All industrial facilities have a vested interest in operating in the most environmentally responsible and safe manner possible. This is because operating in this manner carries with it the lowest risk of interruption to production. Whether that interruption is in the form of a hazardous material release, regulatory violation, injury, lawsuit, or negative publicity, this is a situation that no facility wants to find themselves in. Reducing the potential for environmental pollution and improving worker safety might seem secondary to production, but serious injuries and regulatory violations can have significant implications which can range from heavy fines to shutting down operations entirely. All industrial facilities should, at the very least, take the time to consider whether they are currently running the risk of being impacted by these types of issues.

Continue reading “The Necessity of Environmental and Safety Compliance Reviews”

One of the easiest ways for an EPA or state inspector to find violations is to compare your current operating equipment and emissions with the permitted equipment and emissions. If you do not keep your Air Quality Permit up to date, you run the risk of an inspector finding serious violations – which come with serious monetary fines. This applies to your facility whether your permit is a Title V, Synthetic Minor, or even True Minor operating permit.

If you operate under a Title V Air Quality Permit, you are required to renew your permit every 5 years, and likely have an annual inspection conducted by the EPA or state. With these measures in place, chances are your Air Quality Permit is staying up to date. However, anytime your facility installs new operating equipment or removes/decommissions old operating equipment you should reassess your air emissions. Continue reading “Is My Facility Fully Covered by My Air Quality Permit?”

On July 26, 2019, the Environmental Protection Agency (EPA) proposed revisions that would allow an operating facility to be reclassified from a major source of hazardous air pollutants under Section 112 of the Clean Air Act to an area source, thus removing the policy commonly known as “once in, always in”. This revision could take a lot of pressure for capital investments and permitting off of facilities that are eligible.

Continue reading “EPA Allows Reclassification from A Major Source of Hazardous Air Pollutants (HAP) to An Area Source”

On January 31, 2013, the U.S. Environmental Protection Agency (EPA) finalized amendments to the national emission standards (NESHAP) for the control of hazardous air pollutants (HAP) at major sources from new and existing industrial, commercial, and institutional (ICI) boilers and process heaters (Boiler MACT). Subsequently, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit), in a decision issued in July 2016, remanded several of the emission standards to the EPA based on the court’s review of the EPA’s approach to setting those standards. In response to these remands, this action proposes to amend several numeric emission limits for new and existing boilers and process heaters consistent with the court’s opinion and set compliance dates for these new emission limits. Continue reading “EPA’s Proposed Revisions to Emission Limits for Boiler MACT”

Indoor air quality is important for employee health and comfort. Poor air quality can lead to several negative health effects, including irritation, coughing, and fatigue. More serious health hazards such as occupational asthma, specific organ toxicity, or cancer can also occur, depending on the chemicals being handled on site. Because of this, the Occupational Safety and Health Administration (OSHA) has developed permissible exposure limits (PELs) for several dusts, fumes, and vapors from various chemicals. These PELs, found in 29 CFR 1910.1000 Table Z-1, identify the maximum concentrations of different chemicals and materials an employee can be exposed over the course of an 8-hour work shift. Employees exposed to airborne concentrations of a material above a PEL may be at risk for serious health hazards. Continue reading “When Should You Retest Your Indoor Air Quality?”

Every year, the Georgia Environmental Protection Division (EPD) requires that certain Title V major source facilities submit their air emission data to the state. EPD submits this emission data to the U.S. Environmental Protection Agency (EPA) as part of the National Emissions Inventory (NEI) released every three years. The NEI is a comprehensive and detailed estimate of air emissions comprising of data from State, Local, and Tribal air agencies across the country. This data is used by the agencies for rule development, attainment/nonattainment designations, and State Implementation Plans (SIPs) for attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). Continue reading “2019 Air Emission Inventory Reporting – Georgia”

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.

Facilities are required to ensure that any stormwater discharging from their property is free from contaminants by conducting analytical sampling. Continue reading “Management and Prevention of Stormwater Benchmark Exceedances”

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”

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 cti@conversiontechnology.com.

The Emission Inventory for Georgia facilities is due to the Georgia Environmental Protection Division (GAEPD) by June 30, 2019. This is for the mandatory reporting of facility emissions that occurred in calendar year 2018. This is part of the US Environmental Protection Agency’s (USEPA) National Emissions Inventory (NEI). The NEI is developed during three-year cycle reporting periods, where all Title V (or Part 70) permitted sources will be required to report at least every third year. The other two years only comprise larger sources with greater emission potentials. The 2017 emission inventory required all Title V sources to report. The 2018 inventory due this year, and the 2019 inventory that will be due in 2020, is for the larger Title V sources only. Continue reading “Air Emission Inventory Due End of June”