html. A copy of the area source rule can be found at http://www.epa.gov/ttn/atw/boiler/fr21mr11a.pdf.

Filed under: Air Pollution,Compliance,MACT,NESHAPs,Rules and Regulations,Uncategorized,USEPA — TCozzie @ 9:07 am

August 25, 2011

New chemical data reporting requirements take effect…

Hazardous Materials Inventory System labelThe US Environmental Protection Agency (EPA) wants more information on commercial chemicals from chemical manufacturers.  Published on August 16, 2011, the EPA’s new Chemical Data Reporting rule (CDR) requires more frequent reporting of critical information on a larger number of chemicals and requires the submission of new and updated information regarding:

  • potential chemical exposures,
  • current production volume,
  • manufacturing site-related data, and
  • processing and use.

The rule limits opportunities for confidentiality claims.  It also requires that the information be submitted via the Internet, using EPA’s electronic reporting tool, e-CDRweb (which will be accessible through the EPA Central Data Exchange, or CDX). The new reporting requirements will take effect in the next data submission period, from February 1 to June 30, 2012.

Get more information and reporting instructions here (http://www.epa.gov/iur/pubs/guidance/aboutsub.html).

Filed under: Compliance,Reporting,Rules and Regulations,Toxic Chemicals,Uncategorized,USEPA — TCozzie @ 4:19 pm

June 12, 2011

Reminder: Deadline for 2010 TRI Form R Reporting is Near!

It’s like this happens every year…

If you have not completed your Toxic Chemical Release Inventory (TRI) reports yet, note that they are due by July 1.

For additional information, refer to our TRI reporting guidance pages:

The US Environmental Protection Agency site for Toxic Release Inventory Reporting is www.epa.gov/tri/.

Of course, feel free to contact T. Cozzie Consulting (but soon!) if you need additional information or assistance.

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Toxics Release Inventory Form R,USEPA — admin @ 3:49 pm
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