…but fishermen might still have cause for concern:
A flurry of protests followed the U.S. Environmental Protection Agency’s notice on August 24 that it would accept comments on a petition requesting that it ban lead in bullets and shot, as well as in fishing tackle (e.g., lead sinkers). As quickly as the clamor rose, it subsided, when EPA today denied the part of the petition calling for a ban on the production and distribution of lead hunting ammunition. The EPA letter explaining its denial can be found at http://www.epa.gov/oppt/chemtest/pubs/sect21.html.
EPA determined that the agency could not act on the requested ban on lead ammunition because it does not have the legal authority to regulate this type of product under the Toxic Substances Control Act (TSCA) – and stated that it is not seeking such authority.
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On April 29, 2010, the US Environmental Protection Agency (EPA) proposed three rules to regulate hazardous air emissions from commercial, institutional and industrial boilers, process heaters and incinerators at major and area sources.
One of the proposed rules addresses boilers at area sources – facilities that potentially emit less than 10 tons per year (tpy) of any single hazardous air pollutant or 25 tpy of combined air toxics. The rule will apply to facilities with boilers that burn coal, oil or biomass (i.e., wood), but not waste materials. New boilers that burn coal would need to meet emission standards for mercury, particulates and carbon monoxide. New boilers burning oil or biomass will need to meet emission limits for particulates and carbon monoxide. Existing large boilers (heat input of 10 million Btu/hr or greater) that burn coal will be required to meet emission limits for mercury and carbon monoxide; existing large boilers that are oil or biomass-fired will have an emission limit for carbon monoxide, only. The rule requires that all facilities with large boilers conduct an energy assessment to identify practicable conservation measures. Facilities with small boilers will be required only to conduct a boiler tune-up at least once every two years.
The second rule applies to boilers and process heaters at major source facilities. The rule will apply to boilers that burn natural gas, fuel oil, coal, biomass or other gas, but not waste, and to process heaters (which heat raw or intermediate materials in an industrial process).
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Toxic Chemical Release Inventory (TRI) Form R or Form A reports are due by July 1! If your facility:
- has 10 or more employees;
- is included among certain covered industrial categories, including manufacturers that correspond to SIC Codes 20 through 39; some mining operations; utilities that burn coal or oil for commercial electrical generation; chemical wholesalers; petroleum bulk storage terminals; and waste treatment, disposal and recovery facilities; and
- manufactured, imported, processed or otherwise used listed toxic chemicals above threshold reporting quantities,
Then you are likely required to report your releases and off-site transfers of the toxic chemicals. More information on these requirements is linked at www.tcozzie.com/compliance/tri-2009.htm. You can visit the Environmental Protection Agency’s TRI reporting materials page by clicking on the image at right.
Does your facility need to comply? Are you ready to meet this requirement? As always, feel free to contact T. Cozzie Consulting for further information or assistance.
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In the April 22 Federal Register, the Environmental Protection Agency (EPA) proposed to remove saccharin and its salts from the lists of hazardous constituents and commercial chemical products which are hazardous wastes when discarded. EPA also proposed to remove saccharin and its salts from the list of hazardous substances regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
The Calorie Control Council petitioned EPA to remove saccharin and its salts from the above lists. Evaluations conducted by public health agencies such as the National Toxicological Program and the International Agency for Research on Cancer have demonstrated that saccharin and its salts do not have either cancer-causing or other toxic effects that meet the criteria for listing as hazardous constituents, hazardous wastes, and hazardous substances.
When finalized, the proposed amendments will provide relief to manufacturers of soft drinks, flavoring syrups, pharmaceuticals and cosmetics from RCRA requirements to manage and dispose of unused or “off-spec” saccharin and its salts as hazardous wastes, as well as CERCLA reporting requirements for spills or releases.
I found this interesting because I have not heard much about saccharin in years, as other sugar substitutes like aspartame and sucralose (e.g., Splenda) have replaced it in common use. Do you remember when saccharin gained notoriety as a suspected human carcinogen? Do any food products even contain saccharin as a “low-cal sweetener” anymore?
In three four (!) separate notices published in the April 12 Federal Register, the US Environmental Protection Agency has proposed to expand the information required under the Mandatory Reporting of Greenhouse Gases Rule. The additional information to be required includes…
- reporting of emissions of fluorinated greenhouse gases (GHGs) from certain sources, such as electronics manufacturing, production of fluorinated gases, and use of electrical transmission and distribution equipment, as well as manufacture or refurbishment of electrical equipment;
- reporting on carbon dioxide (CO2) injection and geologic sequestration;
- emissions reporting from the following industry segments: petroleum and natural gas production, natural gas processing, natural gas transmission compressor stations, underground natural gas storage, liquefied natural gas (LNG) storage, LNG import and export terminals and distribution; and
- for reporters subject to the rule to provide: the name, address, and ownership status of their US parent company; their primary and all other applicable North American Industry Classification System (NAICS) codes; and an indication of whether or not any of their reported emissions are from a cogeneration unit.
For more information on the proposed rules and how to comment, visit the EPA’s GHG reporting web page.
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On April 6, EPA proposed to add sixteen (16) chemicals to the list of toxic chemicals subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act (your Form R or Form A submissions due each July 1). These sixteen chemicals have been classified by the National Toxicology Program as “reasonably anticipated to be a human carcinogen.” Based on its review of available production and use information, EPA has concluded that these sixteen chemicals are manufactured, processed, or otherwise used in quantities that would exceed the EPCRA section 313 reporting thresholds.
The 16 chemicals include:
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