Industrial Stormwater Permitting requirements have been in place for over 20 years. Facilities that fall under one of eleven industry categories identified by the US Environmental Protection Agency (USEPA) and have material handling and storage, equipment maintenance and cleaning, and other activities exposed to stormwater are required to have a permit to discharge their stormwater runoff. Stormwater runoff is generated from rain and snowmelt events that flow over land or impervious surfaces, such as paved streets, parking lots, and building rooftops, and does not soak into the ground. The runoff picks up pollutants like trash, chemicals, oils, and dirt/sediment that can harm our rivers, streams, lakes, and coastal waters. Most often, industrial facilities are covered under General Permits issued by the State, but some facilities have individual permits. Continue reading “Industrial Stormwater Compliance – Increased Focus from Regulators”
For many industrial facilities, staying on top of the numerous and ever changing Environmental Protection Agency (EPA) regulations can be difficult and sometimes frustrating. One area that we have seen many facilities having issues with is following the regulations and requirements associated with the Resource Conservation Recovery Act (RCRA). RCRA regulations are those that govern the management of hazardous waste, solid waste, bio-hazardous waste, and universal waste. In this article, we will explore some of the most common mistakes made within general industry when handling, storing, and generating waste streams, and potential violations that are the result of these mistakes. Continue reading “Common Mistakes in Handling Waste”
Changes to EPA “Once In Always In” Policy for MACT Rules
On January 25th 2018, the EPA released a guidance memo reversing the “Once in Always in” (OIAI) policy regarding the classification of major source facilities subject to MACT (Maximum Achievable Control Technology) standards. A major source is defined as any facility which emits at least 10 tons of any Hazardous Air Pollutant (HAP), or 25 tons of any combination of HAPs. This policy, which has been in place since 1995, stated that any major source that becomes subject to a MACT rule must stay in compliance with that rule permanently, even if the facility finds a way to drop emissions below major source thresholds. Continue reading “Federal, State, and Local Changes to Air Permitting Requirements”
In November of 2016, the Environmental Protection Agency (EPA) published its final rule on hazardous waste generator requirements. This rule provides guidance and best management practices (BMPs) for all levels of hazardous waste generators. This article will explore some of the changes in requirements for hazardous waste generators with the passage of the new rule. Continue reading “Changes to Hazardous Waste Generator Regulations”
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), for the “Plywood Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP) Risk and Technology Review (RTR)” (Kiln MACT) to the office of Management and Budget (OMB) for preview and approval.
This Kiln MACT applies to every sawmill that is a Major Source or Synthetic Minor Source for Hazardous Air Pollutants (HAP).
The ICR will be sent to all known operators of PCWP facilities that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering NESHAP applicability. The information collection seeks to collect facility-level information (e.g. facility name, location, contact information, and process unit details), emissions information, compliance data, control information, and descriptions of technological innovations.
The EPA will either establish an emission limit or work practices in order to minimize emissions for process units included in the PCWP MACT source category. Capturing, controlling, and the measurements of kiln emissions is not feasible. Installing emissions capture and add-on control equipment for VOC/HAP removal have not been identified. It is therefore predicted that facilities will choose to use work practice requirements in lieu of emission limits.
The purpose of work practices is to minimize HAP emissions. For most kiln schedules, the HAP emissions increase near the end of the drying cycle when the wood reaches its final moisture content. HAP emissions increase as the moisture content decreases.
If you operate a lumber kiln, you will need to develop a plan for minimizing HAP emissions from the lumber kiln(s) by minimizing the annual average variability in dried lumber moisture content. Plans must be required to be submitted to the appropriate regulatory agency with your Notice of Compliance Status and you will need to maintain appropriate records of compliance with the work practices.
Changes in kiln operating temperatures can significantly affect mill operations and drying capacity. Lower kiln temperatures result in longer drying times. This is a production and capacity issue for mills. A mill operating four lumber kilns at full capacity at 225OF would have to add two more lumber kilns to dry the same amount of lumber at 180OF. To overcome the potential Kiln MACT limitation, facilities will need to prepare a compliance work practice plan that minimizes emissions with the least affect to drying production.
Shortly Major Source and Synthetic Minor Source of HAPs will receive an ICR survey. You will have 120 days after ICR mailout to submit it. CTI is experienced in this area in assisting many lumber mills in the permitting process that includes most of the information requested in the survey. CTI also has assisted facilities with ICR for other regulations in the past.
Upon receipt of the ICR, feel free to contact us for a proposal to assist you to prepare it. If you have any questions or need additional information, please contact us.
One environmental reporting requirement that is often overlooked, but enforced regularly by the Environmental Protection Agency (EPA), the Georgia Environmental Protection Division (GA EPD), and other state agencies is Tier II Reporting under the Superfund Amendments and Recovery Act (SARA).
If your facility stores any chemical or product on site that requires a Safety Data Sheet (SDS) (e.g. petroleum products, grains, paints, lead-acid batteries, liquid oxygen, etc.) in amounts over 10,000 pounds, your facility is required to notify the state, your local emergency planning committee, and the local fire department of these materials on an annual basis. Additionally, if you store any extremely hazardous substances (e.g. sulfuric acid) above its reportable quantity, usually 500 or 1,000 pounds, your facility is also required to report under the SARA Tier II requirements. The annual deadline to submit Tier II reports is March 1.
If you would like assistance determining whether or not your facility is required to report under the SARA Tier II requirements, or need assistance completing the reports, please give me a call at (770) 363-6330, x.113 or email me at email@example.com.
The US Environmental Protection Agency (EPA) has proposed to issue an Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP), also known as the “PCWP MACT” or “Kiln MACT”. This is an important update for those in the lumber industry, as lumber drying kilns are one of the sources regulated under the standard. While the PCWP NESHAP covers many types of process units, this discussion will be primarily focused on the standard’s effect on sawmills operating lumber drying kilns.
What is the history of the rule? Continue reading “EPA Proposes Collection of Information for “Kiln MACT””
The US Environmental Protection Agency (EPA) has issued a final rule to revise the Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program. The update contains over 60 revisions and will be effective May 30, 2017. One of the EPA’s objectives of the revisions is to reorganize the regulations to make them more user-friendly and easier to understand for generators. The revisions also include changes that address gaps in existing regulations, provide more flexibility for generators to mange hazardous waste, and make technical corrections.
Below is a list of some the program changes: Continue reading “EPA Issues Changes to RCRA Hazardous Waste Generator Rule”
EPA is working on the Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP). The comment period for preparing the ICR ended on November 7, 2016. This is the MACT standard commonly referred to as the Kiln MACT as it will apply to lumber drying kilns in some fashion, in addition to plywood and composite wood products. Continue reading “EPA Information Request for Kiln MACT Standard (40 CFR 63 Subpart DDDD)”
Most industrial facilities are required to maintain a Storm Water Pollution Prevention Plan (SWPPP) in order to minimize the discharge of pollutants from the property. The U.S. Environmental Protection Agency (US EPA) releases a Multi-Sector General Permit every five years that the majority of states model their permits after. These 6 steps are important for maintaining a compliant SWPPP in most states: