EPA Approval Of Painting Controls For Some Surface Coating Operaitons

EPA has approved a revision to the Illinois State Implementation plan (SIP) submitted by the Illinois Environmental Protection Agency (Illinois EPA) on November 14, 2011. The revision amended Illinois Administrative Code by adding a "small container exemption" for pleasure craft surface coating operations in the Chicago and Metro-East St. Louis 8-hour ozone nonattainment areas. EPA concluded that these exemptions were consistent with EPA volatile organic compound (VOC) reasonably available control technology (RACT) policy.

EPA found the exemption was consistent with Illinois RACT rules for similar coating operations, including can, coil, vinyl, metal furniture, and magnet wire coatings. EPA agreed with Illinois EPA and ACA that the exemption may reduce VOC emissions by encouraging repairs and touch ups, as opposed to performing complete re-coats.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
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Final Transport Rule Released

On June 12, EPA announced the final set of minor adjustments to the Cross-State Air Pollution Rule (CSAPR), better known as the "Transport Rule." The Agency says the changes will provide important and consistent technical adjustments to the CSAPR programs in certain states. No changes were made to the core elements of the program. The changes were originally issued as a direct final rule in the February 21, 2012, Federal Register, but were withdrawn because EPA received adverse comments during the public comment period. The Agency says the new final rule includes the same set of revisions; it also addresses the comments received.

The final rule revises state budgets for Arkansas, Georgia, Indiana, Kansas, Louisiana, Mississippi, Missouri, Nebraska, New York, Ohio, Oklahoma, South Carolina, and Texas. In addition, the rule revises unit set-asides for Arkansas, Louisiana, and Missouri.

CSAPR is a market-based program that is designed to reduce the amount of pollutants that drift from upwind states into downwind states. According to EPA, the total budget increase from the new rule is small (less than 1%) when compared to the millions of tons of pollution reductions secured by CSAPR.

On December 30, 2011, the U.S. District Court of Appeals stayed CSAPR pending judicial review. Currently CSAPR's predecessor, the Clean Air Interstate Rule, is in effect. The Agency anticipates a ruling from the court on CSAPR sometime this summer. EPA finalized the new adjustments and corrections so that it can be “prepared to implement CSAPR if the stay is lifted. Finalizing the rule does not impose any requirements on regulated units or states.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
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Illinois SIP To Reduce Regional Haze

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 (including Illinois), 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. The dates for action on the Illinois regional haze SIP are:
Proposed Promulgation: January 17, 2012
Final Promulgation: May 15, 2012

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 expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Mercury Standard For Power Plants Extended Comment Period

In response to requests from Congress and to allow additional public comment, EPA has extended the timeline for public input on the proposed mercury and air toxics standards applicable to coal-fired power plants. The 30-day extension will not alter the timeline for issuing the final standards in November 2011.

EPA proposed the national mercury and air toxics standards in March. The standards will be phased in over 3 years, and states have the ability to give facilities a fourth year to comply. Currently, EPA estimates that more than half of all coal-fired power plants already deploy widely available pollution control technologies that are called for to meet the proposed standards. Once final in November, these standards will require the remaining coal-fired plants, roughly 44%, take similar steps to decrease emissions.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Toxic Release Inventory TRI Report Summary For Chicago Metro

A summary of the 2009 Toxic Release Inventory for facilities in the Chicago-Joliet-Naperville, IL-IN-WI metropolitan area has been released by US EPA. Total on-site disposal or other releases for the Chicago metropolitan area decreased by 25% from 2001 to 2009 with a 12% decrease from 2008 to 2009. Air releases decreased 29% from 2001 to 2009 and 14% from 2008 to 2009. Surface water discharges decreased by 50% from 2001 to 2009 and 17% from 2008 to 2009. The primary metals total disposal or other releases decreased by 20% from 2001 to 2009, including a 49% decrease in surface water discharges and a 31% decrease in air releases.

The Chicago metropolitan area had similar TRI releases compared to the national averages. In 2009, nationwide the releases of 313 toxic chemicals decreased by 12% from 2008. The analysis, which includes data on approximately 650 chemicals from more than 20,000 facilities, found that nationally total releases to air decreased 20% since 2008, and releases to surface water decreased 18%, and to land 4% since 2008.

The EPA analysis shows decreases in the releases of persistent, bioaccumulative, and toxic (PBT) chemicals including lead, dioxin, and mercury. Total disposal or other releases of mercury decreased 3% and total disposal or other releases of both dioxin and lead decreased by 18%. Seven percent few facilities reported to TRI from the previous year, continuing a trend from the past few years.

EPA added 16 chemicals to the TRI list of reportable chemicals in November. These chemicals are reasonably anticipated to be human carcinogens, and represent the largest chemical expansion of the program in a decade. Data on the new TRI chemicals will be reported by facilities on July 1, 2012.

Caltha LLP provides specialized expertise to clients in Illinois in the preparation of EPCRA 313 Toxic Release Inventory reports, developing chemical tracking procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at
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Greenhouse Gas Ruling for IEPA Air Permits

U.S. EPA's Environmental Appeals Board recently issued a decision concerning greenhouse gas requirements of air permits in Illinois. This case involved a petition for review filed by the Sierra Club challenging certain conditions of a prevention of significant deterioration (“PSD”) permit issued by the Illinois Environmental Protection Agency for construction of a synthetic natural gas manufacturing plant.

The Sierra Club raised several issues, including that the permit failed to regulate greenhouse gases. According to Sierra Club, greenhouse gases constitute "contaminants" causing or contributing to "air pollution" under IEPA rules. However, the Illinois EPA disagreed and made its case that IEPA does not interpret State rules as requiring regulation of greenhouse gas emissions.

The Board deferred to Illinois EPA's interpretation and rejected Sierra Club's argument. Because the IEPA had interpreted the disputed provision of its state SIP as inapplicable to greenhouse gases, and because this interpretation did not appear unreasonable, the Appeals Board declined to substitute its judgment for that of the IEPA and denied review of this issue.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Transport Rule Proposed Under Clean Air Act

U.S. Environmental Protection Agency (EPA) is proposing regulations targeting power plant emissions that drift across the borders of 31 eastern states and the District of Columbia, commonly referred to as the Transport Rule.

The Transport Rule would reduce power plant emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) to meet state-by-state emission reductions. By 2014, the rule and other state and EPA actions would reduce SO2 emissions by 71 percent over 2005 levels. NOx emissions would drop by 52 percent.

The proposal would replace the 2005 Clean Air Interstate Rule (CAIR), which the U.S. Court of Appeals for the D.C. Circuit ordered EPA to revise in 2008. The court allowed CAIR to remain in place temporarily while EPA worked to finalize the replacement rule.

EPA will take public comment on the proposal for 60 days after the rule is published in the Federal Register. The agency also will hold public hearings.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Sulfur Dioxide - Final Health Standard

USEPA has issued a final new health standard for sulfur dioxide (SO2). EPA sets the 1-hour SO2 health standard at 75 parts per billion (ppb), to protect against short-term exposures ranging from five minutes to 24 hours. EPA is also revoking the current 24-hour and annual SO2 health standards because these existing standards would not provide additional health benefits.

EPA is also changing the monitoring requirements for SO2, and also changes the Air Quality Index to reflect the revised SO2 standard.

The final rule addresses only the SO2 primary standards, which are designed to protect public health. EPA will address the secondary standard, designed to protect the public welfare including the environment, as part of a separate review to be completed in 2012.

EPA expects to identify or designate areas not meeting the new standard by June 2012.

More information on new health standard for sulfur dioxide - SO2

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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info@calthacompany.com

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NESHAP Compliance Reporting For IL Plating Operations

On or before July 1, 2010, plating facilities in Illinois subject to the plating or polishing operations National Emission Standards for Hazardous Air Pollutants (NESHAP) will have to submit their Notification of Compliance Status. In 2008, EPA published the NESHAP for Plating and Polishing Operations, which impacted many metal finishing operations, including facilities with plating, polishing or thermal spray processes that contain cadmium, nickel, lead, manganese and/or chromium.

The rule specifies several notification, recordkeeping and reporting requirements:
• Submit an Initial Notification by Oct. 29, 2008.
• Submit a Notification of Compliance Status by July 1, 2010 for existing processes, or at startup for new processes.
• Submit an annual compliance certification and,
• Submit an annual deviations report, if applicable.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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RICE Proposed Rule for Area Sources

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 expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
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Regulatory Updates - Environmental Compliance Requirements

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 expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
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Caltha LLP Website

Illinois (IEPA) Clean Air Mercury Rule - Proposed Updates

Illinois' Clean Air Mercury Rule (CAMR) provides for the control of mercury from coal-fired electric generating units. IEPA regards the majority of the rule as in effect despite the fact that the federal CAMR rule has been vacated. However, a number of monitoring, recordkeeping, and reporting provisions simply incorporated the federal CAMR rule by reference, and so are no longer valid. Therefore, the Illinois rule must be amended.

Currently the Illinois Pollution Control Board to update the Illinois' Clean Air Mercury Rule (CAMR). CAMR regulates mercury emissions from coal-fired electric generating units. The proposed rule no longer requires a CEMS, but allows periodic emissions testing as an alternative. Additionally, under the proposed rule, units complying with the Multi-Pollutant Standard or the Combined-Pollutant Standard can elect to comply with these monitoring requirements or with semi-annual emissions testing requirements

Under current rules, emissions monitoring must have commenced by January 1, 2009. However, in the proposed rule, this deadline is extended until July 1, 2009. The proposed rule also amends reporting requirements.

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
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Environmental Training in Ilinois - EHS Training Courses

Caltha LLP offers a wide variety of Environmental Training courses developed to meet requirements of numerous regulatory programs.

Training is offered in a number of flexible formats, ranging from traditional classroom training presented periodically in different locations, to facility-level training conducted at individual sites to meet employee and/or contractor training needs. Caltha offers web-based and remote training options. Caltha also creates facility-specific training materials and conducts “train-the-trainer” sessions for facility training staff.

Caltha provides training in the following areas:
[Click on area to request information on upcoming training programs and training options]

RCRA - Hazardous Waste Generator (LQG) Training
HazCom - Hazard Communication Training
Stormwater Pollution Prevention - SWPPP Training [read more about State-specific SWPPP training]
Spill Prevention Control & Countermeasure - SPCC Training
Internal Compliance Audit Training
Internal EMS Audit Training
Contractor Training Programs
Facility Environmental Regulatory Overview Course

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
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Illinois Environmental Consultant – Environmental Consulting Services

Caltha LLP provides expert technical consulting services to private and public sector clients across Illinois. For further information, click on links below:

Illinois (IEPA) Environmental Compliance – Permitting Services
Illinois (IEPA) Stormwater Permit Compliance – Storm Water Permitting Services
Illinois Environmental Assessment– Phase I (Phase 1) ESA Services
Illinois RCRA Compliance Services
Illinois Haz Com – Hazard Communication Compliance Services
Illinois EHS Staffing - Contract Employee Services
Illinois Wastewater Compliance - NPDES Permitting Services

Caltha LLP provides expert environmental consultant services in Illinois to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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