On October 15, 2007, U.S. EPA proposed amendments to the existing 40 CFR Part 112 SPCC rule to clarify and streamline requirements. The amendments would increase flexibility for SPCC-regulated facilities in complying with security and facility diagram requirements and in using industry standards to meet integrity testing requirements. The amendments would also clarify general secondary containment requirements. In addition, U.S. EPA is proposing to exempt hot mix asphalt and hot mix asphalt containers; exempt pesticide application equipment and related mix containers used at farms; differentiate testing requirements for certain containers that store animal fats or vegetable oils (AFVO); and define “loading/unloading rack” to clarify equipment subject to the rules. Farms and oil production facilities would be exempt from loading/unloading requirements under the proposed rules. As part of the amendments, “Tier 1” qualified facilities (having no individual oil storage container with a capacity greater than 5,000 gallons up to an aggregate of 10,000 gallons) would be permitted to use an SPCC Plan template to meet rule requirements. For further information, refer to the Federal Register or contact Mike Arozarena or Ken Hardesty at (800) 229-7495.
On September 20, 2007, U.S. EPA proposed air toxics standards for electric arc furnaces (EAFs) at steelmaking facilities that are considered “area sources” of hazardous air pollutants (HAPs) (i.e., emit less than 10 tons per year of any single HAP or 25 tons per year of total HAPs). To reduce mercury emissions, the proposed rule would require EAF steelmakers to only purchase motor vehicle scrap from providers participating in an EPA-approved mercury switch removal program. The rule also contains limitations on the type of scrap used and allowable scrap contaminants to reduce organic and other toxic metal HAPs. The proposed rule contains particulate matter emission limits for control devices that are dependent on the type and annual production of steel manufactured. A 6 percent opacity limit would apply to fugitive emissions from all EAF melt shops. The compliance date for existing EAFs would be 6 months from final promulgation (unless the owner demonstrates that additional time is needed). For further information, refer to the Federal Register or contact Steve Felton at (800) 229-5299.
An official with the Office of Air and Radiation indicated in a recent presentation to the Clean Air Act Advisory Committee that U.S. EPA plans to regulate CO2 under federal New Source Review (NSR) programs. U.S. EPA’s plans follow an April 2, 2007 ruling by the U.S. Supreme Court that U.S. EPA is required under the Clean Air Act to regulate CO2 emissions from mobile sources. Regulation under NSR would require best available control technology for CO2 from major new or modified CO2 sources. Once U.S. EPA promulgates CO2 emission limits for motor vehicles, CO2 would be a “regulated pollutant” and U.S. EPA must determine an emission rate threshold that would subject new and modified sources to review. Unless U.S. EPA promulgates a significant emission rate for CO2 by the time it finalizes its mobile source standards for these pollutants, U.S. EPA would be forced by rule to consider “any CO2 emission increase” subject to NSR regulations. For further information, contact Jeff Slayback at (800) 229-7495 or Kent Berry at (800) 229-5299.
Dennis Dezial, Department of Homeland Security (DHS) Deputy Director for Chemical Security Compliance, indicated in a recent meeting with the Synthetic Organic Chemical Manufacturers Association, that the final list of “chemicals of interest” (Appendix A) in federal chemical security rules will include threshold levels for all listed chemicals. This differs from the current proposed Appendix A list, where approximately 100 of the 344 listed chemicals have no threshold level, meaning chemical facilities that possess any amount of these chemicals would trigger the requirements for risk assessments and security plans. Dezial also indicated that the final Appendix A list will take into account the concerns of the National Propane Gas Association regarding the reportable quantity thresholds for propane, and the concerns expressed by colleges and universities regarding the regulation of chemicals present in academic laboratories. In addition, Dezial indicated that several chemicals will be removed from the final list. Although the draft Appendix A list is still under review, Dezial indicated that DHS has been pushing for an accelerated release. For more information, refer to the DHS website or contact Sheri Bussard at (800) 229-7495
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