Environmental Management and Compliance

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.
Continue reading “And so it begins…”

Um, no, this is not exactly what we meant by global harmonization…

The Occupational Health and Safety Administration (OSHA) has finalized its rule intended to conform the Hazard Communication Standard to the UN Globally Harmonized System for Classification and Labeling of Chemicals (GHS). The 858-page (gah!) rule can be downloaded here. It is expected to be published in the March 26 Federal Register.

The revisions introduce several important changes to the Hazard Communication Standard:

• Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
• Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
• The new format for Safety Data Sheets (no longer Material Safety Data Sheets, or MSDS) requires 16 specific sections, ensuring consistency in presentation of important protection information.
• Workers must be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to current training requirements.

The implementation schedule for the revised Hazard Communication Standard is as follows:
Continue reading “Joining the Globally Harmonized System for Chemicals”

Perhaps we’ll be enjoying these scenes for a long time yet…

Are concerns over man-made global warming (i.e., anthropogenic global climate change) overblown? So says this January 27 opinion piece in the Wall Street Journal online, written by sixteen eminent physical scientists. They argue that predictive computer models have exaggerated the potential effects of continued emissions of carbon dioxide, and point to the documented halt (or pause, depending on your perspective) in rising global temperatures over the last decade or so as evidence supporting their position.

Not to be outdone, the UK Daily Mail waded into the global warming debate with two seemingly contradictory articles: First, theorizing that global cooling, not warming, may be a more immediate concern on the global temperature front, based on solar energy cycles – and then, on the same day, reporting that the British government’s national risk assessment on climate change warns that increasing temperatures will lead to “major increases in flooding, heatwaves and water shortages that could kill thousands of people a year.”

What should we make of the current state of anthropogenic climate change science?
Continue reading “Global warming worries? Just, relax…”

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.
Continue reading “Your SPCC Plan – Is it up-to-date?”

(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.

The 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).

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.

Continue reading “Finally! Air emissions standards for boilers and incinerators”

…but fishermen might still have cause for concern:

A 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.
Continue reading “EPA to ban lead bullets!… err, maybe not…”