Environmental Management and Compliance News, Tips and Tools

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

August 30, 2010

EPA to ban lead bullets!… err, maybe not…

…but fishermen might still have cause for concern:

ammunitionA 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.
(more…)

Filed under: Rules and Regulations,USEPA — TCozzie @ 2:11 pm

May 13, 2010

Air pollutant emission standards for boilers and process heaters

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.

(emission control device and exhaust stack)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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Filed under: Air Pollution,Compliance,Rules and Regulations,USEPA — TCozzie @ 5:00 pm

May 11, 2010

Compliance Alert: Deadline for Toxic Chemical Release Inventory Form R report is July 1

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,

(link to EPA reporting page)
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.

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Toxic Chemicals,Toxics Release Inventory Form R,USEPA — TCozzie @ 9:58 am

April 30, 2010

EPA agrees: Saccharin is not so bad, after all…

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?

Filed under: Hazardous Waste,RCRA,Rules and Regulations,Toxic Chemicals — TCozzie @ 2:43 pm

April 20, 2010

EPA proposes expansion of mandatory greenhouse gases reporting requirements

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.

Filed under: Air Pollution,Compliance,Greenhouse Gases,Reporting,Rules and Regulations,USEPA — TCozzie @ 5:50 pm

April 6, 2010

EPA proposes adding 16 chemicals to Toxic Release Inventory reporting rule

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.
image: hazardous substance warning label
The 16 chemicals include:

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Filed under: EPCRA,Reporting,Rules and Regulations,Toxic Chemicals,Toxics Release Inventory Form R,USEPA — TCozzie @ 2:25 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 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

February 23, 2010

EPA Administrator offers timetable for regulating greenhouse gas emissions

In a February 22 letter to members of the US Senate, EPA Administrator Lisa Jackson has proposed a rough schedule for phasing in of regulatory control of greenhouse gas emissions from stationary sources.

Ms. Jackson’s letter (which can be read in its entirety here) anticipates that permit requirements for control of greenhouse gas emissions from large stationary sources will appear in 2011, requiring first those facilities already subject to permitting as major sources of priority or hazardous air pollutants to address greenhouse gas emissions in their permit applications.  Other “large” sources (i.e., those emitting more than 25,000 tons of carbon dioxide and other greenhouse gases per year) will follow, though the Administrator expressed an expectation that the threshold for permitting through 2013 will be substantially higher than the original 25,000 ton level.  Permitting for smaller sources is not anticipated prior to the year 2016, according to Administrator Jackson.

We’ll offer an interpretation of other points raised or answered in Ms. Jackson’s letter in a later post.

Filed under: Air Pollution,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 3:46 pm
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