Environmental Management and Compliance News, Tips and Tools

March 31, 2010

For “major” sources of air pollution, the hits keep coming…

In a matter of a few weeks, the US Environmental Protection Agency (EPA) has proposed several actions that could have dramatic impacts for facilities subject to Clean Air Act New Source Review (NSR) provisions (i.e., major sources of air pollutant emissions).  These actions address the grandfathering provision for fine particulate emissions, the fugitive emissions rule and the aggregation rule.  To wit:

  • On February 4, EPA proposed to repeal the NSR “grandfathering provision” for emissions of particulate matter less than 2.5 microns, or micrometers, in diameter (PM2.5), commonly termed “fine particulates.”  The rule had allowed permit applicants to rely on permitting requirements for “coarse particulates” – particulate matter 10 microns or less in diameter, or PM10 -  as a surrogate for PM2.5 requirements if the application had been submitted prior to July 15, 2008.  The EPA proposal also will end the “PM10 surrogate policy” by no later than May 2011, eliminating the use of PM10 as a substitute for PM2.5 analysis in State permitting programs.

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Filed under: Air Pollution,Compliance,Permits — TCozzie @ 3:58 pm

March 29, 2010

EPA formally announces greenhouse gas permitting schedule

The US Environmental Protection Agency (EPA) has announced  that Clean Air Act permits for stationary sources of greenhouse gases (GHGs) will not be required before January 2011 – or, to put it another way, EPA has put the largest sources of greenhouse gas emissions on notice that permitting will commence in January 2011.

Clean Air Act construction and operating permit requirements for the facilities emitting the largest quantities of GHGs will begin when the first national GHG control rule takes effect.  EPA’s target date for implementation of a rule regulating GHG emissions from cars and light trucks is January 2011, when model year 2012 vehicles meeting the standards can first be sold in the United States.  Final greenhouse gas emissions standards for vehicles are pending. image: air emissions stacks at industrial facility

At this point, potentially regulated sources are still waiting for EPA to formally reveal the threshold quantities of GHG emissions that will trigger the requirement for permit limitations on these emissions.

What do you think – too soon?  Can we expect that regulators and regulated industries will be able to identify, engineer and implement effective control technologies and procedures in timely fashion?  And how will the costs affect not only the permitted industries but also chances for an economic recovery?

More information on the EPA approach and its intended timeline can be found at www.epa.gov/nsr/guidance.html.

Filed under: Air Pollution,Compliance,Greenhouse Gases,Permits,Rules and Regulations — TCozzie @ 9:09 pm

March 26, 2010

Compliance Alert: Florida air permit annual operating reports are due April 1

We just wrapped up preparation and delivery of several air permit Annual Operating Reports for Florida clients, using the state Department of Environmental Protection’s electronic annual operating report software.  If you are an air permit holder subject to this annual reporting requirement, be aware that submission of the annual operating report is due by April 1.  That’s right, the due date is less than a week away!

If you haven’t done so already, download the software and get started now.  Or contact us right away for assistance with preparation of your report.

Filed under: Air Pollution,Compliance,Florida,Reporting — TCozzie @ 12:29 pm

March 19, 2010

EPA brushes State rulemakers aside, will set nutrient standards for Florida waterways

Update:  EPA has extended the comment period on the proposed standards for Florida waters until April 28, 2010.

On January 26, the U.S. Environmental Protection Agency (EPA) proposed water quality standards to protect Florida’s waters. The proposed action would set a series of numeric limits on the amount of phosphorus and nitrogen, also known as “nutrients,” that would be allowed in Florida’s lakes, rivers, streams, springs and canals. Major sources of phosphorus and nitrogen pollution include farm operations, particularly fertilizer use and livestock wastes, as well as stormwater runoff and municipal wastewater treatment.

image: storm water outfall

The EPA action was initiated after the federal agency entered into a 2009 consent decree with the Florida Wildlife Federation to propose limits to this pollution.  The consent decree committed EPA to proposing numeric nutrient standards for lakes and flowing waters in Florida by January 2010, and for estuarine and coastal waters by January 2011.  EPA also agreed to establish final standards by October 2010 for lakes and flowing waters and by October 2011 for estuarine and coastal waters.
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Filed under: Florida,Rules and Regulations,States,Storm Water,Wastewater — TCozzie @ 5:40 pm