WHAT'S NEW
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NEWLY PROMULGATED REGULATIONS -FEDERAL
TSCA Chemical Data Reporting Requirements -Citation: 40 CFR 711
Deadline is June 30, 2012
EPA promulgated a new regulation under the Toxic Substances Control Act (TSCA) that requires facilities to report to EPA about chemicals manufactured or imported at their facilities in reporting year 2011. This reporting requirement is similar to the Inventory Update Reporting that was required by EPA for reporting year 2006; however, EPA has rewritten the rule for reporting year 2011 so the applicability and required data items are not necessarily the same.
In general, the rule applies to the manufacture or import of more than 25,000 pounds of a chemical listed on EPA’s TSCA inventory (essentially any chemical with an assigned CAS number). The rule has some exceptions to exclude the following:
- “Small manufacturers” defined by annual sales less than $4 million OR annual sales less than $40 million and less than 100,000 pounds manufactured
- Manufacture of a byproduct which is not distributed in commerce
- Manufacture of polymers
- Manufacture of living microorganisms
- Manufacture of natural gas and gasoline
- Extraction of naturally occurring chemical substances
- Partial exemption for approximately 90 listed chemicals
EPA has indicated that the required reporting form (Form U) will be filed through the EPA Central Data Exchange. The full text is at http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=6d64a71dacdd276e5184cf6e928798dc&tpl=/ecfrbrowse/Title40/40cfr711_main_02.tpl
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NEWLY PROMULGATED REGULATIONS in MA
Mass DFS Hazardous Material Processing Regulations, 527 CMR 33.00
The MA Department of Fire Services promulgated a new regulation for facilities that process hazardous materials. In general, the regulation applies to facilities that process a material that has a rating of 3 or 4 for health (blue), flammability (red), or reactivity (yellow) on the NFPA diamond. However, there are a number of exceptions for activities or materials that will not be regulated under this rule, including:
- Atmospheric storage of hazardous material below its boiling point without refrigeration
- Hazardous waste activities regulated by Mass DEP
- Air pollution control devices regulated by Mass DEP
- Treatment of potable water or sanitary wastewater, or pretreatment of industrial wastewater with a grade of 1 or 2
- Fuels burned solely for the operation of equipment
- Repackaging of flammable and combustible liquids
Facilities subject to the rule will need to apply for a processing permit from their local Fire Department by the following deadlines:
- Facilities subject to EPA Chemical Accident Prevention Provisions (40 CFR 68) or OSHA Process Safety Management: January 1, 2013
- Facilities with a single processing vessel greater than 300 gallons: June 1, 2013
- Facilities with a processing vessel between 2.5 and 300 gallons: January 1, 2014
- Facilities with processing vessels smaller than 2.5 gallons: not required
Facilities will be required to have process safety measures in place for the hazardous material processing permitting including:
- Process hazard analysis
- Safeguards and management procedures to prevent incidents
- Emergency response procedures
Date of promulgation:
February 3, 2012
www.lawlib.state.ma.us/source/mass/cmr/cmrtext/527CMR33.pdf
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Toxic Use Reduction Filing -2012 is another Planning Year
A significant number of Massachusetts TURA Filers chose IRWIN in 2011 for their filings following the 2010 planning year.
Andy Irwin, PE, LSP, TURP, CPEA is certified for TUR Plans and Resource Conservation Plans. He is also a RAB Certified Environmental Auditor and a
BEAC Certified Professional Environmental Auditor ISO14000 Plus. He is a former President, Treasurer and Board Member of the Toxics Use Reduction Planners Association
The TURA program is intended to facilitate and encourage pollution prevention opportunities by evaluating operations and identifying feasible options for reducing the use of toxics. Facility personnel, along with a certified TUR Planner, work to identify TUR options and evaluate them for their technical and economic feasibility.
IRWIN works with companies to evaluate their operations, advise them on potential TUR opportunities, and complete the TUR plan in conjunction with facility employees. In many cases, we have found that implementing various TUR opportunities not only reduced the amount of toxics used, but also reduced costs and improved efficiency for our clients.
Project Examples:
- We worked with one facility that eliminated their use of VOCs, allowing them to turn their emission control catalytic oxidizer off and save over $120,000 a year.
- We identified an option for a processing facility to recover a rare earth metal from a toxic waste stream, eliminating disposal costs of $150,000 a year, and instead generating additional revenue from the recovered material.
- As an alternative to a TUR filing this year, we completed a Resource Conservation (RC) Plan for a facility wishing to reduce energy costs. The audit resulted in recommendations that yield annual energy savings of 13.6% with a financial payback time of just over one year.
- We reduced the amount of planning required for a facility by incorporating TUR into their Environmental Management System. This integration helps reduce the time required to fulfill regulatory obligations and raises awareness of TUR chemical use as significant environmental aspects of the operation.
We serve a wide range of industries including:
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For more information visit,
IRWIN Engineers Pollution Prevention & Toxic Use Reduction
Massachusetts DEP TURA Program Overview
Title V and Prevention of Significant Deterioration Applicability for Greenhouse Gases, 40 CFR 51, 52, 70, 71
EPA promulgated a new regulation describing how greenhouse gases (GHG) will be regulated under Prevention of Significant Deterioration (PSD) and Title V permitting during the upcoming years. EPA is implementing the permitting program in several phases.
Contact us for long range planning deadlines. EPA's plan extends into 2016.
IRWIN Engineers, Inc.
33 W. Central St.
Natick, MA 01760
508-653-8007