New PM2.5 Air Quality Standard Proposed

In response to a court order, the U.S. Environmental Protection Agency (EPA) has proposed updates to its national ambient air quality standards (NAAQS) for fine particulates known as PM2.5. A federal court ruling required EPA to update the standard based on best available science. According to EPA estimates, 99 % of U.S. counties are projected to meet the proposed standard without any additional action.

EPA’s proposal lowers the annual health standard for PM2.5 to a level within a range of 12 to 13 micrograms per cubic meter. The current annual standard is 15 micrograms per cubic meter. By proposing a range, the agency will collect input from the public as well as a number of stakeholders, including industry and public health groups, to help determine the most appropriate final standard to protect public health. The proposal has no effect on the existing daily standard for fine particles or the existing daily standard for coarse particles (PM10), both of which would remain unchanged.

The Clean Air Act requires EPA to review its standards for particle pollution every five years to determine whether the standards should be revised. The law requires the agency to ensure the standards are “requisite to protect public health with an adequate margin of safety” and “requisite to protect the public welfare.” A federal court ordered EPA sign the proposed particle pollution standards by June 14, 2012, because the agency did not meet its five-year legal deadline for reviewing the standards.

EPA will accept public comment for 63 days after the proposed standards are published in the Federal Register. The agency plans to hold two public hearings; one in Sacramento, CA. and one in Philadelphia, PA. EPA will issue the final standards by December 14, 2012.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
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Action On South Dakota Regional Haze Reduction Plan

The U.S. Environmental Protection Agency (EPA) has announced a court ordered schedule to review and act on more than 40 state regional haze reduction plans (including South Dakota), designed to improve visibility in national parks and wilderness areas. The EPA action by itself does not establish control requirements; EPA will work with the states to approve their plans by the court ordered deadline in the agreement. Under the terms of the consent decree, if a state plan cannot be approved, EPA will determine an appropriate federal plan.

The dates for promulgation of final rules (either accepting or rejecting State plans) begin December 13, 2011 and run through November 15, 2011. The dates for action on the South Dakota regional haze SIP are:
Proposed Promulgation: November 29,2011
Final Promulgation: March 29, 2012

EPA initially issued a rule in 1999 requiring states to submit regional haze plans. These plans were due in December 2007, but no action was taken by the agency in response to the submittals. National Parks Conservation Association and other environmental groups sued the agency in August 2011 to take action on these plans, and the consent decree resolves this litigation. EPA will accept public comment on this agreement for 30 days following publication of a notice in the Federal Register.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Amendments To South Dakota Air Construction Permit Requirements and GHG Pemits

The South Dakota Department of Environment and Natural Resources (DENR) is proposing revisions to administrative rules of South Dakota Chapter 74:36, Air Pollution Control Program. DENR is proposing that the Board of Minerals and Environment adopt revisions to the Administrative Rules of South Dakota (ARSD) Article 74:36 – Air Pollution Control Program to be consistent with federal rules.

The federal Environmental Protection Agency (EPA) adopted revisions to its Prevention of Significant Deterioration and Title V air quality permit programs which established greenhouse gases (GHG) as a regulated air pollutant and a greenhouse gas air emission threshold for when a business is required to obtain a permit. The proposed revisions to ARSD Article 74:36 will be to adopt the federal greenhouse gas tailoring regulations. The proposed revisions to ARSD Article 74:36 will also allow certain businesses to start construction before a construction permit is issued.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Chromium Electroplating and Steel Pickling NESHAP Subparts N and CCC)

EPA has finalized how the agency will address the residual risk and technology reviews conducted for the two national emission standards for hazardous air pollutants (NESHAP) for Chromium Electroplating and Steel Pickling operations (subparts N and CCC). The two NESHAPs include 6 source categories. The review also addresses provisions related to emissions during periods of startup, shutdown, and malfunction. Additionally, EPA has finalized changes to correct editorial errors, makes clarification, and addresses issues with implementation.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Greenhouse Gas Rules for Petroleum and Natural Gas Sectors

U.S. Environmental Protection Agency (EPA) has finalized greenhouse gas (GHG) reporting requirements for the petroleum and natural gas industries as part of the mandatory reporting program. The data collected through the reporting program will provide information about GHG emissions from petroleum and natural gas facilities.

Beginning in 2011, petroleum and natural gas facilities that emit more than 25,000 metric tons of carbon dioxide equivalent a year are required to monitor and report all greenhouse gas emissions to EPA. Data collection for petroleum and natural gas sources will begin January 1, 2011, with first annual reports due to EPA March 31, 2012.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

PSD and NSR Rule For Fugitive Emissions

EPA is proposing to reconsider the final rule titled, "Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NSR): Reconsideration of Inclusion of Fugitive Emissions," published on December 19, 2008.

Through a letter signed on April 24, 2009, EPA granted reconsideration on a petition submitted by National Resources Defense Council (NRDC), as well as an administrative stay. In addition to the three-month administrative stay, EPA proposed and finalized an additional 18 month stay to allow enough time to propose, take public comment on, and issue a final action concerning the inclusion of fugitive emissions in the federal PSD program. The additional 18 month stay became effective on March 31, 2010. EPA will consider the petition for reconsideration, public comments, and information contained in the rulemaking docket to reach a decision on the reconsideration and finalize the rule, which is expected in March 2011.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Interim Guidance On RMP Inspections

The Environmental Protection Agency (EPA) has released interim guidance on the agency’s chemical safety inspections process. Under the interim guidance, EPA inspectors will offer employees and employee representatives the opportunity to participate in chemical safety inspections. In addition, EPA will request that state and local agencies adopt similar procedures under the Risk Management Program.

EPA expects to issue final guidance on participation of employees and employee representative in RMP inspections later this year.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Burning Hazardous Waste As Fuel - Emission Comparable Fuels Rule

EPA has withdrawn the Emission Comparable Fuels (ECF) Rule, which had been finalized in December 2008. The ECF rule sought to reduce regulatory burdens by reclassifying fuels that would otherwise be regulated as hazardous waste, but generate emissions similar to fuel oil when burned.

Due to difficulty of ensuring that emissions from burning ECF are comparable to emissions from burning fuel oil, EPA has now withdrawn the rule. The ECF rule was criticized for potentially allowing hazardous waste to evade the hazardous waste regulatory system, and for being difficult to administer. Industry members have also criticized it because of the detailed conditions for reclassification, which they believe limited the rule’s use.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

SD DENR Multimedia General Permits - Air and Stormwater Permit

South Dakota is one of two States that offer a Multimedia General Permit. There is a clear advantage for permitting agencies to develop general permits to the regulated community. A single permit can be prepared and issued which can be used by many permittees. In most cases, the general permit option benefits the permit holder as well, including:

• Significant reduced time to receive permit(s),


• Clear understanding of permit requirements and limitations before applying for coverage,

Permittees that can not accept the requirements or limitations in the general permit have the option to apply for an individual permit.

Multimedia General Permits incorporate the requirements that apply to different permitting programs. To date, the permitting programs which have been combined are Air Emission Permits and Stormwater Discharge Permits. In this case, permittees that require both an air permit and a stormwater permit apply to be covered under a single Multimedia General Permit.

Because the regulatory requirements for air emission and stormwater discharge permits are sector- or industry-specific, the multimedia general permits offered are usually limited to a fairly narrow industrial sector. And therefore, because a multimedia general permit will apply to a smaller number of potential permittees, many States have not devoted significant resources to develop many such permits.

Two States have developed one or more Multimedia General Permits:

Alabama – (ADEQ): In February 2009, ADEQ promulgated a multimedia general permit for Dry Litter Poultry Animal Feeding Operations – a type of regulated Confined Animal Feeding Operation or CAFO. The general permit incorporates requirements for air emission permitting and compliance and stormwater permitting and compliance.

South Dakota – (SDDENR): DENR has three Multimedia General Permits for asphalt plants, rock crushing operations, and concrete plant. Like the Alabama permit, the South Dakota permit combines air emission and stormwater discharge requirements.

Because permittees need to accept both air emission and stormwater discharge requirements and limits, it becomes even more important for sites considering multimedia general permit coverage carefully review the compliance requirements.

Caltha LLP provides expert environmental consultant services in South Dakota to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Extension of NSR Aggregation Policy Implementation

On February 9, 2009, EPA extended the effective date of the rule final rule modifying the New Source Review (NSR) air permitting program’s “aggregation” policy, to allow for further review. To allow time for the review and the reconsideration, EPA will stay the effective date of this rule for 90 days, until May 18, 2009.

In January 2009, EPA issued a final rule that revised its policy on “aggregation” as it relates NSR under the Clean Air Act. To determine whether NSR applies, this rule directs facilities and permitting authorities to combine, or aggregate, emissions from plant modifications when those projects are related.

NSR is a pre-construction permitting program to ensure ambient air quality standards (AAQS) are maintained when factories, industrial boilers, power plants, etc. are built or modified. The program requires appropriate emission control technology be installed at new or existing sources that are undergoing a major modification. Aggregation refers to the grouping of multiple, related physical or operational changes into a single project for evaluating requirements under the NSR program.

Caltha LLP offers a wide variety of Environmental Training courses developed to meet requirements of numerous regulatory programs. Caltha provides training in the following areas:
[Click on area to request information on upcoming training programs and training options]

RCRA - Hazardous Waste Generator (LQG) Training
HazCom - Hazard Communication Training
Stormwater Pollution Prevention - SWPPP Training [read more about State-specific SWPPP training]
Spill Prevention Control & Countermeasure - SPCC Training
Internal Compliance Audit Training
Internal EMS Audit Training
Contractor Training Programs
Facility Environmental Regulatory Overview Course


For further information contact Caltha LLP at
info@calthacompany.com
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Caltha LLP Website

South Dakota EH&S Consultant – Environmental Consulting Services

Caltha LLP provides expert technical consulting services to private and public sector clients across South Dakota. For further information, click on links below:

South Dakota Air Permit Compliance – Air Emission Permitting Services
South Dakota Stormwater Permit Compliance – Storm Water Permitting Services
South Dakota Environmental Assessment– Phase I (Phase 1) ESA Services
South Dakota Product Stewardship Services
South Dakota Pollution Prevention - Pollution Minimization Services
South Dakota Wastewater Compliance - NPDES Permitting Services

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

South Dakota Contract EHS Staffing - Temporary EH&S Staff

Caltha LLP provides experienced EH&S personnel to fill corporate and facility positions. Positions can be filled on a full-time or part-time basis. Assignments typically range from a few weeks to several months. Temporary staffing can be used for:

Short-term resource needs
Workload leveling
Bridge staffing while positions are being filled
Special projects
New program roll-out
Reporting

Click here to request more information on Temporary EHS staffing.

Caltha is always interested in hearing from EHS professionals with corporate or facility EHS compliance experience. Click here to send an inquiry regarding staffing positions.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

South Dakota Environmental Consultant Services

Caltha LLP is an Environmental Health & Safety (EHS) Consultant serving a broad range in public and private sector clients in South Dakota.

Caltha’s practice areas include:

• Air permitting
• Wastewater permitting
• Stormwater permitting
• Environmental review
• Waste management consulting
• ISO 14001 – Environmental management system consulting
• EH&S Training
• Site assessment & environmental due diligence
• Risk assessment
• Hazard communication
• Product stewardship support
• Temporary EHS staffing

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SDDENR Air Permit Services

Caltha LLP provides a wide range of services related to air emission permitting and compliance. This includes:

State operating permits
Part 70 operating permits
PSD permitting
Registration permits
Air emission inventory
DENR reports
Recordkeeping systems
Employee training
BART determination
Fugative emission determination


For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website