Thursday, May 30, 2013

Environmental Product Declarations For Adhesives and Sealants

ASTM International has announced that it will be collaborating with industry to develop Environmental Product Declarations (EPDs) across the over 90 industry markets, including sealants. The Adhesive and Sealant Council (ASC) will be partnering with ASTM International to raise awareness and educate industry on the value of Type III EPDs, and proactively engage industry in developing Product Category Rules (PCR).

In 2012, ASTM International announced that it was becoming a global Program Operator for PCR development and EPD verification. In January 2013, the members of ASTM Committee C24 on Building Seals and Sealants agreed to become active in the PCR process and to move forward with scoping the PCR development for sealants. ASTM Committee C24 will meet in Indianapolis in June 2013.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
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Thursday, May 23, 2013

New Source Performance Standards Proposed For Kraft Pulp Mills

The EPA is proposing revisions to the new source performance standards (NSPS) for kraft pulp mills. These revised standards include particulate matter emission limits for recovery furnaces, smelt dissolving tanks and lime kilns, which apply to emission units commencing construction, reconstruction or modification after May 23, 2013 that are different than those required under the existing standards for kraft pulp mills. The exemptions to opacity standards do not apply to the proposed standards for kraft pulp mills. The proposed rule also removes the exemption for periods of startup and shutdown (SSM) resulting in a standard that applies at all times. The proposed rule includes additional testing requirements and updated monitoring, recordkeeping and reporting requirements for affected sources. Comments on the proposed rules must be received on or before July 8, 2013.

To address the NSPS review, SSM exemptions and other changes, the EPA is proposing new standards, which will apply to affected sources at kraft pulp mills for which construction, modification or reconstruction commences on or after May 23, 2013. The affected sources under the proposed NSPS are new, modified or reconstructed digester systems, brown stock washer systems, evaporator systems, condensate stripper systems, recovery furnaces, SDTs, and lime kilns at kraft pulp mills. The requirements for these new, modified or reconstructed sources will be included in a new subpart-40 CFR part 60, subpart BBa. The EPA is also proposing testing, monitoring, recordkeeping and reporting requirements for subpart BBa that are in some ways different from what is required under subpart BB.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
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Wednesday, May 22, 2013

Wisconsin Prevention of Significant Deterioration For GHG Emissions Approved

In a final rule, US EPA has approved revisions to the Wisconsin State Implementation Plan (SIP), submitted by the Wisconsin Department of Natural Resources (WDNR) in 2011 and 2012. The revisions modify Wisconsin's Prevention of Significant Deterioration (PSD) program to establish emission thresholds for determining which new stationary sources and modification projects become subject to Wisconsin's PSD permitting requirements for their greenhouse gas (GHG) emissions. Additionally, these revisions defer until July 21, 2014, the application of the PSD permitting requirements to biogenic carbon dioxide (CO2) emissions from bioenergy and other biogenic stationary sources in the State of Wisconsin. EPA has made the preliminary determination that these revisions are in accordance with the Clean Air Act (CAA) and EPA regulations regarding PSD permitting for GHGs and is approving Wisconsin's revisions.

Caltha LLP provides specialized expertise to clients in Wisconsin and  nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
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Monday, May 13, 2013

Lead Renovation, Repair, and Painting Program Application To Public and Commercial Buildings

US EPA has announced that it will conduct a public meeting on June 26, 2013 to gather public comment regarding extending its Lead Renovation, Repair, and Painting Program to public and commercial buildings. In 2010, EPA issued an advance notice of proposed rulemaking (ANPRM) concerning renovation, repair, and painting activities in public and commercial buildings.

EPA is in the process of determining whether these activities create lead-based paint hazards, and, for those that do, developing certification, training, and work practice requirements as directed by the Toxic Substances Control Act (TSCA). EPA has also reopened the comment period for the December 31, 2012 Federal Register document to allow for additional data and other information to be submitted by the public and interested stakeholders. EPA specifically requested information on the following:

1. The manufacture, sale, and uses of lead-based paint after 1978.
2. The use of lead-based paint on public and commercial buildings.
3. The frequency and extent of renovations of public and commercial buildings.
4. Work practices used to renovate public and commercial buildings.
5. Dust generation and transportation from exterior and interior renovations of public and commercial buildings.

Click here for further background on the application of the LBP Rule to public and commercial buildings




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Thursday, May 2, 2013

EPA Approval of Changes To Georgia RCRA Rules

The Environmental Protection Agency (EPA) has proposed final authorization of State Hazardous Waste Management Program Revisions submitted by the Geogia Environmental Protection Division. Georgia applied to EPA for final authorization of changes to its hazardous waste program under the Resource Conservation and Recovery Act (RCRA). EPA determined that these changes satisfy all requirements needed to qualify for final authorization. Unless EPA receives written comments that oppose this authorization during the comment period, the decision to authorize Georgia's changes to its hazardous waste program will take effect on July 1, 2013.

EPA has determined there are no State requirements in this program revision considered to be more stringent or broader in scope than the Federal requirements. While Georgia has adopted the necessary regulations to receive authorization for the Uniform Hazardous Waste Manifest Rule, EPA cannot delegate the Federal manifest registry functions or the export or import provisions. and will continue to implement these requirements. Similarly, EPA cannot delegate the Federal requirements at 40 CFR 261.39(a)(5), 261.40 and 261.41 contained in the Cathode Ray Tubes Rule. While Georgia has properly adopted these requirements by reference at Georgia Hazardous Waste Management Rule 391-3-11-.07(1), EPA will continue to implement these requirements.

Georgia will issue permits for all the provisions for which it is authorized and will administer the permits it issues. EPA will continue to administer any RCRA hazardous waste permits or portions of permits which EPA issued prior to the effective date of the authorization until they expire or are terminated. EPA will not issue any more permits or new portions of permits for the provisions listed in the authorization after the effective date. EPA will continue to implement and issue permits for HSWA requirements for which Georgia is not authorized.

Caltha LLP provides specialized expertise to clients in Georgia and nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
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