New Washington Interim Policy On Handling Pharmaceutical Wastes Classified As Dangerous Waste

Washington Department of Ecology has developed an interim policy for generators of pharmaceutical wastes which could be classified as “dangerous waste” under State rules. The State has enacted this policy pending US EPA finalizing federal rules to streamline handling and disposal of these wastes. Once the EPA rule is finalized, Ecology expects to adopt the federal rule.

What are the generator requirements under the interim Ecology policy?

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

EPA Proposes Review of SIPs For SSM Requirements

The EPA is proposing to take action on a petition for rulemaking filed by the Sierra Club in 2011 concerning the treatment of excess emissions in state rules by sources during periods of startup, shutdown, or malfunction (SSM). EPA is proposing to grant in part and to deny in part the request to rescind its policy interpreting the Clean Air Act (CAA) to allow states to have appropriately drawn state implementation plan (SIP) provisions that provide affirmative defenses to monetary penalties for violations during periods of SSM. The EPA is also proposing either to grant or to deny the Petition regarding existing SIP provisions related to SSM in each of 39 states identified in the petition.

For each of those states where EPA proposes to grant the petition concerning specific provisions, EPA also is proposing to find that the existing SIP provision is substantially inadequate to meet CAA requirements and proposes a "SIP call." For those affected states EPA will require the states to submit a corrective SIP revision. Comments on the proposed actions must be received on or before March 25, 2013.

Through this rulemaking, EPA intends to clarify its interpretation of the CAA regarding excess emissions during SSM events. EPA may find specific SIP provisions to be substantially inadequate to meet CAA requirements; if a state's existing SIP provision allows an automatic exemption for excess emissions during periods of startup, shutdown, or malfunction, then the EPA may determine that the SIP provision is substantially inadequate because the provision is inconsistent with requirements of the CAA.
The affected States include:

Alabama
Alaska
Arizona
Arkansas
Colorado
Delaware
District of Columbia
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
New Hampshire
New Jersey
New Mexico
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Rhode Island
South Carolina
South Dakota
Tennessee
Virginia
Washington
West Virginia
Wyoming

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Schedule For Action On State Regional Haze Plans

The U.S. Environmental Protection Agency (EPA) has announced a court ordered schedule to review and act on more than 40 state regional haze reduction plans, designed to improve visibility in national parks and wilderness areas. The EPA action by itself does not establish control requirements; EPA will work with the states to approve their plans by the court ordered deadline in the agreement. Under the terms of the consent decree, if a state plan cannot be approved, EPA will determine an appropriate federal plan.

The dates for promulgation of final rules (either accepting or rejecting State plans) begin December 13, 2011 and run through November 15, 2011. States are grouped within this timeframe.

EPA initially issued a rule in 1999 requiring states to submit regional haze plans. These plans were due in December 2007, but no action was taken by the agency in response to the submittals. National Parks Conservation Association and other environmental groups sued the agency in August 2011 to take action on these plans, and the consent decree resolves this litigation. EPA will accept public comment on this agreement for 30 days following publication of a notice 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

Washington Proposed GHG Reporting Requirements

Washington has by statute adopted a Climate Change Framework that sets greenhouse gas(GHG) reduction targets over the next several decades. Ecology has been directed to develop and implement a reporting system to establish a baseline inventory of GHGs emitted in the state. Ecology began developing a GHG reporting rule before EPA’s reporting rules were available, and after the federal rules were released, the Washington legislature revised the state GHG reporting statute to be more in line with EPA’s reporting requirements. Ecology then worked to develop GHG reporting rules that would implement the revised state GHG reporting statute.

Ecology’s proposed rule requires the following sources to report emissions of certain GHGs:

• A single facility, source, or site that directly emits at least 10,000 metric tons of carbon dioxide equivalent gases (CO2e) annually in Washington; and
• Suppliers of liquid motor vehicle fuel, special fuel, or aircraft fuel that supplies products equal to at least 10,000 metric tons of CO2e annually in the state.

Ecology’s rule would also require reporting of emissions from biomass combustion sources. Facilities will not need to consider or report indirect emissions once they reach the threshold for direct emissions, which is a change from the draft rule released late last year. The proposed rule also does not require mobile sources such as cars, trucks, ships, trains, and planes to report because those emissions will be covered by fuel supplier reporting.

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

Washington WEEE Recycling Law - E-Cycle Washington

Beginning January 1, 2009, the E-Cycle Washington program kicks-off and provides no cost recycling of many waste electronic and electrical equipment (WEEE). The program is available to households, small businesses, schools & school districts, small governments, special purpose districts, and nonprofits & charities who can recycle electronic products free of charge.

E-Cycle Washington is one outcome of the Washington Electronic Product Recycling Law and Department of Ecology rules passed in 2007. These rules include:

• Manufacturer requirements
• Transporter requirements
• Recycler requirements
• Retailer requirements
• Reporting requirements
• Education and outreach

Caltha LLP assists manufacturers in meeting their internal product stewardship goals and regulatory requirements.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website