Final Air Toxics Rule For Chromium Electroplating Facilities

The final air toxics rule for chromium electroplating facilities, issued Aug. 15 by US EPA, rejected industry and environmentalists' requests to revise key provisions. The final rule closely follows the proposed version. The final rule concludes that a technology review of the chromium electroplating and steel pickling industry determined that new techniques are available to further lower air toxics from facilities at a "reasonable cost".

EPA also studied remaining health risks from the sector, and consequently tightened emissions limits for hexavalent chromium (Cr+6) emissions, to reduce cancer risks from covered facilities. The rule fulfills EPA's mandate under the Clean Air Act to conduct a residual risk review of air toxics controls for the sector. The Clean Air Act requires the performance of the review eight years following implementation of a national emissions standards for hazardous air pollutants (NESHAP) to determine remaining health risks from a sector's emissions. EPA must amend the existing NESHAP if a review finds justification for tighter controls.

EPA estimates that the revised NESHAP will cut hexavalent chromium emissions by 224 pounds annually. It also says many facilities are already reaching the revised hexavalent chromium limit, or emitting under the limit. The final rule finalized the agency's plan for a three-year phase out of the use of perfluorooctane sulfonate (PFOS) as a method for reducing hexavalent chromium emissions from hard chromium electroplating, decorative chromium electroplating, and chromium anodizing tanks.

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Public Meeting On Proposed National Primary Drinking Water Regulation for Perchlorate

EPA will hold a public meeting and a webcast to share information with the public related to treatment technologies, analytical methods, and other information on the development of a proposed National Primary Drinking Water Regulation for Perchlorate. Perchlorate is a naturally occurring and man-made chemical that is used to produce rocket fuel, fireworks, flares, and explosives. It is sometimes used to produce bleach and certain fertilizers. Scientific research suggests perchlorate can have adverse health effects, including disrupting the thyroid's ability to produce hormones needed for normal growth and development.

EPA says it anticipates publishing its proposed rule for regulating perchlorate for public review and comment in 2013.

The public meeting and webcast will take place on September 20, 2012, from 10 am to 4 pm (EST), in Arlington, Virginia. Anyone wishing to participate in the in-person meeting must register in advance no later than 5 pm EST on September 17, 2012. Seating is limited and will be available on a first-come, first-served basis for those persons registered. Webcast participants must register in advance; EPA says the number of connections available of the webcast is also limited and will be available on a first-come, first-served basis.

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State Pipeline Damage Prevention Program Grants

The Pipeline and Hazardous Materials Safety Administration (PHMSA) announced over $1.5 million in grants to 22 states to strengthen and support pipeline damage prevention programs. States will use the damage prevention grants to continue implementation of the nine elements of an effective damage prevention program, outlined in the Pipeline Inspection, Protection, Enforcement and Safety Act of 2006. Program elements include effective communications, partnerships, fair and consistent enforcement, training and technology.

Excavation damage is the number one cause of pipeline accidents resulting in fatality or injury. Since 2002, excavation damage resulted in over $190 million in property damage nationwide. Between 2002 and 2011, more than 28 % of all serious pipeline accidents were caused by excavation damage, resulting in 38 fatalities and 148 injuries.

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 

 

New Federal Carbon Footprint Tool Released-Building GHG Reduction Planning Module Planned

On August 27, The U.S. General Services Administration (GSA) announced a new version of its GSA Carbon Footprint Tool. GSA offers tool to all federal agencies to assist them in compiling their annual comprehensive greenhouse gas (GHG) inventory and tracking their progress toward achieving their GHG reduction goals. The agency says there is no charge to use this tool.

The new upgrades include advanced analytics features to help users verify data, identify underperforming, and take corrective action. GSA says the redesign was based on extensive internal user experience audits, focus groups, and input from over 30 federal agencies. GSA believes the redesigned tool is easier to navigate, enables users to find and share key information faster, and offers better support for mobile devices. The redesign focuses on helping agencies save time and money associated with implementing GHG reductions under Executive Order 13514.

Highlights of the GSA Carbon Footprint Tool's redesign include:

• Aligning site navigation with the GHG inventory and reduction process. The Tool is now organized by key tasks—from initial agency site setup to data collection, second-party data verification, DOE FEMP Reporting Portal reporting, GHG reduction planning, and goal tracking.
• Enabling agencies to seamlessly import building energy data from EPA ENERGY STAR Portfolio Manager and GSA building and travel data systems. Data can also be downloaded for export to the DOE FEMP Reporting Portal with a single mouse click.
• Embedding a quality assurance review process that allows agencies to submit their GHG emissions data to agency administrators for second-party review and verification.
• Allowing agencies to share site and GHG emissions data on the GIS map fosters interagency collaboration for climate adaptation planning; and creating a benchmarking capability lets agencies compare their building energy and GHG emissions performance against other buildings within the portfolio and against industry averages.

GSA plans to release a Building GHG Reduction Planning module by the end of the year that will allow agencies to review the potential cost, payback period, return on investment, and GHG emissions reductions associated with building energy conservation measures. This feature will incorporate money-saving strategies in the initial planning processes so that agencies can focus their efforts on the implementation phases.


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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What Kinds Of Oil Are Regulated Under SPCC Rule?

What types of oil are regulated by the SPCC Rules (40 CFR 112)?

Caltha receives this question often as facility operators or owners are determining if the SPCC Rule applies to their site. The SPCC Rules define “oil” broadly, and also differentiate between “oil” and “non-petroleum oil”. Petroleum oils, fuels, etc are regulated, as are synthetic oils, and oily wastes. In general, materials that can create a surface sheen or an emulsion in water are likely regulated as oil under the SPCC rules.

40 CFR 122.2:
"Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil."

"Non-petroleum oil means oil of any kind that is not petroleum-based, including but not limited to: Fats, oils, and greases of animal, fish, or marine mammal origin; and vegetable oils, including oils from seeds, nuts, fruits, and kernels."

On April 18, 2011, EPA published a final rule amending the SPCC regulations to exempt milk and milk product containers, associated piping and appurtenances. EPA believes that certain specific construction and sanitation standards and requirements address the prevention of oil discharges in quantities that may be harmful. The capacity of the exempt milk and milk product containers, piping and appurtenances does need not be included in a facility's total oil storage capacity calculation to determine if the facility is subject to SPCC.

SPCC Rules apply to oil-filled operational equipment. Oil-filled operational equipment means equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Oil-filled operational equipment is not considered a bulk storage container, and does not include oil-filled manufacturing equipment (flow-through process). Examples of oil-filled operational equipment include hydraulic systems, lubricating systems, gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, and other systems containing oil solely to enable the operation of the device.

FAQ: Does an SPCC Plan Expire? How often must I update my SPCC Plan?


Caltha LLP provides specialized expertise to clients nationwide in the preparing PE certified and self-certified SPCC Plans, developing emergency preparedness procedures, and preparing cost-effective EHS management programs.
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Johnson & Johnson To Phase Out Certain Chemicals From Products

Johnson and Johnson has announced that it plans to remove all potential carcinogens and dangerous chemicals from its line of toiletries and cosmetics for adults by 2015. Among the chemicals that will be removed from the products, which include adult skin care brands such as Aveeno and Neutrogena, over the next 3-4 years are 1,4 dioxane, formaldehyde, triclosan, phthalates, parabens, and fragrance ingredients. However, products will be allowed to contain chemicals that release formaldehyde in the event that there is no safe alternative. J and J's decision to remove the chemicals from its products comes after the Campaign for Safe Cosmetics began pressuring the company to do so in order to protect consumers and its own employees.

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 

Ohio Revises Rules For Underground Storage Tanks

Ohio has changed its underground storage tank regulations to align with federal rules.Under Ohio Rule OAC 1301-7-9-06, all new UST Systems must have secondary containment. Previously, only UST Systems in sensitive areas had to secondary containment. Further, when the cumulative replacement of an existing UST system exceeds 50%, then the entire system must have secondary containment. When new dispensers are installed or when existing dispensers are repaired and did not have containment pans under the dispenser, containment must be then installed under the dispenser.

Under Rule OAC 1301-7-9-19, by August 8, 2012, Owners and operators had to designate, train and document the training of Class A, B and C operators. This training was for operators of UST systems and is in addition to the licensure requirements for UST installers. Licensed UST installers automatically qualify as Class A operators.

Class A Operators have the primary responsibility for achieving and maintaining compliance with statutory and regulatory requirements and standards necessary to operate and maintain the UST system at one or more UST Sites. Class B Operators have the primary responsibility for implementing applicable requirements and standards for UST systems at one or more UST sites. Class A and B Operators have to undergo training from a state Fire Marshal approved trainer using formats approved by the state.

Class C operators (often being at least one attendant at the facility during working hours) are responsible for the initial response to alarms and other indications of emergencies caused by spills or releases from a UST system and for notifying the Class A or Class B Operators or emergency response personnel of the same. Class C operators may be trained by Class A or Class B operators using formats approved by the state.


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