EPA Proposes No Revision To Current Greenhouse Gas PSD Program

U.S. Environmental Protection Agency (EPA) is proposing not to change the greenhouse gas (GHG) permitting thresholds for the Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs, and also proposing steps the agency believes would streamline the permitting process for large sources. EPA has proposed not to include additional, smaller sources in the permitting program at this time. EPA will be accepting comments on the proposal for 45 days after it is published in the Federal Register.

The GHG Tailoring Rule would continue to address a group of six greenhouse gases: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Under the approach maintained in the current proposal, new facilities with GHG emissions of at least 100,000 tons per year (tpy) carbon dioxide equivalent (CO2e) continue to be required to obtain PSD permits. Existing facilities that emit 100,000 tpy of CO2e and make changes increasing the GHG emissions by at least 75,000 tpy CO2e, must also obtain PSD permits. Facilities that must obtain a PSD permit, to include other regulated pollutants, must also address GHG emission increases of 75,000 tpy or more of CO2e. New and existing sources with GHG emissions above 100,000 tpy CO2e must also obtain operating permits.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Final Rule On Polyvinyl Chloride & Copolymers (PVC) Air Emissions

U.S. Environmental Protection Agency (EPA) has issued final standards requiring facilities that produce polyvinyl chloride and copolymers (PVC) to reduce air emissions. The final standards are based on currently available technologies and will reduce emissions of air toxics, such as dioxin and vinyl chloride. Facilities will have the flexibility to choose the most practical and cost-effective control technology or technique to reduce the emissions. Facilities will be required to monitor emissions at certain points in the PVC production process to ensure that the standards are met.

Currently, there are 17 PVC production facilities throughout the United States, with a majority of these facilities located in Louisiana and Texas. All existing and any new PVC production facilities are covered by the final rule. PVC production facilities manufacture PVC resins that are used to make a large number of commercial and industrial products at other manufacturing facilities. These products include latex paints, coatings, adhesives, clear plastics, rigid plastics, and flooring.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

What If I Missed My 2006 TSCA Inventory Update Report?

Between February 1 and June 30, chemical manufacturers and companies that import chemicals will be evaluating their production and/or import quantities and if needed will be submitting their inventory data to US EPA under the new Chemical Data Reporting (CDR)Rule.

Click here for an overview of the new Chemical Data Reporting (CDR)Rule.

Although new for 2012, the CDR is a revising to reporting rules that have existed for a number of years under the name "Inventory Update Reporting" or IUR. IUR reporting was required every 4-5 years, with the last reporting year being 2006.

As companies begin to assemble data for the 2012 CDR report, some discover that they may have been subject to earlier reporting and may have failed to submit the required reports.

Under the new CDR, companies who missed their reporting requirements in 2006 have an opportunity to use the new CDR tools to assemble a report for 2006 and submit it as a paper copy. However, in order to comply with the Agency's self-disclosure policy, once a violation has been discovered, a company has 21 days from the time of that discovery to disclose the violation in writing to EPA.

Caltha LLP provides specialized expertise to clients nationwide in the preparation and submital of TSCA reports, including new CDR reporting, preparing submitals under EPA self-disclosure policy, and preparing cost-effective chemical tracking and management programs.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

2012 Regulatory Overview Workshop - EH&S Compliance Training

The 2012 Certified Hazardous Materials Manager (CHMM) Regulatory Overview Workshop has been scheduled for May 1-3, 2012 in Bloomington, MN. The course is sponsored by the North Star Chapter of the AHMP.

The workshop is open to all EH&S professionals who wish to update and expand their knowledge of regulations, regulatory programs relating to environmental, health and safety compliance and the management of hazardous materials, even if they do not intend to become a CHMM.

For more information go to:
http://www.ahmp-nsc.org/2011-chmm-overview-workshops.html

Course Content
Course Introduction
• Course purpose and structure
• Resources: access to information

Federal Statutes Overview
• A brief history
• Perspective
• Fit the pieces together

Liability and Compliance
• Laws & jurisdictions
• Types of torts
• Negligence

Clean Water Act
• Goals & objectives
• Wastewater standards & enforcement
• Oil spill control
• Storm water management

Clean Air Act
• New source review standards
• National emission standards for hazardous air pollutants
• Non-attainment areas
• Risk Management Plans (RMP)

Toxic Substances Control Act (TSCA)
• Pre-Manufacturing Notice (PMN)
• Significant New Use Rule
• Cradle to grave responsibility

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
• Reportable quantities
• Notifications
• National Contingency Plan
• Superfund Amendments and Reauthorization Act
• Who is responsible and who pays
• De-listing

Community Right-to-Know (SARA Title III - EPCRA)
• Community Emergency Planning
• Threshold quantities, EHS
• Toxic Release Inventory reports

Chemistry of Hazardous Materials
• Importance of basic knowledge
• Physical and chemical properties
• Nomenclature & properties of organic compounds

Toxicology
• Dose response
• Measures of effects
• Exposure assumptions

Geology
• Geology basics
• Hydrogeology
• Groundwater contaminant flow
• Monitoring wells

Radiation Principles for Hazardous Materials Managers
• Alpha, Beta & Gamma Radiation
• Units of measure
• Transportation
• Means of protection

Asbestos
• Types of Asbestos
• Health effects
• Regulatory requirements

Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
• Types of products included
• Applicator certification
• Worker protection rules

Hazardous Materials Transportation
• DOT regulations
• Hazardous materials versus hazardous waste
• Hazard classifications
• Container requirements

OSHA
• General Safety
• HAZWOPER
• Hazard communication
• Process safety

Accident Scenario
• Sample incident
• Incident Command System
• Roles of responders
• Proper preparation

Environmental Management Systems
• History of EMS
• ISO-14001 Standard
• Application to OSHA & HazMat

Environmental Considerations in Real Estate/ Due Diligence Assessments
• Phase I assessments
• Phase II investigations
• Voluntary cleanup letters of assurance

Underground Storage Tanks
• Leak prevention
• Detection of leaks
• Response
• Petroleum and hazardous substances vs. hazardous waste

Resource Conservation & Recovery Act (RCRA)
• Regulated hazardous waste
• Generators & transporters
• Permitted treatment, storage & disposal facilities

Waste Analysis
• Waste stream identification
• Sampling methods
• The TCLP analysis
• Waste analysis plans for TSDs

Hazardous Waste Treatment Technologies
• Physical methods, chemical methods & biological methods
• Evaluation and selection

Waste Reduction/Minimization and Pollution Prevention
• Regulations that apply
• Definitions
• Best Practices

Compliance Audits
• Auditing processes
• Auditor qualifications
• Liability management
• Best practices

Motivation of Employees with Respect to Environmental Matters
• Defining motivation & Incentives
• Practical tools & methods

CHMM Code of Ethics
• What it covers
• How it applies to you

Update On 2010/15 PFOA Stewardship Program

U.S. Environmental Protection Agency (EPA) has released the interim results of a voluntary effort by eight chemical manufacturers to reduce emissions and use of long-chain perfluorinated chemicals (LCPFCs), including perfluorooctanoic acid (PFOA).

EPA’s 2010/15 PFOA Stewardship Program was established in 2006 in partnership with DuPont, Solvay Solexis, Asahi Glass Company, Daikin America, Inc., Clariant International Ltd., 3M/Dyneon, Arkema Inc. and BASF (formerly Ciba Specialty Chemicals Corporation). The program set a goal of reducing facility emissions and product content of PFOA and related chemicals on a global basis by 95 % by 2010, and to work toward eliminating emissions and product content of these chemicals by 2015.

Daikin, DuPont, 3M/Dyneon and Solvay Solexis have met the program’s intermediate goal of a 95 % reduction in global emissions and product content by 2010. EPA reports that the companies continue to reduce emissions of LCPFC’s as well as overall product content of LCPFC’s. Additionally, more than 150 replacement chemicals have been developed. The eight participating companies have informed EPA that they are on track to phase out LCPFCs by the end of 2015.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

State Implementation Plan Requirements Under Ozone NAAQS

US EPA has released a pre-proposal notice for several elements of implementation of the 2008 NAAQS for ozone.

This proposal will address requirements for State Implementation Plan Requirements (SIP) elements, including attainment demonstration, reasonable further progress, reasonably available control technology, reasonably available control measures, nonattainment new source review, emission inventory, and others, and timing for SIP submissions, compliance periods and other topics.

EPA anticipates publishing the Notice of Proposed Rule Making (NPRM) in the Federal Register in April 2012.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Rules On 2008 Ozone National Ambient Air Quality Standards

US EPA has released a pre-proposal notice for several elements of implementation of the 2008 NAAQS for ozone. This NPRM will propose rules for implementing the 2008 8-hour Ozone National Ambient Air Quality Standards (NAAQS). The proposed rules will address the classification system, the attainment deadlines for areas designated nonattainment, the methodology to address areas receiving voluntary reclassifications for the 1997 ozone NAAQS, and revocation of the 1997 ozone NAAQS for transportation conformity purposes.

The proposed rules were submitted to the Office of Management & Budget (OMB) in December 2011, and were received back in January 2012. EPA anticipates publishing the Notice of Propose Rule Making (NPRM) in the Federal Register in February 2012.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Electric Generating Units GHG NSPS For Existing Sources

US EPA has issued a pre-proposal notification for the development of a greenhouse gas new source performance standard (NSPS) for electric generating units. These emission guidelines will apply to existing sources. This action will amend the electric generating units (EGUs) New Source Performance Standard and add a section 111(d) greenhouse gas (GHG) standard for existing sources.

EPA did not indicate a schedule for publishing the Notice of Propose Rule Making (NPRM) in the Federal Register.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Formaldehyde Standards Under Composite Wood Products Act

The Formaldehyde Standards for Composite Wood Products Act was enacted in July 2010. This law amended the Toxic Substances Control Act (TSCA) to establish specific formaldehyde emission limits for hardwood plywood, particleboard, and medium-density fiberboard. By law, the limits are identical to the California emission limits for these products. The law further requires EPA to promulgate implementing regulations by January 1, 2013.

US EPA has issued an Advanced Notification of Proposed Rulemaking to implement these formaldehyde emission limits. This rulemaking will address the mandate to promulgate regulations to implement the statutory formaldehyde emission standards for hardwood plywood, medium-density fiberboard, and particleboard sold, supplied, offered for sale, or manufactured (including imported) in the United States. As directed by the statute, EPA will also consider provisions relating to, among other things, laminated products, products made with no-added formaldehyde resins, testing requirements, product labeling, chain of custody documentation and other recordkeeping requirements, and product inventory sell-through provisions.

A separate Regulatory Agenda entry (RIN 2070-AJ44) covers the mandate for EPA to promulgate regulations to address requirements for accrediting bodies and third-party certifiers. EPA anticipates publishing the Notice of Proposed Rule Making (NPRM) in the Federal Register in April 2012.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website