CTI EHS Blog

Georgia Industrial Stormwater Permit Update

2012-04-17T21:14:32Z

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. ]]> Normal 0 false false false EN-US X-NONE X-NONE

Upon issuance of this new permit, the Notice of Intent (NOI), No Exposure Exclusion (NEE), and No Discharge Exclusion (NDE) are due to the EPD no more than 30 days after the effective date of the permit. Due to the extended holdup of the permit, the next Annual Report deadline has been pushed back until January 31, 2014. This Annual Report will include the rest of 2012 and all of 2013.

A Stormwater Pollution Prevention Plan (SWP3) must be prepared before submitting the NOI for new dischargers. Existing permitted facilities must have an updated SWP3 within 90 days of the effective date of the 2012 IGP. Any proposed modifications need to be implemented within 180 days of the effective date of the 2012 IGP.

Under this permit, site inspections and evaluations are required to be conducted quarterly, at a minimum. These inspections should be conducted for all areas of the facility where industrial materials are exposed to stormwater, and there should be added focus on control measures during these inspections. An inspection must be conducted at least once per calendar year when stormwater discharges are occurring.

Among many changes from the 2006 IGP, there are significant modifications to monitoring and sampling requirements. Specifically, the permit will now have sector specific benchmarks, which are target values set for stormwater sampling results. Permitted facilities must monitor for any benchmark parameter specified for their industrial sector. This benchmark data is primarily for facilities to determine the effectiveness of control measures.

In addition to sector specific benchmarks, Impaired Stream benchmarks are included in the permit. Every facility needs to evaluate if their receiving water, within 1 mile of each outfall, is impaired, even if it was not classified as impaired in the previous permit. An exceedence of these sector or impaired stream benchmark values is not a violation; however, the facility will be required to evaluate administrative and physical controls used to reduce stormwater pollution and take feasible corrective actions.

If, during a site inspection, unauthorized discharges are observed, or a facility determines that control measures need to be added or modified, the need for corrective actions must be reviewed. Within 24 hours of discovery of these unauthorized discharges or incidents of non-compliance, a facility must identify and document any triggering conditions, descriptions of the problems, and the date the problem was identified. Within 30 days of discovery, facilities must document a summary of the corrective actions to be taken, the date(s) the corrective actions are initiated, and the date(s) the corrective actions are expected to be completed. Modifications must be made no more than 90 days after discovery.

There are several other important aspects of the new permit that will affect industrial activities. A few of these components are:

· Vehicle and equipment wash water is considered an unauthorized non-stormwater discharge. If a facility is currently washing vehicles and equipment outside, that is not approved under this permit, and the facility will have to come up with a course of action for disposal.

· Waste pile leachate, over de minimus amounts, is also considered an unauthorized non-stormwater discharge and is not eligible for coverage under this permit.

· All employees who work in the areas where industrial materials or activities are exposed to stormwater must be properly trained. It is required that training be conducted at time of hire and refreshed annually for existing employees.

· Smoke/Dye testing must be performed at least once during the permit cycle to evaluate for the presence of non-storm water discharges into the storm sewer system from all floor drains, and from all sinks in industrial areas (excluding eye wash stations) that were installed prior to January 2006.

We have already begun updating the SWP3s for a number of our clients.

Please contact CTI if you have any questions or would like assistance in bringing your SWP3 and facility into compliance with the new permit.

http://conversiontechnology.com/

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

2012-03-19T19:01:57Z

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

2012-03-13T15:36:47Z

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

2012-02-22T21:49:27Z

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

2011-12-08T20:28:29Z

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:

In the case of “clean cellulosic biomass,” EPA is identifying specific materials that EPA believes are included within the current definition and would thus be considered a traditional non-waste fuel, including: agricultural derived biomass, other crop residues (including vines, orchard trees, hulls, seeds), other biomass crops used for the production of cellulosic biofuels, hogged fuel, untreated wood pallets, wood pellets, and wood debris from urban areas.

Adding a process for an owner or operator of a facility to petition EPA to categorically list non-hazardous secondary materials as being a non-waste when used as a fuel, including allowing other relevant factors beyond those used in the original rule - EPA is proposing to create a rulemaking petition process that would provide persons an opportunity to submit a rulemaking petition to the Administrator, seeking a categorical determination for additional NHSMs to be listed as non-waste fuels. To be successful, the petitioner would need to demonstrate that the NHSM has not been discarded, and either meets the previously established legitimacy criteria, or, after balancing the legitimacy criteria with other relevant factors, the NHSM is not a solid waste when used as a fuel.

Identifying two secondary materials, resinated wood products and tires managed under the oversight of established tire collection programs, as non-wastes when used as a fuel - EPA is proposing to categorically list several NHSMs as not being solid waste when burned as a fuel in a combustion unit where the Agency has sufficient information to determine that discard is not occurring when these materials are being used as fuels.

Revising the legitimacy criteria to expressly allow the comparison of groups of contaminants and clarifying that contaminant comparisons may be made for any traditional fuel for which a combustion unit is designed to burn - EPA is clarifying that similar groups of pollutants (such as volatile organics, semi-volatile organics) can be compared rather than individual contaminants. The proposal also clarifies that in cases where a unit can burn traditional fuels from several categories, such as a boiler that can burn either coal or biomass, contaminant comparisons could be made using data from either fuel category at the combustor’s discretion. In other words, if a facility burns biomass in its combustion unit, but that same combustion unit could also burn coal, the facility could compare its secondary material to either traditional fuel.

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OSHA Combustible Dust Rule Moving Forward

2011-11-14T15:20:33Z

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.
]]> It is worth noting that the Combustible Dust rule has been slated for SBREFA review before, and delayed. At the beginning of 2011, the rule was on schedule for panel review, but this was delayed in order to hold an Expert Forum (Link to CTI's summary on the Expert Forum).

What does a SBREFA review mean? The below excerpt is taken from OSHA's website (Link to OSHA's SBREFA Page)

OSHA next convenes a Small Business Advocacy Review Panel, consisting of officials from the agency, the SBA's Chief Counsel for Advocacy, and the Office of Management and Budget's (OMB) Office of Information and Regulatory Affairs. The panel hears comments from small entity representatives and reviews the draft proposed rule and related analyses prepared by OSHA. A written report of this interagency panel is submitted to OSHA within 60 days. OSHA reviews the report, makes any appropriate revisions to the rule and publishes the proposed rule along with the panel’s report in the Federal Register.

The SBA's Chief Counsel participates in the small business advocacy review panels and identifies the small entities that the panel should consult. The chief counsel also submits comments on agency proposals. These comments can be viewed on the Office of Advocacy's home page. Concerns about proposed regulations can be addressed to the SBA’s Chief Counsel for Advocacy, 409 3rd. St., S.W., Suite 7800; Washington, DC 20416; or faxed to the Chief Counsel at (202) 205-6928.

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

2011-10-03T16:20:06Z

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

2011-10-03T15:20:57Z

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 has participated in the permit development since day one. This has included attending the stakeholder meetings, submitting written comments, attending the public hearing, and most importantly, staying in communication with the Georgia Environmental Protection Division (GAEPD) staff throughout the process. Through our participation, we have worked with several industry groups, including: the Treated Wood Council (TWC), Southeastern Lumber Manufacturer's Association (SLMA), and the Institute of Scrap Recycling Industries (ISRI).

Because of CTI's participation, we have helped reduce the burden on permitted facilities. Specifically, CTI's comments have resulted in the follwing changes:

The original permit did not allow discharges from material and waste piles. This was primarilly aimed at outdoor storage piles at wood products facilities (e.g. bark, sawdust and chip piles) and other industries. This has been removed from the permit, and now only discharges from "waste piles" is not allowed.
The new permit requires smoke and dye testing of sinks and floor drains at facilities in order to verify they are not connected to the storm water system. Through CTI's comments, exceptions and alternative options to comply with this requirement are in the permit.
CTI's comments during the stakeholder meetings helped the Recycling Industry succeed in removing Iron and Aluminum analysis requirements.

The most recent draft of the permit was issued on September 2nd, and a comment period was open until September 16th. I contacted the GAEPD today to inquire on the status of the permit, and they stated that based on the comments received, additional public hearings are not likely. The permit is expected to become effective this fall, with compliance dates coming by the end of the year. In my opinion, facilities can begin to update their SWP3s to be in compliance with the permit. In fact, we have already begun updating the SWP3s for a number of our clients.

Please contact me at (770) 263-6330 x 103, or bedwards@conversiontechnology.com, if you have any questions or would like assistance in bringing your SWP3 and facility into compliance with the new permit.

Brian Edwards, PE

CTI Article on Combustible Dust

2011-09-01T16:44:37Z

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

2011-09-01T16:20:52Z

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

2011-06-07T18:28:24Z

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

2011-05-14T15:49:16Z

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.

]]> Scope:

The term Scope, in the context of this discussion, refers to who and what the combustible dust rule will ultimately apply to.

The panel agreed that the rule should not specifically exclude any industry.
Some members of the panel suggested that dust with low explosive properties and hard-to-ignite dust should possibly be excluded, or at least should be addressed differently than more hazardous and easily ignitable dust.
Other members of the panel warned that there is no technical support for this exclusion, and pointed out a number of serious dust fire and explosion events that occurred due to what were thought to be “low-hazard” dusts.
A member suggested that if any dust is to be excluded, it should only be a dust that is not combustible at all.
Regardless, the panel agreed that if there was some type exclusion or limitation on which dust were covered by the standard, it should not be based on a single dust property.
One suggested test would be the ASTM test used to determine if a material can support propagation of a flame front.
The panel suggested that the size of a facility should not be a sole reason for exclusion.
One possible exclusion from the rule could be based on quantity of dust at a facility. One example is facilities with less than 5 lbs of aluminum dust.
A panel member suggested that size exclusions could apply to specific pieces of equipment, like in NFPA 654, but should not be based on facility size.
It was noted that the fatality rates in smaller facilities are actually higher than those in large facilities.

Focus on Preventing Secondary Explosions:

OSHA asked if focusing on preventing secondary explosions would be the best way to prevent multi-fatality events. OSHA also asked if there would be a significant impact if the regulation omitted provisions to address primary explosions.

One panel member noted that 95-99% of fatalities and injuries are the result of secondary explosions that occur due to accumulated, fugitive dust.
The grain handling rule focused on housekeeping and ignition control, and that rule has been very effective.
The panel agreed that the first step is to keep dust inside the equipment and vessels, and not let it escape into the work environment.
One panel member stated that $1 spent to contain and/or capture the dust can save $10 in electrical classification, and save $100 in housekeeping cost over 10 years.
For dust that does escape into the work environment, it is important that safe housekeeping methods that cover all areas (including hidden, out-of-site areas) be conducted.
It was suggested that recordkeeping of housekeeping activities and inspection of hidden areas is important.
The panel stated that determining what level of dust accumulation presents a hazard is still being studied, and the rule should allow for advances in knowledge after it is developed.
Most of the panel agreed that reducing the risk of secondary explosions is critical, but primary explosions can be very dangerous and cannot be neglected.
Housekeeping is an important part of controlling combustible dust hazards, but it is only part of a comprehensive management system needed. This system needs to include hazard recognition, engineering controls, employee training and involvement, maintenance and inspection, etc.
Some panel members suggested that some components of the Process Safety Management (PSM) rule, such as Hazard Analysis and Management of Change, could be beneficial, but most agreed that the full PSM regulation would not be appropriate.

Existing Facilities:

OSHA is concerned about the burden on employers if existing facilities must retroactively comply with the standards – particularly for higher-cost engineering controls.

A panel member stated that it is important to understand that the most severe incidents have occurred at “old” facilities, so grandfathering across the board would not address the greatest hazard.
However, several panel members did agree that in some cases, installing engineering controls at existing facilities is not feasible, either economically or technically.
One panel member noted that some controls mandated in NFPA standards are not always justified, and may be obtrusive.
It was suggested that if controls are required, that there should be a phased applicability so that employers do not have to make all modifications at once.
Several members emphasized the importance of conducting a hazard assessment, as the controls needed will be very facility specific and based on the actual hazards at each individual plant.
One possible method is to require facilities to conduct a risk assessment and develop their own priorities for installing controls.
It was noted that NFPA standards have retroactively clauses, and typically only administrative controls (housekeeping, training, hazard analysis) and ignition source controls are retroactive.
Several panel members agreed that housekeeping, training, and ignition controls should be the first priority.
It was suggested that OSHA should include a list of high-hazard processes and equipment that an employer must evaluate (e.g. dust collectors, hammermills, spray dryers).
Also, it was suggested that the exposure to employees should be considered when prioritizing the protection needed.

Multiple Layers of Protection:

OSHA noted that many fire and explosion control scenarios include multiple layers of protection, and asked if requiring only a single layer of protection (e.g. housekeeping) would be appropriate.

The panel agreed that controlling dust fires and explosions require making a number of choices and selecting a number of controls.
Several panel members pointed out that each type of control has holes, and multiple layers are required to truly protect a facility. For example, ignition controls are good, but it is impossible to remove all possible ignition sources.
It was noted that it is important to install multiple layers of controls in order to reduce risk to an acceptable level – though several members agreed that it is impossible to get to zero risk.
Therefore, it was agreed that it is necessary to evaluate each individual situation to determine what levels of control are needed.
It was a consensus that multiple layers of protection are needed, but one panel member urged that OSHA must include some flexibility in the rule, as not every hazard mitigation approach works for every situation – and there is no silver bullet for addressing combustible dust hazards.

My Personal Interpretation

The expert forum provided OSHA with a number of points to consider. I cannot predict exactly how OSHA will use the data, and I can’t say that what I walked out of the meeting with is the same that OSHA walked out with. So, the following summary is only my opinion on how OSHA may, or should use the information provided in this expert forum.

The scope of the rule should cover all facilities that generate and handle combustible dust in a significant quantity.
The rule should make preventing hazardous levels of fugitive dust accumulation a priority. This should be achieved by proper engineering and maintenance of equipment and dust collectors, safe housekeeping, and training.
The rule should require some level of hazard / risk assessments.
Some engineering controls should be required retroactively, but there should be some elasticity in how facilities decide what controls are required.
The rule must contain multiple types of controls, both administrative and engineering, to be effective in reducing the hazards associated with combustible dust.

OSHA Expert Forum on Combustible Dust

2011-05-03T14:48:02Z

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

2011-03-24T21:35:05Z

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).

]]> What does all this mean for you? If you are an area source for hazardous air pollutants (HAPs), and operate an industrial, institutional, or commercial boiler that is coal-fired, biomass-fired, or oil-fired, then 40 CFR Part 63 Subpart JJJJJJ, better known as the Boiler GACT, applies to you. An area source is a facility that emits less than 10 tons per year (TPY) of any single hazardous air pollutant (HAP) or 25 TPY of any combination of HAPs. A major source is a facility that emits above those thresholds. If you are a major source for HAPs and operate boiler or process heater, regardless of fuel type, then 40 CFR Part 63 Subpart DDDDD, better known as the Boiler MACT applies to you.

Under the Boiler GACT, all new or reconstructed boilers and existing coal-fired and oil-fired boilers must meet emission limitations. All affected facilities must conduct boiler tune-ups and perform a onetime boiler energy assessment of at least one boiler. For existing sources, the boiler tune-up must be completed by March 21, 2012. All other requirements must be met by March 21, 2014. If you have a new or reconstructed boiler, it must meet all requirements by May 20, 2011, or by the date it becomes operational, whichever is later.

Under the Boiler MACT, all solid fuel and liquid fuel boilers and process heaters must meet emission limitations. There are a few exceptions, including limited-use boilers, boilers or process heaters associated with a source already subject to another NESHAP, and boilers or process heaters used as emission control devices (i.e. thermal oxidizers). All units must conduct regular tune-ups and perform a onetime boiler energy assessment of at least one boiler. For existing boilers and process heaters, all requirements must be met by March 21, 2014. If you have a new or reconstructed boiler or process heater, it must meet all requirements by May 20, 2011, or by the date it becomes operational, whichever is later.

If you’re facility does not utilize what are defined as “traditional fuels”, then the Identification of Non-Hazardous Secondary Materials that are Solid Waste rule published concurrently with the Boiler GACT and Boiler MACT rules will be of particular importance to you. This rule outlines what are traditional fuels, including virgin biomass. A secondary material is any material that is not the primary product of a manufacturing or commercial process. Essentially, if the secondary material is considered a non-hazardous waste when it is discarded, then it is a solid waste. Unfortunately, selling this secondary material to another entity, in some circumstances, constitutes discarding. All materials that are not considered traditional fuels must meet the Legitimacy Criteria identified in the rule. The EPA has responded to numerous comments regarding secondary materials that have been used as fuel. Unfortunately, many of those do not meet the Legitimacy Criteria. To use treated wood as an example, all but borate treated wood have been found to contain contaminates exceeding those of virgin biomass and are considered solid waste. If your facility utilizes a non-hazardous secondary material that is considered a solid waste under this rule, you must change fuels or comply with the newly issued New Source Performance Standard (NSPS) for Commercial and Industrial Solid Waste Incinerators (CISWI). Unless your facility already had a boiler or process heater identified as an incinerator, it is unlikely your facility can meet the emission limitation requirements, as well as many of the other requirements.

For more information, please visit our website at www.boilermactcompliance.com.

Environmental Alert: EPA Issues Final Boiler MACT

2011-02-24T16:18:52Z

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.