EPA NOC for Boilers Subject to Tune-ups Due July 19th (With a Twist)!

powerhouse-epa-boiler-mactFor those Area Source facilities which are subject to the new EPA Boiler MACT (40 CFR Part 63, Subpart JJJJJ), an important deadline is fast approaching. The Notification of Compliance (NOC), due July 19, 2014, is required for all existing Area Source facilities which were required to complete either the One-time Energy Assessment or an initial Tune-up Work Practice. Both the Energy Assessment and Tune-up were due March 21, 2014.

Unlike previous compliance notification reports; however, the EPA has stated that they will not accept paper certifications. Instead, the report needs to be submitted using the EPA’s Compliance and Emissions Data Reporting Interface. CEDRI will be new to most users, but can be accessed through the same web-based server as that used to complete EPA Toxic Release Inventory Reports and Greenhouse Gas Summary Report. Be sure to check with local/state authorities to make sure that a separate location notification is not also required in paper format.

If you need any assistance setting up an account with CEDRI and/or filing the NOC, please contact Bay Environmental Strategies, Inc. at 888-576-2476.

Planning for Hazardous Materials Before Renovation or Demolition Projects

tylerDo you have an upcoming renovation or demolition project on your schedule? For building owners and contractors, it is important to remember that building materials may contain hazardous toxins that may require specific handling, removal and disposal methods. Construction materials that are commonly encountered on the job site that may require specific care and disposal are:

 

Asbestos

 

Asbestos can be a cancerous causing substance that can cause numerous diseases and health concerns. It is a fibrous material that is still used today in several building materials because of its superior strength and excellent insulating properties. It can be found in adhesives, caulks, electrical panels, drywall, fireproofing, flooring tiles, insulation, paints, plaster, and exterior roofing materials. A licensed asbestos inspector can help you sample and identify asbestos containing material (ACM) on your project site. It is recommended for a single family homes and multi-family units (2-4 units) and required for any building undergoing a controlled fire exercise, multi-family units (larger than 5 units), commercial, and industrial buildings that inspections and all friable ACM is removed before work starts.  

 

Chlorofluorocarbons and Halons (CFCs)

 

CFCs contribute towards a loss in ozone which increases our chances of exposure from the sun’s Ultraviolet rays (UV). This increase the chance for skin, eye, and immune system concerns. CFCs are commonly found in bubblers, cooling units, heat pumps, and refrigeration appliances. Halrons are used in fire extinguishing devices. A project site walkthrough before demolition or renovation can help you identify CFC and Halron containing units.

 

Lead

 

Lead is commonly found in pre 1978 residential, commercial, and industrial exterior and interior paints. Lead can also be found in emergency lighting units. If lead is ingested and inhaled, it cause serious neurological and internal organ concerns. A licensed inspector can help sample and identify lead containing substances on your project site. Remember many buildings contain several layers and coats of paint.

 

Mercury

 

Mercury is contained in several pressure and temperature monitoring devices. It can also be found in agricultural, dental, and electrical devices.  When exposed to an outside environment, Mercury slowly vaporizes which releases dangerous vapors that can go unnoticed by building owners and contractors. The harmful vapors can lead to several neurological and birth defects.

 

Polychlorinated biphenyls (PCBs)

               

PCBs are a cancer causing substance that can be found in caulk, electrical equipment, oils, and specialty paints. An environmental consultant can help you sample and identify PCB containing material on your project site. Labeling PCB containing materials before renovation or demolition can help limit the chance of exposure and contamination.

 

Performing a site walk through with an environmental consultant can help identify and ensure proper disposal of any hazardous materials that may exist on your project site. Collecting an inventory and gaining an understanding of all building materials on your project site can  help ensure hazardous materials do not impact public safety and the environment during your renovation or demolition project.

 

More information on handling hazardous materials before your renovation and demolition project can be found at: http://dnr.wi.gov/topic/demo/.

Read Your Permits

title VA manufacturing operation generally requires several environmental permits in order to legally operate. These permits may be for wastewater, storm water, and/or air discharges associated with its operations. Each of these permits will detail the specific requirements needed to maintain compliance with the associated discharges. It is extremely important that each permit is thoroughly reviewed to understand these legal requirements. Unfortunately a defense of not reading your permit will not withstand the scrutiny of your State, Federal or Local compliance or enforcement manager.

Most permits can be reviewed in an hour or less depending on the complexity of the facility. A more complex facility that has Title V permit may require a longer period of time to review. If there are sections of the permit that are difficult to understand do not be afraid to ask questions from your regulatory compliance manager or environmental consultant. Your lack of understanding the permit requirements are also not a proper defense to noncompliance.

Some of the facility permits will last several years before reissuance is required. We recommend that not only do you review the permit upon issuance but also annually to ensure continuing compliance. With that said constructing a compliance calendar with the facility’s permit requirements is an invaluable tool to help reduce liability and increase permit compliance.