MassDEP Limits Mercury in Industial Wastewater Discharges

Massachusetts Department of Environmental Protection (MassDEP) restrictions on mercury discharges to municipal sewer systems go into effect on May 1, 2009. These rules, promulgated under the Massachusetts Mercury Management Act, limit the maximum concentration of mercury in sanitary sewer discharges from industrial users to less than 1 ug/L (1 ppb). By July 2007, all dischargers were to have determined possible sources of mercury in their discharges and have taken reasonable steps to eliminate them.

[What is 1 ug/L (parts per billion) mercury equivalent to?]

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Revised NESHAP for Petroluem Refineries

EPA recently released its final amendments to the National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (40 CFR 63, Subpart CC). EPA is required to review the developments in practices, processed, and control technologies every eight years and update national emissions standards to address the "residual risk" after implementation of the original standards.

The updated NESHAP includes new requirements for storage vessels. All Group 1 external floating roof (EFR) storage tanks will be required to install controls for guide poles and other openings, and additional inspection, recordkeeping, and reporting requirements.

Heat exchange systems will be required to conduct monthly sampling and analyses for VOC in the cooling water. The amendments to Refinery MACT will require the repair of leaks in heat exchangers within 45 days of the sampling event in which the leak is detected, unless a delay in repair is allowed.

All Group 1 storage vessels and heat exchange systems at existing refineries must be in compliance within 36 months after the Final Amendments are published in the Federal Register.

EPA opted not to promulgate changes to Refinery MACT that would include performance standards and monitoring requirements for enhanced biological units to treat wastewater streams.

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North Carolina CAFO General NPDES Permit Renewal

The North Carolina Department of Environment, Health, and Natural Resources – Division of Water Quality has revised its general NPDES discharge permits for confined animal feeding operations (CAFO). The current general permits for waste systems at swine, cattle and dairy and wet poultry operations will expire on Sept. 30, 2009. Operators of swine, cattle and poultry farms who come under the state general permits for wastewater systems need to apply for renewal under the new permit before April 1, 2009.

Animal feeding operations that have more than 250 swine, 100 confined cattle or dairy animals, 75 horses or a wet litter operation for more than 30,000 chickens are required to apply for a permit from the state.

General permits set requirements for waste management activities common to facilities of a particular type, and are issued as a class every five years. General permits for animal operations are issued along with certificates of coverage that address specific requirements for each facility.

The new general permits differ from the current permits in some operational, monitoring and reporting requirements. The most substantive change to the current permit is that application of waste must stop within 4 hours of a National Weather Service (NWS) issuing a warning of a hurricane, tropical storm or flood watch for the county in which the CAFO is located.

Looking for other water quality-related topics?, go to:
Water Quality Standards Aquatic Toxicology NPDES Permit Limits

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Proposed Reciprocating Internal Combustion Engine RICE Rules

Update:  January 2013 - EPA Released Final RICE NESHAP

On March 5, 2009, EPA published new proposed 40 CFR Part 63 rules for reciprocating internal combustion engines (RICE). The rules would affect:

• Engines at facilities classified as "Area Sources" with hazardous air pollutant (HAP) emissions less than 10/25 TPY.
• Engines with horsepower rating less than 500 at major source facilities and constructed/reconstructed before June 12. 2006.
• Engines with horsepower rating greater than 500 at major source facilities and constructed/reconstructed before December 12, 2002.

EPA expects that the new emissions limits would be met by installing "after-treatment" controls such as:

• Existing rich-burn engines would install non-selective catalytic reduction (NSCR).
• Existing diesel engines would install oxidation catalysts and/or catalyzed diesel particulate filters (CDFP).
• Non-emergency engines with greater than 300 horsepower would burn ultra-low sulfur fuel.

Caltha LLP provides specialized expertise to clients nationwide in the air emission permitting, regulatory compliance support, and preparing cost-effective regulatory compliance programs.
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Changes to 2009 Toxic Release Inventory Report Requirements

Toxics Release Inventory (TRI) reporting requirements were changed on March 11, 2009 as part of the Omnibus Appropriations Act of 2009. These changes affect TRI reports due July 1, 2009. The 2009 Omnibus Appropriations Act returned TRI reporting requirements back to the rules in effect prior to December 22, 2006.

The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals be submitted on "Form R,", which is the more detailed form. For all other chemicals the shorter form, “Form A” may be used only if the annual reporting amount is 500 pounds or less and that the chemical was manufactured, processed or otherwise used in an amount not exceeding 1 million pounds during the reporting year. EPA will issue a rule shortly revising the regulatory text in the Code of Federal Regulations to reflect these changes. TRI-ME software and other reporting assistance materials are also being revised.

As background, in December 2006 U.S. EPA revised the reporting requirements for releases of listed chemicals (commonly known as 313 chemicals) required under Section 313 of the Emergency Planning & Community Right-to-Know Act (EPCRA). The revisions made by EPA in 2006 related to the Forms used to report 313 chemical releases. Form R is typically used to report releases, and data submitted on Form R is released to the public. Form A is a streamlined reporting process, used for 313 chemicals released in smaller quantities. Data submitted on Form A is not released to the public. The revision made by U.S. EPA changed the thresholds for when Form A could be used. Form R could always be used to report data, even for small quantities.

The 2006 revision allowed some facilities to use a streamlined reporting process; chemicals reported using the streamlined process would not be included in facility TRI reports released to the public. In response, twelve States filed a law suit against U.S. EPA in November 2007. The suit claims that the revision prevented citizens and communities from having access to the critical information required under EPCRA.

The 2009 changes to TRI reporting only affects how TRI data are reported; it does not change the thresholds used to determine if a TRI report is required. This change only applies to TRI reporters with total releases less than 5,000 lbs/year. No revisions were made by U.S. EPA for reporting 313 chemicals that have releases greater than 5,000 lbs/year.


[Read more about recent changes to TRI reporting for auxiliary facilities]
[Read more about 2008 legislation in Minnesota that reversed 2006 EPA TRI changes for Minnesota TRI sites]

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Regulatory Updates - Environmental Management and Compliance

In addition to this ENVIRONMENTAL REGULATORY COMPLIANCE page, Caltha LLP maintains several websites to provide regulatory updates and discussion of current environmental, health and safety topics, as listed below. Interested parties can register to receive automatic notification when a new topic is posted.

SWPPP - Stormwater Pollution Prevention Plans - Stormwater Permits - Stormwater Training
Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits, Stormwater Pollution Prevention Plans, monitoring, training, spill prevention and control, SPCC compliance.

Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits
Discussion of a variety of topics related to State and Federal water quality standards, ambient water quality criteria, sediment criteria, NPDES & site-specific discharge standards, water quality management, aquatic toxicology, aquatic community impacts, and water quality assessment.

Environmental Sustainability - Sustainable Environmental Management Systems
Discussion of sustainability topics, including pollution prevention, waste reduction, material reuse, environmental management systems, product stewardship, and international environmental standards.

Environmental Due Diligence - Site Assessments - Phase I ESA - Environmental Liability
Discussions and comments regarding environmental due diligence, environmental liabilities, CERCLA liabilities, Phase I environmental site assessments, corporate liabilities, environmental compliance liabilities, quantitative environmental liability assessment.

Regulatory Briefings
Regulatory Briefings are published periodically by Caltha to highlight new or proposed regulations on a wide range of environmental, health & safety topics. These briefings are generally 2- to 4-pages in length and provide an overview of the regulations and discuss potential impacts on the regulated community. Participants must sign up to receive an email link to new Regulatory Briefings as they are posted.

Caltha LLP provides specialized expertise to clients nationwide in the environmental permitting & compliance, environmental management systems, and preparing cost-effective EHS compliance programs.

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South Coast AQMD Rules for Thinners and Solvents

The South Coast Air Quality Management District (SCAQMD) has recently adopted rules that restrict the VOC content of a wide range of paint thinners and solvents commonly used as consumer products and in commercial and industrial settings. The purpose of the rule (Rule 1143) is to reduce emissions of volatile organic compounds (VOCs) from the use, storage and disposal of consumer paint thinners and multi-purpose solvents commonly used in thinning of coating materials, cleaning of coating application equipment, and other solvent cleaning operations.

The rule applies to anyone who supplies, sells, offers for sale, or manufactures consumer paint thinners and multi-purpose solvents for sale in the SCAQMD, as well as anyone who uses or solicits the use of any consumer paint thinner and multi-purpose solvent within the SCAQMD.

The rule, adopted March 6, 2009, restricts the VOC content of consumer paint thinners and multi-purpose solvent to:

2.5 Lbs VOC/gal (effective 1/1/2010)
0.21 Lbs VOC/gal (effective 1/1/2011)

Some exemptions are included for certain materials and uses.

Caltha LLP provides specialized expertise to clients nationwide in the environmental permitting, developing pollution prevention procedures, and preparing cost-effective environmental compliance programs.

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