Environmental Management and Compliance News, Tips and Tools

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.

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

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

August 9, 2010

Scoffing at skeptics…

On July 29, The U.S. Environmental Protection Agency (EPA) denied 10 petitions challenging its 2009 determination that

  • climate change is real,
  • it is occurring due to emissions of greenhouse gases from human activities, and
  • it threatens human health and the environment.

EPA’s decision rejected claims that climate science cannot be trusted and that collusion (dare we say, a “conspiracy”?) among members of leading research bodies to suppress conflicting data and hide errors or gaps in their own research invalidates the findings of the Intergovernmental Panel on Climate Change (IPCC), the U.S. National Academy of Sciences, and the U.S. Global Change Research Program. Having given “months of serious consideration” to the petitions and to the state of climate change science, EPA found no evidence to support these claims. In fact, EPA has determined that climate science is credible, compelling, and growing stronger!

EPA Administrator Lisa P. Jackson blamed the petitions on “defenders of the status quo [who] will try to slow our efforts to get America running on clean energy,” and called on petitioners “to join the vast majority of the American people who want to see more green jobs, more clean energy innovation and an end to the oil addiction that pollutes our planet and jeopardizes our national security.”

The basic assertions by the petitioners and EPA responses follow.
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Filed under: Air Pollution,Climate Change,Greenhouse Gases,USEPA — TCozzie @ 2:36 pm

August 2, 2010

EPA to delay compliance deadline for Spill Prevention, Control and Countermeasure (SPCC) Plans

The Environmental Protection Agency (EPA) has proposed to extend the compliance date for some facilities subject to the Spill Prevention, Control and Countermeasure (SPCC) Rule amendments.

(aboveground storage tank in secondary containment) Drilling, production or workover facilities that are offshore or onshore facilities required to have and submit facility response plans (FRPs) will not be eligible for the proposed extension, and must prepare or update their SPCC Plans in accordance with the rule amendments by November 10 of this year. Other facilities, including onshore oil production facilities, farms, utilities, various manufacturers, petroleum bulk storage and retail, transportation and commercial operations may put off their plan and facility updates until November 10, 2011.

Provided, of course, that facilities that were in operation and subject to SPCC regulations before August 16, 2002, maintain and continue to implement their existing SPCC Plans in accordance with the regulations that were then in effect.

More information on SPCC requirements can be found at this page. Please comment below or contact T. Cozzie Consulting if you have questions or concerns about how these requirements affect your facility.

Filed under: Compliance,Spill Prevention Plans,USEPA — TCozzie @ 6:18 pm

July 5, 2010

Announcing our latest upgrade of the Virtual Environmental (& Health & Safety) Manager Program

(Virtual Environmental Manager Welcome Screen)
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Filed under: Compliance,Solutions — TCozzie @ 5:12 pm

June 17, 2010

Reminder – TRI Reports due in two weeks!

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:

Of course, feel free to contact T. Cozzie Consulting (but soon!) if you need additional information or assistance.

Filed under: Compliance,Reporting,Toxics Release Inventory Form R — TCozzie @ 4:57 pm

June 3, 2010

Chrome platers – you must notify your employees of ALL hexavalent chromium exposures

The US Occupational Safety and Health Administration (OSHA) has confirmed that employers will be required to notify their workers of all hexavalent chromium exposures, effective June 15, 2010. Previously, OSHA’s Hexavalent Chromium standard required workers be notified only when they experienced exposures exceeding the permissible exposure limit.

chromium symbol
Occupational exposures to hexavalent chromium can occur among workers operating chrome plating baths, of course, as well as when handling pigments, spray paints and coatings containing chromates and welding or cutting metals containing chromium (e.g., stainless steel).

More information on protecting workers from exposure to this chemical can be found on OSHA’s Safety and Health Topics page on Hexavalent Chromium.

Filed under: Health and Safety,OSHA,Toxic Chemicals — TCozzie @ 10:20 am

May 13, 2010

Thresholds for greenhouse gas permitting announced

On May 13, the US Environmental Protection Agency (EPA) announced its final “GHG Tailoring” rule to address greenhouse gas (GHG) emissions from stationary sources. The phased-in approach will initially address large facilities like power plants and oil refineries that emit most of the greenhouse gases from stationary sources. The regulated GHGs include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride.

(image of clouds)Starting in January 2011, Clean Air Act permitting requirements for GHGs will apply to large facilities that are already obtaining Clean Air Act permits for other pollutants. Those facilities will be required to include GHGs in their permit if they increase their GHG emissions by 75,000 tons per year (tpy). In July 2011, permitting requirements will expand to cover all new facilities with GHG emissions of at least 100,000 tpy and modifications at existing facilities that would increase GHG emissions by at least 75,000 tpy. The permits must demonstrate the use of best available control technologies to minimize GHG emission increases when facilities are constructed or significantly modified. EPA estimates approximately 900 additional permitting actions covering new sources and modifications to existing sources would be subject to review each year. In addition, 550 sources will need to obtain operating permits for the first time because of their GHG emissions.

Permitting requirements for smaller sources will await the findings of a 5-year study of the effects of GHG permitting of these sources, slated for completion in 2015.

According to the EPA press release announcing the final rule, the agency received about 450,000 (!) comments within the 60-day public comment period that followed issuance of the proposed rule in October 2009.

More information on the GHG Tailoring Rule and its implementation schedule can be found at http://www.epa.gov/nsr/actions.html.

What do you think? Has EPA struck the proper balance between regulating a significant threat to health and the environment and providing relief to small businesses and farms?

Filed under: Air Pollution,Compliance,Greenhouse Gases,Permits,USEPA — TCozzie @ 5:01 pm
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