The prevention of stormwater contamination is a major concern that does not discriminate between, and is applicable to, all types of industry. Stormwater can be defined as storm water runoff (e.g. rain flow), snow melt runoff, and drainage. All industrial facilities have some form of stormwater discharge which has the potential to be impacted by pollutants from different types of industrial activities, such as pallets stored outside, forklift traffic between buildings, outdoor parts storage, etc. Due to this potential, all industrial facilities in the United States are required to comply with National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Regulations. Noncompliance with any of the Industrial Stormwater Regulations, such as the discharge of stormwater mixed with pollutants from processes or other industrial activity, is a violation of the Clean Water Act, which regulates the discharge of pollutants to waters of the United States.
Over the past decade, there has been a push by lumber manufacturers to install continuous dry kilns, or CDKs, to supplement or replace batch kilns. There are numerous benefits with CDKs, including higher quality lumber, more efficient combustion of fuel, pre-heating of green, undried lumber with heat that would be lost with a batch kiln, and elimination of charge turnover resulting in a significant increase in production efficiency. With all these benefits, comes a substantial problem: a dramatic increase in the generation of kiln condensate.
The regulations that apply to kiln condensate are complex and typically require stringent permits or alternative management techniques. CTI’s white paper provides an overview of the regulations that are applicable to kiln condensate, and it details the legal options lumber manufacturers have in managing it.
CTI has teamed up with the Fike Corporation and CST to co-host an educational webinar on the ever-growing topic of dust hazards, NFPA Compliance, design approaches and retrofit issues. The webinar will cover:
The Georgia Environmental Protection Division (EPD) continues to roll out features that require the use of the Georgia EPD Online System (GEOS), their online reporting portal. As more features and updates are added to this website, the EPD is taking a more active approach to reviewing the forms and reports that are being submitted. Lately, the biggest item under review seems to be Stormwater Annual Reports from 2017 and 2018. Special attention is being made to review the annual reports for completion of required tests (e.g. Smoke & Dye, stormwater benchmarks, etc.) and other actions. Continue reading “Georgia EPD to Increase Focus on Facility Online Submittals”→
On July 26, 2019, the U.S. Federal Register published the Environmental Protection Agency’s (EPA) proposed amendments to the provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAP). The primary purpose of the proposed amendments is to withdraw the “Once In, Always In” (OIAI) policy regarding the classification of facilities as major sources of hazardous air pollutants (HAPs) subject to Maximum Achievable Control Technology (MACT) standards. A major source is defined as any facility which emits at least 10 tons per year of any HAP or at least 25 tons per year of any combination of HAPs. A facility that is not classified as a major source is considered an area source. The OIAI policy, issued in 1995, required major source facilities that are subject to a MACT standard to permanently comply with that standard even if a facility reduces its HAP emissions below major source thresholds. The withdrawal of the OIAI policy was also previously discussed in EPA’s guidance memorandum issued on January 25, 2018.Continue reading “EPA Proposes NESHAP Amendments to Withdraw “Once In, Always In” Policy for MACT Standards”→
The Occupational Safety and Health Administration (OSHA) requires all employees who are exposed to noise levels with a time-weighted average of 85-decibels or more to be included in a hearing conservation program. These employees must receive audiograms on an annual basis to determine if they experience a certain level of hearing loss known as a “Standard Threshold Shift”. In addition, the facility must also evaluate feasible administrative or engineering controls to reduce employee noise exposure for all employees who are exposed to noise levels at or above OSHA’s permissible exposure limit (PEL) of 90-decibels. If no additional controls are employed, then those employees exposed to noise levels above the OSHA PEL must wear hearing protectors. It is important to remember that, according to OSHA’s Hierarchy of Controls, the use of PPE is the last step to reducing an employee’s exposure to high levels of noise, after engineering and administrative controls. Continue reading “Are Your Noise Monitoring Results Still Valid?”→
CTI’s Director of Engineering, Brian Edwards, joined Dr. Chris Cloney, the Managing Director and Lead Researcher at DustEx Research, to discuss the history of OSHA’s National Emphasis Program (NEP) on combustible dust. In this free, 45 minutes podcast, you can hear Brian and Chris discuss:
The origin of the combustible dust NEP
The programs and regulations that were in place before the NEP
The OSHA rulemaking process
The challenges of establishing a national standard
How OSHA is currently regulating combustible dust standards
On September 6, 2019, the EPA published a proposed amendment to what is commonly referred to as the Plywood or Kiln MACT. This proposed amendment does not address lumber kiln emission standards. EPA has stated that the lumber kiln emission and work practice standards will be addressed in a later proposed amendment.
This proposed amendment to 40 CFR 63, Subpart DDDD: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plywood and Composite Wood Products (PCWP) is based on the completion of the residual risk and technology review. The review has found that no revisions are necessary to the current controls in the original rule. The rule does propose removal of the startup, shutdown, and malfunctions plans as EPA has deemed this to be sufficiently addressed in the work practice standards of the regulation, as well as by the Clean Air Act (CAA).
The proposed rule is open to comments until October 21, 2019. All submissions must include Docket ID No. EPA-HQ-OAR-2016-0243-0034. The EPA encourages that comments be submitted through the Federal eRulemaking Portal located at https://www.regulations.gov/.
If you need help identifying how this proposed rule change will affect your facility or need assistance with providing comments to the EPA, please contact us at (770) 263-6330 or email@example.com.
The National Fire Protection Association (NFPA) is an organization tasked with developing and maintaining fire protection and life safety standards in the United States and worldwide. In addition to subjects such as sprinkler design, flammable liquid storage, and emergency exit requirements, NFPA has standards that deal specifically with combustible dust; a topic that CTI has been focused on for over a decade. There are several NFPA Standards that address combustible dust: NFPA 652 – Standard on the Fundamentals of Combustible Dust, is the overarching standard that applies to all facilities, and there are also several commodity-specific dust standards (e.g. 61 for agricultural and food, 664 for wood products, 484 for metals). CTI is a principal member of the NFPA 61 Technical Committee for Agricultural Dust and has worked with several of the other committees. All of these standards are changing, and CTI is here to help our clients understand what that will mean for them. Continue reading “Changes to Combustible Dust Standards”→
In order to keep employees safe while handling hazardous waste, the Occupational Health and Safety Administration (OSHA) has developed the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), written in 29 CFR 1910.120. These regulations identify information and training requirements that facilities must comply with to keep employees safe during emergency response involving hazardous chemicals. Continue reading “HAZWOPER Requirements for Small Quantity Generators”→