Environmental Management and Compliance

Oooh, shiny. (and good housekeeping, too!)

On September 19, 2012, the US Environmental Protection Agency published a final review amending the National Emission Standards for Hazardous Air Pollutants: Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR Part 63, Subpart N). In addition to revised emission limits for total chromium and other changes, the rule amendment introduced requirements for housekeeping practices to minimize fugitive emissions. These housekeeping procedures must be implemented within six months after publication of the rule, or by March 19, 2013.

Required housekeeping procedures include:

• storage of substances containing hexavalent chromium in closed containers in an enclosed area, and transport of these substances in closed containers, only;
• drip trays, containment or on-site treatment as controls for dripping of plating bath solution during dragout;
• splash guards for electroplating and anodizing tanks;
• prompt (i.e., within one hour) cleanup and containment of spills of hexavalent chromium substances;
• routine cleaning and stabilization of storage and work surfaces, walkways, and other surfaces that could become contaminated with hexavalent chromium;
• installation of barriers between plating or anodizing equipment and any buffing, grinding or polishing operations; and
• proper storage, disposal, recovery or recycling of chromium-containing wastes.

Continue reading “Housekeeping for Chrome Platers”

RICE. On a sugar cane farm. (No, really!)

The US Environmental Protection Agency announced on January 14 that it has finalized revisions to standards for emissions from stationary engines that generate electricity and power equipment, better known as Reciprocating Internal Combustion Engines (“RICE”) in regulatory parlance.

The final rule amends the 2010 National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE) to address challenges to the 2010 rule by regulated industries. The 2010 rules separately addressed compression ignition engines, powered by diesel fuel, and spark ignition engines, usually powered by gasoline or natural gas. Both rules prompted petitions for reconsideration.

Among other changes, the amendments specify how the standards apply to emergency engines used for emergency demand response. Under the rules, any engine may operate without emissions limitations during an emergency. However, the emergency operating time during Level 2 energy emergency alerts – events with potential for blackouts – was limited to 15 hours per year. This 15-hour limit was viewed as insufficient to allow engines to be used in emergency demand response programs. Therefore, the amended provisions allow owners and operators to operate their engines as part of an emergency demand response program within the 100 operating hours separately allotted for maintenance and testing.

Continue reading “EPA is on a Roll! RICE emission standards finalized…”

These belching smokestack pictures never get old, right? Uh, right?

On June 29, the US Environmental Protection Agency (EPA) issued “Step 3” of the Greenhouse Gas (GHG) Tailoring Rule, confirming that the GHG emissions thresholds for permitting under the New Source Prevention of Significant Deterioration (PSD) and Title V Operating Permits programs would remain unchanged from the levels set in July 2011.

PSD permit requirements will continue to apply for new facilities that emit more than 100,000 tons per year (tpy) of carbon dioxide equivalents and for existing facilities subject to PSD that intend to increase GHG emissions by 75,000 tpy. Title V operating permit requirements apply to new and existing facilities that emit more than 100,000 tpy of CO2 equivalents.
Continue reading “Don’t Fear the GHG Permitting Rule (Yet!)”

On June 18, the US Environmental Protection Agency (EPA) quietly extended the deadline for submission of the inaugural Toxic Substances Control Act (TSCA) Chemical Data Reports, formerly known as TSCA Section 8(a) Inventory Update Reports. (Just in time, as the reports were due by June 30.) But don’t relax just yet – the revised due date is August 13, 2012, just a month away!

The CDR rule (40 CFR part 711) requires manufacturers and importers of certain chemical substances included on the TSCA Chemical Substance Inventory to report current data on the manufacturing, processing, and use of the chemical substances. (I know what you’re thinking: Didn’t we just report this information on our annual Toxic Release Inventory Form R submissions? But, really, this is something different.) The required data include current information on chemical substance production volumes, manufacturing sites, and how the chemical substances are used.

As amended in the August 16, 2011, Federal Register, the Inventory Update Rule was renamed the Chemical Data Reporting rule with the following reporting thresholds and requirements:
Continue reading “After a brief respite, TSCA Chemical Data Reporting deadline looms”

Even if you only ship hazardous wastes, you may need to register…

The US Department of Transportation’s Pipeline and Hazardous Material Safety Administration (PHMSA) requires both shippers and carriers of certain types or amounts of hazardous material to register and pay a fee each year by June 30 (or prior to the shipping activity).

The following hazardous materials and/or hazardous wastes carried on board a vehicle or offered for shipment at any one time trigger annual registration:

• A highway route-controlled quantity of a Class 7 (radioactive) material;
• More than 25 kg (55 lb) of a Division 1.1, 1.2, or 1.3 (explosive) material;
• More than one liter (1.06 quarts) per package of a material extremely toxic by inhalation (that meets the criteria for hazard zone A);
• A shipment of a quantity of hazardous materials, including hazardous waste, in bulk packaging with a capacity equal to or greater than 13,248 liters (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids; even if the materials are Class 9 hazardous that do not require placarding;
• A shipment in other than a bulk packaging of 2,268 kg (5,000 lb) gross weight or more of one class of hazardous materials – including hazardous wastes – for which placarding is required; or
• A quantity of hazardous material that requires placarding (with some exceptions for farmers).

Continue reading “Hazardous Materials Transport – Do You Need to Register?”

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:
Continue reading “Are you ready for TRI Form R Reporting?”

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?
Continue reading “EPA revises TPQ… meaning what, now?”