- 01
- Jan
- 2017
Most facilities outsource the maintenance and servicing of their HVAC equipment. Nonetheless, it must be stressed that the ultimate responsibility for environmental compliance is the facility’s responsibility. If a facility has chillers, or other equipment that contain listed ozone depleting Substances (ODS), commonly referred to as refrigerants, the facility is responsible for demonstrating compliance with […]
Continue Reading...- 01
- Jan
- 2017
The need for a stormwater permit is mandated in EPA regulations (40 CFR 122) for industrial activities. This permit requirement is for facilities during normal operations. The applicability is based upon the SIC code assigned to the facility. An analysis to determine if your facility needs a stormwater permit, or is exempt from it, should […]
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National Ambient Air Quality Standards, or NAAQS, are “ceiling limit” of a pollutant in the atmosphere. A NAAQS limit is not-to-exceed concentration. If exceeded, the area becomes non-attainment for that pollutant and EPA mandates a State Implementation Plan (SIP) to correct this issue. Therefore, a modeling analysis is done when a new source is permitted. […]
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Affirmative defense were widely used to explain the emissions excursions. It was a way to document that the emission exceedances are beyond the facility control and therefore an NOV is not warranted. EPA routinely accepted the Startup, Shutdown, & Malfunction (SSM) excursions as an affirmative defense. Well, Sierra Club sued and the D.C. Circuit vacated […]
Continue Reading...- 01
- Jan
- 2017
EPA’s Chemical Data Reporting (CDR) Rule requires manufacturers and importers of chemical substances included on the TSCA list to report manufacturing information for chemicals manufactured or imported in amounts of 25,000 lbs or greater for the reporting year, unless specifically excluded. The CDR submission periods are from June 1 to September 30 at 4-year intervals, beginning in […]
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