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.
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”
The Georgia Environmental Protection Division (GAEPD) have issued a draft of the “Air Permit Application & Annual Permit Fees” manual and associated proposed rules update. The fees manual is released annually detailing application fees, annual permit fees, and procedures for calculating the fees and emissions for facilities. With this change, the annual air permit fees will increase effective July 1, 2020 and will apply to the fees due on September 1, 2020. Additionally, the fees for air permit applications will increase effective March 1, 2021. This proposed change is still open for comment. The GAEPD held an online public meeting on Monday, March 30, 2020 at 2:00 pm. There were no comments received during the meeting. Written comments can still be submitted, but must be received by 4:30 PM on Monday, April 6, 2020. The proposed updates will then be voted on at the Board of Natural Resources meeting on May 19, 2020.
Continue reading “Georgia EPD Increases Air Permit Fees”
The Georgia Environmental Protection Division (GAEPD) has issued a draft “Air Permit Application & Annual Permit Fees” manual. Under this manual, the annual permit fees will be increasing, effective for fee payments this year. The fees for NSPS and Synthetic Minor Sources will be increasing by $500 and Title V Sources will now have an additional annual maintenance fee of $800. The GAEPD is also proposing to double the Air Permit Application fees, beginning March 1, 2021.
The GAEPD is hosting an online public hearing on these proposed amendments on Monday, March 30, 2020 at 2:00 pm. We at CTI will be participating in the public hearing and will post updates accordingly.
Check back with our blog for updates.
If your facility is a Large Quantity Generator (LQG), meaning it generated more than 2,200 lbs of hazardous waste and/or 2.2 lbs of acute hazardous waste per month during 2019, the upcoming deadline applies to you.
LQG are required to complete a Hazardous Waste Report (also called the Biennial Report) and a Hazardous Waste Reduction Plan for waste generated in 2019 by March 2, 2020.
Conversion Technology Inc. (CTI) is an environmental, health, and safety consulting firm with over 30 years experience covering the above reports and other aspects of permitting, and environmental, health, and safety regulatory compliance. If you need help preparing the waste reports, please contacts us at 770-263-6330 or firstname.lastname@example.org.
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”
Several National Fire Protection Association (NFPA) standards for combustible dust were updated in 2019, including standards applicable to food, agricultural, wood product, plastic, pharmaceutical, and many other industries. The 2020 Editions of NFPA 61, 654, and 664 were all issued in the past few months. (Much like a new car model, the new NFPA editions are typically released in the year before the date of the edition.) Below are some of the major changes to these standards. If you have specific questions about how these changes may affect your facility, CTI’s combustible dust experts are available to talk. Continue reading “Updates to the 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”
Come say hello to Adam Haroz, one of CTI’s Engineering Managers, as he will be speaking at this year’s Region IV VPPPA Conference in Chattanooga, TN on June 19th.
Adam Haroz will be discussing how the regulations governing industrial machinery have shifted the need for conducting risk assessments on robotic systems from a good practice to now a mandatory requirement. The discussion will emphasize the benefits of conducting an on-site risk assessment. It will also highlight the need to identify the hazards and assess the potential risks associated with robot operations when selecting and designing safeguarding measures. He will review the methodology for conducting a risk assessment for different robotic systems, as well as other industrial equipment, how to assess the adequacy of current safeguards, and methods for determining the risk reduction measures required.
The Voluntary Protection Program (VPP) is designed to encourage cooperative efforts between employees, management and OSHA for the purpose of improving workplace safety and health. The VPP concept recognizes that workplace safety and health can be enforced in a compliance atmosphere and can be enhanced in a cooperative atmosphere. OSHA recognizes and partners with worksites that demonstrate excellence in Safety and Health.
Region IV VPPPA is the region that serves the eight Southeast states. (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee)
For more information on the VPPA or to register for the Region IV VPPA Conference click the following link: http://www.regionivvppconference.com/