Environmental Management and Compliance News, Tips and Tools

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

March 18, 2011

Not ready to report greenhouse gas emissions? No worries…

The Environmental Protection Agency has finalized its rule to extend the deadline for reporting 2010 emissions of greenhouse gases (GHGs) to September 30, 2011. (Reports had been due by the end of this month.)

Those facilities required to report their GHG emissions must first register with the EPA’s electronic greenhouse gas reporting tool (“e-GGRT”). Registration will now be due 60 days prior to the reporting deadline, or by August 1.

For information on the GHG reporting requirements, visit www.epa.gov/climatechange/emissions/ghgrulemaking.html. The e-GGRT reporting tool can be accessed at ghgreporting.epa.gov/ghg/login.do.  And come back to this site soon for upcoming posts on GHG rules.

Filed under: Air Pollution,Climate Change,Compliance,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 3:26 pm

November 1, 2010

Just a little more time – for SPCC Plan updates

The US Environmental Protection Agency (EPA) has extended the deadline for most facilities that are required to prepare or revise their oil Spill Prevention Control and Countermeasure (SPCC) Plans to comply with recent amendments to the SPCC rule.  The compliance date of November 10, 2011, applies to regulated facilities in a broad range of categories, including:

Onshore oil production, farms, electric utility plants, petroleum refining and related industries, chemical manufacturing, food manufacturing, manufacturing facilities using and storing animal fats and vegetable oils, metal and other manufacturing, real estate rental and leasing, retail trade, petroleum bulk stations and terminals, education, hospitals and other health care, fuel oil dealers, gasoline stations, transportation and other commercial, etc.

However, some facilities are not eligible for the extension, and must comply by November 10, 2010.  These include:

Drilling, production or workover facilities that are offshore or that have an offshore component, and

Onshore facilities required to have and submit facility response plans (FRPs), due to the potential threat of significant oil spills to navigable waters or adjoining shorelines from these facilities.

As we must always note, owners or operators of facilities in operation before August 16, 2002, must continue to maintain and implement an SPCC Plan in accordance with the regulations then in effect.

More information on the rule can be found at the EPA webpage,  http://www.epa.gov/emergencies/content/spcc/compliance_dates.htm.

Filed under: Compliance,Rules and Regulations,Spill Prevention Plans,USEPA — TCozzie @ 8:58 am
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