CTI EHS Blog

Georgia Industrial Stormwater Permit Update

Tue, 17 Apr 2012 16:14:32 -0500

The Georgia Environmental Protection Division (EPD) has revised the 2006 NPDES General Stormwater Permit for Industrial Activity. This permit expired on July 31, 2011. According to the Georgia EPD, the 2012 Industrial Stormwater General Permit No. GAR050000 (IGP) was signed on April 16, 2012 and is going to become effective on June 1, 2012. All facilities that are currently operating under the 2006 IGP are required to continue compliance under that permit’s specification until the new permit is in effect.

The US EPA "No Action Assurance" for GACT Tune-up

Mon, 19 Mar 2012 14:01:57 -0500

On March 13, 2012, the US Environmental Protection Agency, Office of Enforcement and Compliance Assurance, provided notice to associations and group representatives of owners of existing Area Source (GACT) boilers that the agency will exercise its discretion not to pursue enforcement for violations of the deadline to complete initial tune-up required in the final rule by March 12, 2012. In addition, the US EPA recently published a proposed re-consideration of the Area Source Boiler Rule that would postpone the tune-up from March 12, 2012 to March 12, 2013. This "No Action Assurance" applies to only the timelines of tune-up and the US EPA notes that nothing in this "No Action Assurance" affects any other provisions in the Area Source Boiler Rule. The "No Action Assurance" is to remain in effect until either (1) 11:59PM EDT October 1, 2012, or (2) the effective date of a final rule addressing the proposal reconsideration of the Area Source Boiler Rule, whichever occurs earlier.

The Collins Amendment Does Not Pass Senate Vote

Tue, 13 Mar 2012 10:36:47 -0500

On March 8, 2012, the US Senate voted by a 52-46 vote (60 needed to pass), to dissapprove the Collins Amendment (SA 1660). This Amendment requested to include the US EPA Regulatory Relief Act of 2011 in the Senate Transportation Bill (S.1813). The amendment would have given the US EPA more time to modify the Boiler MACT related rules, including the Non-Hazardous Secondary Materials that are the Solid Waste Rule.

For more information on the Boiler MACT Rules, visit www.boilermactcompliance.com

Upcoming Events

Wed, 22 Feb 2012 16:49:27 -0500

I will be speaking on Combustible Dust Safety at the following conferences:

Region 8 VPPPA 2012 Conference (May 2-3 @ Greenwood Village, Colorado) - website
Region 7 VPPPA 2012 Conference (May 8-9 @ Des Moines, Iowa) - website
Region 6 VPPPA 2012 Conference (May 17-18 @ Fort Worth, Texas) - website
Region 1 VPPPA 2012 Conference (June 11-13 @ Killington, Vermont) - website
Region 4 VPPPA 2012 Conference (June 19-21 @ Chattanooga, Tennessee) - website
28th Annual National VPPPA Conference (August 20-23 @ Anaheim, California) - website

Proposed Changes to the Non-Hazardous Secondary Materials That Are Waste (NHSM) Rule

Thu, 08 Dec 2011 15:28:29 -0500

On December 2, 2011, the EPA Administrator, Lisa P. Jackson, signed a notice and EPA is submitting it for publication in the Federal Register (FR). The proposed changes to the NSHM rule, include:

OSHA Combustible Dust Rule Moving Forward

Mon, 14 Nov 2011 10:20:33 -0500

I spoke to an OSHA rulemaker who is working on the long-storied Combustible Dust Safety Rule that has been in the works for over 2 years now (Link to CTI's Blog on the ANPR). The latest news I was told is that the proposed rule is scheduled to move to a Small Business Regulatory Enforcement Fairness Act (SBREFA) review panel in December of 2011.

H.R. 2250 - EPA Regulatory Relief Act of 2011

Mon, 03 Oct 2011 11:20:06 -0500

On September 13^th, the House Subcommittee on Energy and Power approved H.R. 2250 – The U.S. EPA Regulatory Relief Act of 2011. There is also a companion bill, S.B. 1392, in the U.S. Senate. This proposed legislation, if passed, will stay the Boiler MACT/GACT, Incinerator MACT, and Non-Hazardous Secondary Materials rules. Currently all but the Boiler GACT rules have already been stayed by the EPA. This legislation would stay all four rules for at least 15 month and instruct the EPA to revise the rules according to achievable results. Until the legislation passes, the Boiler GACT deadlines are still in effect. The deadline for initial notification of applicability is still September 17, 2011 and the deadline for compliance is March 21, 2012. H.R. 2250 is expected to be voted on this shortly.

No Additional Hearings Likely for GA Storm Water Permit

Mon, 03 Oct 2011 10:20:57 -0500

As I have reported here on the CTI's blog in the past, the Georgia Industrial General Permit for Storm Water Discharges (GAR0500000) is in the process of being reissued. The format and requirements of the permit will be significantly modified, requiring facilities to update their Storm Water Pollution Prevention Plans (SWP3) and conduct additional actions required to comply with the new permit.

CTI Article on Combustible Dust

Thu, 01 Sep 2011 11:44:37 -0500

PH Haroz and Brian Edwards, PE of CTI have written an article for the American Society of Safety Engineers' newsletter Safely Made on the status of OSHA's Combustible Dust Rule-making and on methods to reduce the risk associate with combustible dust. A copy of this article is available on our website for download here: http://www.conversiontechnology.com/brochures/SafelyMade_V03N01_CTI.pdf

Compliance Date for Boiler GACT is Fast Approaching

Thu, 01 Sep 2011 11:20:52 -0500

The first compliance deadline for the Boiler GACT Rule is September 17, 2011 – when the Initial Notification of Applicability is due. This rule applies to facilities with boilers fueled by any fuel except natural gas, and who are not major sources of Hazardous Air Pollutants (HAPs). Some state agencies have already acted, with North Carolina DENR having recently mailed out letters to potentially affected facilities. Others, such as the Georgia EPD, will be sending out similar letters soon. Whether or not you receive a letter, you will have to submit your initial notification by Sept. 17 if this rule applies to your facility.

The Boiler MACT rule, which applies to facilities that are major sources of HAPs, has been placed on legal hold. This means the large facilities have some breathing room, but the small facilities covered by the GACT rule must act now.

More information is available at CTI’s Boiler MACT and GACT website – www.boilermactcompliance.com.

EPA Stays the Boiler MACT for Major Source HAPs

Tue, 07 Jun 2011 13:28:24 -0500

On May 16, 2011, the US EPA signed a stay delaying the effective dates for the final Boiler MACT rules for major sources for hazardous air pollutants (HAPs) and Commercial and Indstrial Solid Waste Incineration (CISWI) Units.

For Boiler MACT sources the deadline for compliance has not changed and is still March 21, 2012. This includes Minor Sources of HAP pollutants and Major Sources of non-HAP pollutants.

The effective dates for HAP Major Source Boiler MACT & CISWI rules are delayed until such time as judicial review is no longer pending or until the US EPA completes its reconsideration of the rules, whichever is earlier.

For more information you can go to www.boilermactcompliance.com or contact us @ 770-263-6330.

Summary of OSHA Combustible Dust Forum

Sat, 14 May 2011 10:49:16 -0500

On May 13, 2011, OSHA held an Expert Forum on Combustible Dust to discuss possible options for developing a comprehensive rule to address the hazards associated with combustible dust. OSHA’s stated intent was to both protect employees and be cost-effective for employers. The major topics for discussion included: Scope; Focus on Preventing Secondary Explosions; Existing Facilities; and Multiple Layers of Protection. The meeting was divided into these four topics for discussion, and OSHA posed questions from each to the panel of experts. Below are the highlights from the meeting.

OSHA Expert Forum on Combustible Dust

Tue, 03 May 2011 09:48:02 -0500

OSHA is holding an Expert Forum to identify regulatory options for addressing combustible dust hazards. The meeting will be May 13th, 2011 in OSHA's home office in Washington DC. CTI will be present for this meeting and we will prepare a summary describing what transpires.

To view the OSHA news release, follow this link: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=19710

An Overview of the Final Boiler MACT Rules and Regulations

Thu, 24 Mar 2011 16:35:05 -0500

On March 21, 2011 the Environmental Protection Agency (EPA) published National Emission Standards for Control of Hazardous Air Pollutants (NESHAP) for boilers, solid waste criteria, and New Source Performance Standards (NSPS) for incineration units. The rules include the following:

NESHAP for new and existing area source boilers (40 CFR Part 63 Subpart JJJJJJ).
NESHAP for new and existing major source boilers and process heaters (40 CFR Part 63 Subpart DDDDD).
Non-hazardous secondary material, when used as fuel or ingredients in combustion units that are “solid waste” under the Resource Conservation and Recovery Act (RCRA) (40 CFR Part 241).
NSPS for new stationary sources and emission guidelines for existing commercial and industrial solid waste incineration (CISWI) units (40 CFR Part 60 Subparts CCCC & DDDD).

Environmental Alert: EPA Issues Final Boiler MACT

Thu, 24 Feb 2011 11:18:52 -0500

On February 21, 2011, the Environmental Protection Agency (EPA) released the final National Emission Standard for Hazardous Air Pollutants (NESHAP) for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, better known as the Boiler MACT. At the same time, the EPA issued the final Boiler GACT for area sources, the final Commercial/Industrial Solid Waste Incinerator (CISWI) rule, and the final Non-Hazardous Secondary Material rule. We at CTI are in the process of reviewing these rules in their entirety and will be issuing Client Alerts in the very near future.