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

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

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

March 9, 2011

Finally! Air emissions standards for boilers and incinerators

The U.S. Environmental Protection Agency (EPA) has issued final Clean Air Act standards for boilers and certain incinerators to reduce toxic air emissions, including mercury and soot. The rule establishes hazardous air pollutant emission standards for new and existing industrial, commercial and institutional boilers and process heaters located at major and area (minor) sources of toxic air pollutants, as well as commercial and industrial solid waste incinerators.  The final rule was signed on February 21.

EPA proposed these rules in April 2010, after a rulemaking period that began in 2007 when a federal court vacated a previous proposal for industry specific standards. Based on substantial public input that was received after the April 2010 proposal, EPA has made extensive revisions to the rules proposed at that time.

EPA estimates that the boiler rules will affect about 200,000 units located at large (major) and small (area) sources of hazardous air pollutant emissions across the country. The types of boilers covered by the new standards include:

  • Boilers and process heaters at major sources of hazardous or toxic air pollutants, such as refineries, chemical plants, and other industrial facilities, that burn natural gas, fuel oil, coal, biomass or other gases. EPA has further identified some 15 (!) subcategories of regulated boilers and process heaters at major sources.
  • Boilers located at area sources of toxic air emissions, including other industrial facilities, universities, hospitals, hotels and commercial buildings that burn fuel oil, coal or biomass. While these units constitute the far greater number of sources, they are responsible for a relatively small amount of the toxic air emissions addressed by the rule.

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Filed under: Air Pollution,Compliance,USEPA — TCozzie @ 5:22 pm
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