Environmental, Health and Safety Compliance Newsletter
June 16 , 2006 - Volume 4, Number 5
MACTEC's Environmental, Health and Safety Compliance Newsletter is a bi-weekly newsletter highlighting regulatory updates and the latest legal and technical news for Environmental and Occupational Safety and Health professionals. This newsletter is also available for printing and downloading here. (122kb PDF)
In this issue
The Environmental Protection Agency (EPA) has finalized revisions to storm water regulations to advance the comprehensive energy policy enacted by Congress last year. This action, implementing an amendment to the Clean Water Act passed in the Energy Policy Act of 2005, modifies water permitting program regulations to clarify that uncontaminated storm water discharged from oil and gas field activities does not require a National Pollutant Discharge Elimination System permit.
This rule encourages voluntary application of best-management practices for oil and gas field construction activities to minimize erosion and control sediment to protect surface water quality during storm events. It also retains the right of states to regulate these activities under other laws and authorities.
EPA will work with government, citizens, and industry to promote the importance of storm water management at oil and gas sites as it implements its rulemaking activities. This rule is effective June 12, 2006.
Information on permitting of storm water discharges: http://cfpub.epa.gov/npdes/stormwater/oilgas.cfm.
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An EPA proposed rule would clarify that permits are not required for transfers of water from one body of water to another. Such transfers include routing water through tunnels, channels, or natural stream courses for public water supplies, irrigation, power generation, flood control, and environmental restoration.
"The Water Transfer Rule gives communities needed flexibility to protect water quality, prevent costly litigation and promote the public good," according to EPA Assistant Administrator for Water Benjamin H. Grumbles. "President Bush is committed to cleaning and protecting the nation's water resources, and this rule keeps the Clean Water Act focused on water pollution, not water allocation."
Thousands of water transfers currently in place across the country are vital to the water infrastructure. Whether a permit is needed under the Clean Water Act's National Pollutant Discharge Elimination System (NPDES) has been an issue in numerous court cases in recent years. The proposed rule would define
such transfers as the movement of water between bodies of water without subjecting the water to intervening industrial, municipal or commercial use.
In 2004, the question of whether NPDES permits were necessary for water transfers went before the U.S. Supreme Court in South Florida Water Management District v. Miccosukee Tribe of Indians. The court did not rule directly on the issue, generating uncertainty about the need for a permit. EPA concluded in 2005 that Congress intended water resource-management agencies and other state authorities to oversee water transfers, not the NPDES permitting program. This rulemaking codifies that conclusion.
Recent articles in the Orlando Sentinel and Palm Beach Post argue that the proposed rule will allow polluted waters from cities and farms to be dumped into lakes.
The proposed rule is available online at http://cfpub.epa.gov/npdes/home.cfm?program_id=41#water_transfer.
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If you are currently working on your SARA Title III (Emergency Planning and Community Right to Know) Form R or Form A, this is the last year that you will be able to classify your facility using the Standard Industrial Classification (SIC) code system. Beginning with reports due July 1, 2007, owners and operators of facilities subject to Toxics Release Inventory (TRI) reporting must identify their principal business activities using North American Industry Classification System (NAICS) codes for releases and other waste management activities for the 2006 calendar year. In the past, principal business activities were reported using Standard Industrial Classification (SIC) codes, so identifying industrial codes is not a new requirement. EPA is not adding or deleting industry groups subject to reporting requirements, but rather is simply identifying the NAICS codes that are subject to TRI. The Office of Management and Budget plans to update the NAICS system every five years. The next update is scheduled for 2007. TRI-covered NAICS codes, if affected by these updates, will be revised accordingly.
For additional information to help facilities convert from SIC to NAICS, see: http://www.epa.gov/tri/tridata/naics/.
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EPA’s Office of Underground Storage Tanks (OUST) recently published for comment three draft guidelines to implement Title XV, Subtitle B of the Energy Policy Act of 2005, which focuses on preventing underground storage tank releases. EPA developed these guidelines for state underground storage tank programs. The agency is accepting comments on the draft guidelines until June 24, 2006. The draft guidelines are available at http://www.epa.gov/oust/fedlaws/epact_05.htm#Drafts.
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The NOAA has issued the Annual Greenhouse Gas Index, its benchmark measurement of gases in the atmosphere that affect the Earth's climate.
This year's AGGI shows an increase in carbon dioxide (CO2) and nitrous oxide (N2O) but a leveling off of methane (CH4), and a decline in two chlorofluorocarbons (CFCs), gases that contribute to the cause of the Antarctic ozone hole. Overall, the AGGI shows a continuing, steady rise in the amount of heat-trapping gases in the atmosphere.
The NOAA AGGI is based on the analyses of atmospheric levels of all the major and minor long-lived greenhouse gases, and factors in the relative strengths of each gas in its ability to trap heat. The gases include carbon dioxide, methane, nitrous oxide, CFCs and the current replacements for CFCs, and have been measured since 1979 by NOAA's global sampling network.
The AGGI will be included in the annual Greenhouse Gas Bulletin issued by the World Meteorological Organization (WMO) in November. The AGGI is available online at http://www.cmdl.noaa.gov/aggi/.
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A new final rule, established under the Clean Water Act, will provide increased protection to fish, shellfish and other aquatic life. This action sets standards for cooling water intake structures at new oil and gas extraction facilities either at offshore or coastal locations. The rule applies to an estimated 124 new rigs and platforms expected to be built over the next two decades. These facilities could require as much as 20 million gallons of water a day to cool the equipment.
Derived from Section 316(b) of the Clean Water Act, this is the final action of a three-phase process that began by implementing requirements for new facilities, but did not include offshore or coastal oil and gas facilities. The second rule addressed existing power plants that use more than 50 million gallons of cooling water per day.
Cooling water intake structures at existing manufacturing facilities and certain power generators will continue to abide by section 316(b) requirements established on a case-by-case, best professional judgment basis through the water permitting program. The final rule does not change the regulatory requirements for facilities subject to the first and second regulations.
Additional information is available online at http://www.epa.gov/waterscience/316b/ph3.htm.
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Pennsylvania’s state-specific proposal to control mercury emissions from coal-fired power plants passes the key test for determining whether a measure violates the Commerce Clause of the U.S. Constitution.
“Pennsylvania’s rule is legally sound and scientifically proven,” Environmental Protection Secretary Kathleen A. McGinty said.
For a measure to be suspect under the U.S. Commerce Clause, it must impose disparate treatment for enterprises within a state, as compared to out-of-state enterprises.
Pennsylvania’s state-specific rule ensures equal treatment, requiring electric generating units to meet the very same performance standards regardless of whether they use bituminous or sub-bituminous coal in their operations.
The state-specific rule presumes compliance for units that burn 100% bituminous coal with advanced air control technologies. But that presumption of compliance has nothing to do with setting an easier standard for bituminous coal. In fact, the state rule establishes the same standard for bituminous and sub-bituminous coals.
The presumption of compliance only recognizes the established fact that mercury is removed with vastly greater efficiency from scrubbed plants burning bituminous coal than from scrubbed plants burning sub-bituminous coal. Bituminous coal contains more mercury than sub-bituminous coal. But it also contains more chlorine, which enhances the removal efficiency of mercury control technology.
Technical analysis shows that units burning 100% bituminous coal and controlling emissions with a wet flue gas desulfurization and selective catalytic reduction capture 90% of mercury emissions. In contrast, units that burn 100% sub-bituminous coal and control emissions with the same technologies capture only 16% of mercury emissions.
Pennsylvania’s state-specific proposal further is demonstrably even-handed by requiring all plants, whether they use bituminous or sub-bituminous coal, to meet their specified mercury emission cap.
In contrast to the state proposal, the EPA’s rule is quite suspect. The federal rule explicitly sets different standards for different coal types, with the effect that waste coal and bituminous coal are severely and unfairly disadvantaged.
EPA’s rule requires little or no reductions from units using sub-bituminous coal mined in the West and places the most stringent requirements on coal mined in states like Pennsylvania, Kentucky, Indiana, Illinois, Ohio, Virginia and West Virginia.
To appreciate the degree to which the federal rule unjustifiably harms bituminous coal interests, current court filings by the Pennsylvania Coal Association and United Mine Workers of America are instructive.
In ongoing legal proceedings in federal court, PCA and UMWA are claiming EPA’s rule will “result in a vast wealth transfer from bituminous coal users to sub-bituminous and lignite users,” and further will have “adverse and irreversible impacts on the Bituminous Coal Coalition member operations, mine production, mine workers and local economies dependent upon coal mining operations.”
Moreover, PCA and UMWA characterize EPA’s rule as illegal, arbitrary and capricious, wholly unwarranted and flawed, and advise the court that EPA’s Clean Air Mercury Rule will harm “producers of bituminous coal, workers in bituminous coal mines and local economies supported by bituminous coal mining.”
Opponents who question the constitutionality of Pennsylvania’s state-specific rule point to a case where the Illinois Coal Act was overturned as a violation of the Commerce Clause. But that proposal aimed to force the use of Illinois-mined coal, cutting off suppliers from other states.
The act required utilities to formulate compliance plans that had to be approved by the Illinois Commerce Commission, which took into account the effect of the local coal industry when approving those plans. It also required the four largest plants in Illinois burning Illinois coal to include the installation of specific technology in their compliance plans so that could continue to burn Illinois coal. In addition, the state’s Commerce Commission had to approve any 10% or greater decrease in the use of Illinois coal by a utility.
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About 4,250 high-hazard worksites are on tap for inspection under OSHA's 2006 Site-Specific Targeting Program, effective June 12. This year's program will initially target sites that reported 12 or more injuries or illnesses resulting in days away from work, restricted work activity, or job transfer for every 100 full-time workers (known as the DART rate). The list will also include sites that have a days away from work injury and illness (DAFWII) rate of 9 or higher. The program stems from the agency's Data Initiative for 2005, which surveyed approximately 80,000 employers to attain their injury and illness numbers for 2004.
The inspection plan is available online at http://www.osha.gov/OshDoc/Directive_pdf/CPL2_06-01.pdf.
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The DOT is revising the transportation requirements for infectious substances, including regulated medical waste and sharps, to adopt new classification criteria, new exceptions, and packaging and hazard communication requirements consistent with revised international standards and to clarify existing requirements to promote compliance. These revisions will ensure an acceptable level of safety for the transportation of infectious substances and facilitate domestic and international transportation.
This final rule is effective October 1, 2006. Voluntary compliance is authorized beginning July 2, 2006.
The Federal Register notice is available online at http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/06-4992.htm.
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The Pipeline and Hazardous Material Safety Administration is extending until July 31, 2006, the validity of all hazardous material registrations with an expiration date of June 30, 2006, for those who 1) engage in any activity after June 30, 2006, that requires registration and 2) renew their registration by July 31, 2006. A letter documenting the extension is being mailed to each registrant holding a certificate with an expiration date of June 30, 2006, who has not already renewed its registration for a period including the 2006-2007 year.
Any person who has already received a registration certificate for a registration period that includes the 2006-2007 registration year is unaffected by this extension. The extension is being granted to those persons who need to renew for periods beginning July 1, 2006, (but have not yet done so) because of an unanticipated delay in the distribution of the 2006-2007 registration brochure. This delay may not allow sufficient time for many persons to submit the registration statement and receive a new certificate of registration by June 30.
If you are not yet registered for the 2006-2007 registration year, the DOT encourages you to register on-line. Payment by credit or debit card will enable you to print the newly issued certificate at the end of the Internet session. Payment by ACH (electronic check) typically takes one or two days to process, but a certificate will be e-mailed to you promptly upon confirmation of the payment.
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NIOSH is requesting public comment on a Draft Report of Investigations, “Laboratory and Field Performance of a Respirable Personal Dust Monitor.” The draft report addresses the laboratory and field testing of the Personal Dust Monitor (PDM). Comments will be accepted until June 30, 2006. A copy of the draft report and links for filing comments by email and online can be found at http://www.cdc.gov/niosh/review/public/dustmonitor. Included in the draft report for public comment are extensive technical data and discussions, such as descriptions of the PDM, the tests performed on the equipment, detailed data from test results, and the conclusions drawn from the results. The draft report concludes that, based on the findings of the tests, the device “functioned as well as the current sampler in terms of availability for use, accuracy, precision, and miner acceptance.”
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A new NIOSH Topic Page provides a resource for findings and recommendations by NIOSH to reduce the risk of severe obstructive lung disease (bronchiolitis obliterans) associated with occupational exposures to flavorings. Bronchiolitis obliterans is a serious, irreversible lung disease whose symptoms include cough and shortness of breath on exertion. The topic page provides background on NIOSH’s extensive research into this occupational disease, outlines the symptoms associated with and treatment for bronchiolitis obliterans, and discusses recommended control measures for reducing job-related exposures to flavorings. Also on the page are links to key NIOSH resources and reports stemming from its research. We invite you to review the Topic Page at http://www.cdc.gov/niosh/topics/flavorings/. The page includes an email address for providing feedback and receiving updates of information, Flavorings@cdc.gov.
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The Research Triangle Park office is pleased to announce the addition of Walter C. Gray as Manager of the RTP Air Emissions Source Testing Group. Walt is a Chemical Engineer who brings over 26 years of air emissions source testing and air quality consulting experience to MACTEC.
He was previously employed with URS Corporation as a Senior Project Manager and Testing Group Unit Manager. Walt has assessed air emissions and the impacts of regulatory requirements for clients include the electric utility companies, the Electric Power Research Institute, the Gas Technology Institute (formerly Gas Research Institute), the Department of Energy, petroleum and natural gas industry organizations, pulp and paper manufacturers, and a wide range of industrial groups. He also characterized emissions due to Open Burn/Open Detonation (OBOD) operations for the Department of Defense (DoD). The RTP office is now using that work to develop emission factors for DoD.
During his career, Walt has developed a broad based knowledge associated with the measurement of air pollutants using U.S. EPA test methods and the application of analytical measurement technologies to stationary sources. At MACTEC, he will be heavily involved in converting our state-of-the-art fine particulate matter sampling train into a commercially-viable product.
Feel free to contact Walt at WCGray@mactec.com for any air emissions testing needs.
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RECENTLY PROMULGATED FEDERAL REGULATIONS
Health and Safety
Heat Stress/Hot-Weather Hazards
To help protect workers from hot-weather hazards, the Occupational Safety and Health Administration has several publications available, OSHA announced May 16. Heat exhaustion from dehydration and heat stroke can be fatal, OSHA warned. Recognizing warning signs of the illnesses and taking quick action can prevent such deaths, the agency said.
Hot-weather publications available from the agency include Working Outdoors, a fact sheet with advice on protecting against ultraviolet radiation exposure, precautions for working in extreme heat, and ways to protect against Lyme Disease and the West Nile Virus; Heat Stress Card, a laminated card, available in English and Spanish, that offers quick reference about heat-related injuries; and Protecting Yourself in the Sun, a pocket card--available in English and Spanish--that explains how to detect early stages of skin
cancer and how to protect against ultraviolet radiation exposure.
The OSHA publications are available online at http://www.osha.gov/pls/publications/pubindex.list, or by calling (202) 693-1888.
OSHA Offers Guide for First Aid Programs
OSHA issued a best-practices guide to assist employers and employees in developing workplace first aid programs. The guide focuses on four essential elements for effective and successful first aid programs: management leadership and employee involvement, worksite analysis, hazard prevention and control, and safety and health training.
Also included are best practices for planning and conducting first aid training. OSHA recommends that training include general and worksite-specific hazard knowledge and skills, incorporate automatic external defibrillator training into CPR training if AEDs are available at the work site, and periodically repeat training to maintain and update knowledge skills. The "Best Practices Guide: Fundamentals of a Workplace First Aid Program," is available on OSHA's Web site at http://www.osha.gov/Publications/OSHA3317first-aid.pdf.
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RECENTLY PROMULGATED STATE REGULATIONS
Air
Connecticut - Ambient Air Quality Standards for Ozone
Final rule of the Department of Environmental Protection amends regulations under RCSA 22a-174-24(i) regarding ambient air quality standards for ozone. The rule adds an eight-hour ozone standard to comply with federal provisions. The rule is effective April 4, 2006.
Louisiana - Incorporation by Reference of Federal Standards
Final rule of the Department of Environmental Quality, Legal Affairs Division, amends regulations under 33 LAC III.111 through .5901 (nonconsecutive) to incorporate by reference federal standards under 40 CFR Parts 51 through 93 (nonconsecutive), as of July 1, 2005. The rule revises definitions and addresses Part 70 operating permit procedures, conformity, control of emission of organic compounds, standards of performance for new stationary sources, the Comprehensive Toxic Air Pollutant Emission Control Program, area sources of toxic air pollutants, and chemical accident prevention and minimization of consequences. The rule is effective May 20, 2006.
Illinois - Sulfur Limitations
Final rule of the Pollution Control Board amends regulations under 35 IAC 214.162 through .421 and Appendix C (nonconsecutive) regarding stationary sources of emissions. The rule corrects typographical errors in formulas. The rule is part of larger rulemaking relating to concurrent final rules under 35 IAC 211, 218, and 219 regarding standards for stationary sources of emissions. The rule is effective May 15, 2006.
Hazardous Materials/Waste
New York - Used Oil Management
Final rule of the Department of Environmental Conservation amends regulations under 6 NYCRR 360-1, 360-14, 372.1, 374-2, and Appendix 26 to incorporate revisions to federal used oil management standards under 40 CFR 279. The rule also reorganizes the provisions so that they more closely match the format of the federal standards. The rule is effective May 12, 2006.
Nevada - Hazardous Waste Management/Disposal
Final rule of the State Environmental Commission amends regulations under NAC 444.8427 through .9452 (nonconsecutive) regarding hazardous waste management and disposal. The rule revises various provisions to update the incorporation by reference of federal standards. The rule also reflects a change of address of the Department of Conservation and Natural Resources, Division of Environmental Protection, for obtaining certain information. The rule is effective May 4, 2006.
Colorado - Generators/Contingency Plans
Hazardous Waste Final rule of the Department of Public Health and Environment, Hazardous Waste Commission, amends hazardous waste regulations under 6 CCR 1007-3, Sections 265.52 and .53, regarding contingency plans. The rule requires contingency plans to specify the fire protection district responsible for providing fire protection services to the facility or to specify that the facility is not within a fire protection district but is operating under its own approved fire protection plan. The rule also requires that plans identify the local emergency planning committee (LEPC) for the area in which the facility is located and specifies that copies of the contingency plan must be submitted to LEPCs. The rule is effective May 30, 2006.
Florida - Hazardous Waste Standards
Final rule of the Department of Environmental Protection, Division of Waste Management, would amend regulations under FAC 62-730.020 through .220 (nonconsecutive) to incorporate changes to federal hazardous waste management regulations made between July 1, 2003, and June 30, 2005. The rule is effective April 6, 2006.
Health and Safety
Virginia - General Industry Standards/Powered Industrial Trucks
Final rule of the Department of Labor and Industry, Safety and Health Codes Board, amends regulations under 16 VAC 25-90-1910.178 to incorporate by reference Sept. 30, 2005, amendments to federal standards for general industry regarding powered industrial trucks. The rule deletes a provision regarding the use of powered industrial trucks to lift personnel. The rule is effective June 15, 2006.
Tennessee - General Industry, Construction, and Agriculture Standards
Final rule of the Department of Labor and Workforce Development, Division of Occupational Safety and Health, amends regulations under RRT 0800-1-1-.06, -6-.02, -7-.01, -7-.02, and -11-.01 through -.06 regarding occupational safety and health standards for general industry, construction, agriculture, and general inspection exemption programs. The rule incorporates federal standards under 29 CFR 1910, 1926, and 1928, as of July 1, 2006. The rule also updates provisions concerning programs that provide employers with an exemption from general schedule inspections and the procedures to obtain, maintain, and revoke the exemption. The rule is effective Aug. 28, 2006, unless a hearing is requested by June 14, 2006.
New Hampshire - Safety and Health of Employees
Interim final rule of the Department of Labor readopts regulations under NHAR Lab 1400 regarding the safety and health of employees in the workplace. The rule sets forth procedures, guidelines, and directives regarding the requirements of employers to maintain safe workplaces. The rule also identifies and clarifies minimum safety work methods and procedures in workplaces, including furnishing personal protective equipment, safety appliances, and safeguards. The rule is effective April 12, 2006, and expires Oct. 9, 2006.
Michigan - General Industry Safety Standards/Fire Extinguishers
Final rule of the Department of Labor and Economic Growth, Director's Office, amends general industry safety standards under MAC 408.10803 through .10836 (nonconsecutive) to clarify requirements for portable fire extinguishers. The rule provides for the use of Class K fire extinguishers, which are the correct protective response to fires in cooking appliances that involve combustible vegetable or animal oils and fats. The rule is effective May 12, 2006.
North Carolina - Boiler and Pressure Vessels/Certificate and Inspection Fees
Final rule of the Department of Labor amends regulations under 13 NCAC 13.0213 regarding boiler and pressure vessel safety. The rule increases certificate and inspection fees. The rule is effective March 1, 2006.
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Web Sightings
EPA releases Scrap Tire Cleanup Guidebook
In an effort to reduce scrap tire piles around the country, EPA and the state of Illinois have created the Scrap Tire Cleanup Guidebook, A Resource for Solid Waste Managers Across the United States.
It is estimated that more than 290 million tires are scrapped each year in the United States. While 80 per cent are being reused, millions have been accumulating in stockpiles over the past several decades.
The new "how-to" guidebook, written for tire manufacturers, state and local government, regulators, auto recyclers and collectors, contains practical solutions including:
- Examples of scrap tire cleanup programs and funding
- Legal considerations and property issues
- Cost recovery
- Local and regional markets for scrap tires
- Cleanup planning
- Selecting contractors
- Project management
Large scrap tire stockpiles present a risk to human health and the environment for several reasons. They provide an ideal breeding ground for mosquitoes, which carry and transmit life-threatening diseases such as encephalitis, West Nile and Eastern Equine virus, and dengue fever in some regions.
Stockpiles can also catch on fire as a result of lightning strikes, equipment malfunctions or arson. State, federal and local agencies have spent tens of millions of dollars over the past few decades responding to tire fires.
The guidebook is rich with case studies highlighting many success stories. It can be found at www.epa.gov/reg5rcra/wptdiv/solidwaste/tires/guidance. In addition to the guidebook, many resources are available to those tackling a scrap tire problem, including presentations from several scrap tire forums, information on technical issues concerning scrap tires, and end-use markets. See www.epa.gov/reg5rcra/wptdiv/solidwaste/tires/index.htm.
Indiana Enforcement Online
The Indiana Department of Environmental Management’s website has a tool that you can use to identify enforcement actions and orders that were finalized during the previous month. New documents are added on a cycle around the middle of the month. Using a web-based form, you can search a database of published actions and orders. Your search results will return as a hyperlinked list of documents. If an enforcement action or order appears on that list but is not hyperlinked, that means the document will be published with the next cycle. You can use the tool to search for air, water, hazardous waste, solid waste, and underground storage tank violations. It’s a great way to find out if your company, its vendors, or any other site of interest to you has had recent environmental violations subject to enforcement actions in Indiana. Visit http://www.in.gov/serv/idem_oe_order.
Dry Cleaner Virtual Tour
This slide presentation was developed by the State Coalition for the Remediation of Drycleaners: http://www.drycleancoalition.org/tour/. Spent drycleaning solvents have been found in soils and ground water in approximately three-quarters of existing or former dry cleaning facilities. Because these contaminants are difficult to remove, they present a substantial environmental challenge. You can take a virtual tour of the dry cleaning process which includes the cleaning and recycling of used cleaning solvents.
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Ask an Expert
Chris Rogers, Senior Scientist, MACTEC’s Gainesville, Florida Office
What is a halogen?
When EPA regulates halogens, are they really regulating the headlights on your car? When reading environmental regulations, you’ll frequently come across the terms “halogen” and “halogenated.” Halogens are found in column 17 of the periodic table and consist of Fluorine, Chlorine, Bromine, Iodine, and Astatine. When these elements are coupled with organic chemicals (specifically those that have a carbon-halogen bond), they are sometimes referred to as halogenated organic compounds (HOC).
Facilities that use these chemicals have to control potential sources of pollution generated from their use under many environmental programs. Federal laws and regulations that set standards for these materials include:
- Clean Air Act (40 CFR 50-99)
- Clean Water Act (40 CFR 100-149)
- Federal Insecticide Fungicide & Rodenticide Act (40 CFR 150-189)
- Resource Conservation and Recovery Act (40 CFR 260-280)
- Toxic Substances Control Act (40 CFR 700-799)
- Superfund Amendments and Reauthorization Act (40 CFR 300-399)
For compliance assistance, contact Chris at CMRogers@mactec.com, or your local MACTEC office.
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