Volume 12 • September 2005

REGULATORY UPDATE

Corrections to Final Rule Standardizing Waste Manifest System – June 16, 2005

On June 16, 2005, the U.S. EPA published corrections to its March 4, 2005 final rule standardizing the hazardous waste manifest system.  The June 16th rule corrects the inadvertent omission of the manifest form and continuation sheet from the instructions.  The June 16th rule also amends portions of the instructions for the manifest and continuation forms, clarifies that the reference to DOT marking regulations in the initial rule does not apply to hazardous waste generators, and corrects errors in the manifest discrepancy requirements. For more information, refer to the corrections in the June 16th Federal Register Notice, and to the initial rule in the March 4th Federal Register Notice.  Facilities may begin using the new forms September 6, 2005. 

Proposed Amendments to Effluent Limitation Guidelines, Pretreatment Standards, and New Source Performance Standards for the Iron and Steel Manufacturing Point Category – August 10, 2005

On August 10, 2005, the U.S. EPA proposed amendments to the regulations establishing effluent limitations guidelines, pretreatment standards, and new source performance standards for the Iron and Steel Manufacturing Point Source Category.  Entities potentially affected by this action include existing and new facilities engaged in metallurgical coke making, sintering, iron making, steelmaking, direct reduced iron making, briquetting, and forging.  Prior to 2002, regulations applicable to the Iron and Steel Manufacturing Point Source Category established limitations on the total mass of a pollutant discharged from a site. This “bubble”-type limit allowed varying discharges from single outfalls as long as the total quantity discharged from the combined outfalls did not exceed the allowed total mass limitation.  On October 17, 2002, U.S. EPA promulgated amendments to the iron and steel regulations that disallowed this approach for oil and grease.  EPA has reconsidered and is now proposing to reinstate the provision authorizing alternative oil and grease limitations. For more details, see the August 10th Federal Register Notice

ENVIRONMENTAL NEWS

U.S EPA is Sued for Allowing States to Drop New Source Review (NSR) Requirements in Certain Areas

The American Lung Association and three other groups have sued U.S. EPA, saying that the new, more stringent 8-hour ozone standard actually allows a relaxation of pollution control measures in some areas of the country (American Lung Association v. EPA, D.C. Cir., Nos. 05-1281, 05-1282, 7/21/05).  The lawsuits challenge U.S EPA’s maintenance of a provision in the implementation rule for the 8-hour ozone standard that allows states to revoke NSR requirements imposed on areas that failed to achieve attainment under the old 1-hour ozone standard if they are in compliance with the new 8-hour ozone standard.  The plaintiffs believe that this provision could cause pollution increases in some major U.S. cities, including Houston, Chicago, Philadelphia, New York, Sacramento, Washington, Dallas, Milwaukee, Baton Rouge, and Boston.

ENVIRONMENTAL RESOURCES

EQ’s Air Emission Testing Services

EQ's Emission Measurement Division is a recognized leader in environmental source testing.  The Source Test Group offers experienced, reliable, and independent testing services to clients who need to obtain new environmental permits, demonstrate compliance with existing permits, determine/verify performance of air pollution control equipment, or develop emission factors for specific processes.  EQ’s Source Test Group has been conducting emission testing for more than 27 years at virtually all types of industrial sources, including chemical manufacturing, steel and coke manufacturing, surface coating and printing operations, utilities, industrial boilers and furnaces, pharmaceutical operations, automotive operations, and many others.  EQ can perform all recognized EPA reference test methods for industrial and government sources under nearly all temperature, pressure, pollutant concentration, and gas flow conditions.  For more information on EQ’s emission testing capabilities, refer to the air capabilities section of our website, or contact Tom Gerstle at (800) 229-7495.

 

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