On October 9, 2008, U.S. EPA published proposed performance specifications and quality assurance requirements for continuous parametric monitoring systems (CPMS). Proposed Performance Specification (PS) 17 – Specifications and Test Procedures for CPMS at Stationary Sources and Procedure 4 – Quality Assurance (QA) Requirements for CPMS at Stationary Sources will have wide applicability and significantly impact permit holders for sources subject to any federal emission standards under Part 60 (NSPS) and Parts 61 and 63 (NESHAP) that require operation of a CPMS for assuring compliance. The proposed requirements are intended to establish consistent procedures to ensure CPMS are properly selected, installed, and operated. PS-17 and its complementary QA requirements will outline the procedures and requirements for selection, installation/operation, and data validation of systems used to monitor specific process or control device parameters such as temperature, pressure, liquid and gas flow rate, mass flow rate, pH, and conductivity. U.S. EPA is accepting comments on the proposed requirements until December 8, 2008.
For more information, see the Federal Register notice or contact EQ’s Jeff Slayback at (800) 229-7495 or Kent Berry at (800) 229-5299.
On October 6, 2008, U.S. EPA proposed 40 CFR Part 63, Subpart VVVVVV, National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical Manufacturing Area Source Categories. The proposed emission standards and work practices will apply to minor (area) sources of Hazardous Air Pollutant (HAP) emissions and chemical manufacturing operations involved in the production of materials described by NAICS code 325 – Agricultural Chemical and Pesticide Manufacturing, Cyclic Crude and Intermediate Production, Industrial Inorganic Chemical Manufacturing, Industrial Organic Chemical Manufacturing, Inorganic Pigments Manufacturing, Miscellaneous Organic Chemical Manufacturing, Plastic Materials and Resins Manufacturing, Pharmaceutical Production, and Synthetic Rubber Manufacturing. Subpart VVVVVV will only apply if your chemical manufacturing operations process, use, produce, or generate one of 15 named chemical manufacturing urban HAP compounds: 1,3-butadiene, 1,3-dichloropropene, acetaldehyde, chloroform, ethylene dichloride, hexachlorobenzene, methylene chloride, quinoline, arsenic compounds, cadmium compounds, chromium compounds, lead compounds, manganese compounds, nickel compounds, and hydrazine). If applicable based on both NAICS code coverage and chemical manufacturing urban HAP usage, Subpart VVVVVV will regulate all HAP emissions from affected continuous and batch process vents, storage tanks, transfer racks, cooling tower systems, wastewater systems, and process line components.
For more information, see the Federal Register notice or contact EQ’s Jeff Slayback at (800) 229-7495 or Kent Berry at (800) 229-5299.
On October 15, 2008, U.S. EPA announced major changes to the National Ambient Air Quality Standard (NAAQS) for lead based on a number of recent studies of adverse effects of lead on children. The new standard of 0.15 µg/m3, 3-month rolling average, is 10 times tighter than the previous standard. U.S. EPA will require additional air quality monitors near industrial facilities emitting lead in order to determine compliance with the new standard. Only two areas in the country with major emission sources of lead are designated nonattainment with the current lead standard. U.S. EPA expects to complete the designation of attainment/nonattainment areas under the new standard by January 2012, with earlier designations occurring once adequate air quality data becomes available in an area. U.S. EPA did not change any provisions under the prevention of significant deterioration (PSD) program related to lead. Thus, the NAAQS revision will have little immediate impact on new source permitting.
For more information, contact EQ’s Jeff Slayback at (800) 229-7495 or Kent Berry at (800) 229-5299.
On October 17, 2008, the U.S. EPA updated the Emergency Planning and Community Right-to-Know (EPCRA) regulations (40 CFR Parts 355 and 370), specifically Section 302 (Emergency Planning), Section 304 (Emergency Release Notification), and Section 311 and 312 (Hazardous Chemical Reporting). The revisions clarify options for reporting mixtures, both those containing extremely hazardous substances (EHS) and those not containing EHSs. The Tier I and II forms and instructions have been removed from the federal regulations; however, the forms are available on the U.S. EPA website. For specifics on these and other minor changes, visit the U.S. EPA website.
For more information or assistance with changes in Tier I and II reporting, contact EQ’s Sheri Bussard at (800) 229-7495.
On October 30, 2008, U.S. EPA published a final rule under RCRA that redefines solid waste and could exclude about 1.5 million tons of hazardous secondary materials annually from hazardous waste regulation, if the materials are reclaimed or recycled.
The rule, five years in the making, establishes a new regulatory exclusion under RCRA stipulating that a material is not discarded, and therefore is not solid waste, if it is legitimately reclaimed either by the generator or, under specific conditions, another company. Materials can also be excluded if U.S. EPA or an authorized state determines through a petition process that the material is a non-waste.
The new rule recognizes three basic types of activities that could now be deemed excluded from the DSW:
"Hazardous secondary materials" eligible for RCRA exclusion include spent materials, listed sludges, and listed byproducts that are generated, legitimately reclaimed, and handled in non-land-based units. The exclusion from RCRA regulation does not cover materials that are inherently waste-like, are used in a manner constituting disposal, or are burned for energy recovery.
The new DSW will not become effective in any state that is “authorized” under the RCRA “base program” until the state takes affirmative legal action to adopt it. Virtually all states (AK and IA excluded) currently have such base program authorization. If U.S. EPA’s new DSW were adding new requirements or making existing requirements more stringent, all states would be required eventually to adopt the new rule or lose their authorization. Because the new DSW makes existing requirements less stringent, states may choose not to follow it.
A copy of the signed version, a U.S. EPA summary, and press release materials are available on the U.S. EPA website.
For more information, see the Federal Register notice or contact EQ’s Tom Robertson at (800) 229-5299.
The U.S. EPA is issuing a new Storm Water Multi-Sector General Permit (MSGP) for an estimated 4,100 industrial facilities in 29 different sectors to implement site-specific storm water pollution prevention plans to protect water quality. Facilities are required to install control measures that meet established technology.
The MSGP applies to facilities in states and territories not authorized to implement U.S. EPA's National Pollutant Discharge Elimination System program, including Alaska, Idaho, Massachusetts, New Hampshire, New Mexico, parts of Texas and Oklahoma, Rhode Island, Puerto Rico, the U.S. Virgin Islands, the District of Columbia, and the territories of Guam, American Samoa, Johnston Atoll, and Midway and Wake Islands. The MSGP also applies to facilities located in Indian Country lands in Connecticut, Massachusetts, Rhode Island, Michigan, Minnesota, Wisconsin, Louisiana, New Mexico, Oklahoma, Texas, Arizona, California, Nevada, Alaska, Idaho, Oregon, and Washington, as well as to industrial activities taking place on Federal Facilities in Vermont, Delaware and Washington. Authorized and/or delegated states may choose to adopt rules that incorporate inclusive or similar permit language. Under the Clean Water Act, all facilities that discharge pollutants into waters of the United States must obtain a National Pollutant Discharge Elimination System permit. The new permit replaces the MSGP issued in 2000.
For more information, contact EQ’s Mike Arozarena at (800) 825-7495 or Tom Robertson at (800) 229-5299.
On June 30, 2008, Ohio EPA unveiled its new Air Services Program under the eBusiness Center web portal. Air Services is a web-based program that is used to complete and file various air reports and permit applications, and to pay fees. According to Ohio EPA, future periodic compliance reports must be submitted via the Air Services portal rather than submitted in hard copy. This includes 4th quarter 2008, 2nd semi-annual period 2008, and annual 2008 compliance reports due in January 2009. This means that all facilities in Ohio with Title V and Synthetic Minor permits that contain such reporting requirements must establish eBusiness Center accounts and gain access to the data for their facility in order to submit these reports. This is a multi-step process that can take some time to complete. For Title V facilities, this process must be initiated by the site’s responsible official. For Synthetic Minor facilities, the process can be initiated by a high-level company official (president, vice president, secretary, treasurer, general partner) or a plant manager. Click here for detailed instructions on gaining access to your facility’s data in Air Services.
For more information or assistance, contact EQ’s Sheri Bussard at (800) 229-7495.
Federal legislation signed into law on October 3 to avert a national financial crisis also includes expansion of tax credits for homeowners and businesses installing qualified geothermal heat pump systems.
Specifically, the new law provides a 10% business tax credit for the purchase of qualified geothermal heat pump property. The business tax credit is effective for qualified purchases made after October 3, 2008 and before January 1, 2017.
By including geothermal heat pumps within the definition of energy property, geothermal heat pump systems placed in service after October 3, 2008 will now also be subject to a 5-year depreciation period.
Individuals may also be eligible for an expanded federal tax credit of 30%, up to $2000, on the purchase of qualified geothermal heat pump property for their residences. The bill defines qualified geothermal heat pump property as any equipment that uses the ground or ground water as a thermal energy source to heat or cool the residence. Additionally, the equipment must meet current Energy Star requirements. The individual tax credit is effective for qualified purchases made after December 31, 2007, expiring December 31, 2016.
Interested individuals should check with their tax accountants or watch for IRS guidance for more details.
CSA America, Inc., a developer of standards, codes and certification programs, is developing a new personnel certification program for individuals who perform third-party greenhouse gas (GHG) verifications.
This is the first personnel certification program in North America for individuals who perform the job function of a GHG Verifier. The certification has been developed by industry stakeholders and will be operated and maintained by CSA America under the structure of ISO 17024.
CSA America is currently beta-testing the exam, which will ultimately consist of about 80 questions. It is expected to be launched before the end of the year. A number of EQ personnel are participating in the beta-testing process and will take part in the certification program.
To pass the exam, GHG verifiers must be familiar with:
· The Climate Registry Protocol
· WRI/WBCSD - Greenhouse Gas Protocol
· ISO 14064:2006 Parts 1, 2 and 3 Protocol
For more information, visit the CSA America website or contact EQ’s Tom Robertson at (800) 229-5299.
EQ crews are helping remove thousands of drums, tanks and smaller containers of hazardous materials or waste that were orphaned by Hurricanes Ike and Gustav in Louisiana and Texas. The work, being conducted through EQ’s Emergency and Rapid Response Services contract with U.S. EPA Region 6, began on September 21 and is expected to continue through December for the Ike cleanup in Texas and through early 2009 for the Gustav cleanup in Louisiana.
About 170 personnel have been mobilized to clean up after the hurricanes. The work includes:
The U.S. EPA task orders for this project have nearly exceeded $10 million.
For more information, contact EQ’s Jack Greber at (800) 229-7495.
Did you know the average U.S. office employee prints 10,000 sheets of paper a year? (based on research by the Resource Conservation Alliance)
How can I help conserve paper?
Why should I do this?
EQ encourages all of its employees and clients to help conserve paper. Everyone can do a small part and make a big difference. Last year, EQ recycled 6 tons of paper. Our recycled paper helped save:
For more information about reducing your carbon footprint or to learn more about EQ’s Sustainability Program, visit our website or contact EQ’s Tom Robertson at (800) 229-5299.
For your engineering needs, please contact EQ Engineers at 219-844-3500, or email Ron Hawks
For questions about EQ's capabilities, please contact
Bob McCullough or Laurie Buckman, or call (800) 229-7495.
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