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.
Environmental rules and regulations include deadlines for submission of reports, plans, fees, training, inspections, and analytical testing. Some of these tasks need to be submitted to the U.S. EPA, some to the State Regulatory Agency, and some to both. Some tasks are only required to be kept on file. We hope that this list of deadlines will assist your facility in maintaining compliance.
Continue reading “Environmental Deadline List”
On September 9, 2019, the US Environmental Protection Agency (EPA) released an Air Plan Approval that will grant approval of proposed changes to Georgia’s Nonattainment New Source Review (NNSR) permitting rules, proposed in Georgia’s July 2, 2018 SIP revision. The proposed changes have already been implemented by the Georgia Environmental Protection Division (GA EPD), and this Air Plan Approval is the EPA saying that it is okay for the GA EPD to continue implementation and begin enforcement. Continue reading “EPA Nonattainment New Source Review Updates – Georgia”
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.
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 firstname.lastname@example.org.
Superfund Amendment and Re-authorization Act (SARA) Title III reports and notifications are required to be prepared and submitted by applicable facilities every year.
A facility that stores over 10,000 pounds of any chemical (e.g. over 1,387 gallons of diesel fuel), or over 500 pounds of an Extremely Hazardous Substance (e.g. sulfuric acid in electric forklift lead-acid batteries), must prepare a SARA Tier II Report and submit it to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and Local Fire Department by March 1st each year.Continue reading “Superfund Amendment and Re-Authorization Act (SARA) Deadlines”
Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the Environmental Protection Agency (EPA) or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random and infrequent.Continue reading “Staying in Compliance with Air Quality Regulations”
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”