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If your facility is subject to the Clean Water Act Spill Prevention, Control, and Countermeasures requirements (with at least 1,320 gallons of oil on-site), your SPCC plan will likely specify that all oil storage containers must be kept closed.
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How to Manage Universal Waste Lamps in Arizona
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Arizona has adopted most of the federal requirements for universal waste lamps, with a few exceptions. Although the state regulations cannot be less stringent than the federal EPA regulations, the states can add additional requirements. The following are some of the Arizona requirements for lamps that are somewhat different from the EPAÆs.
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Containers holding lamps subject to this rule must be marked ôUniversal Waste Mercury Lamp(s),ö or ôWaste Mercury Lamp(s), or ôUsed Mercury Lamps.ö The word ôMercuryö is not required under the federal regulations. Florida also adds the word ôMercuryö to the marking requirement.
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Crushing lamps is considered a form of treatment. If a lamp crusher is used, an emission control device is required. Crushed lamps must be managed as hazardous waste and count towards your generator status. ADEQ estimates that 350 four-foot lamps equal 100 kg of hazardous waste.
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State Law Requires Contractors Performing Phase I or II Assessments to be Certified
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Arkansas (Senate Bill 936) establishes a professional certification program for individuals who conduct Phase I environmental site assessments and Phase II or Comprehensive Site Assessments (CSAs), as well as those contractors who undertake site investigations, response, and remedial actions pursuant to either the Arkansas Hazardous Waste Management Act (A.C.A. 8-7-201 et seq.), the Arkansas Remedial Action Trust Fund Act (A.C.A. 8-7-501 et seq.), or the Arkansas Voluntary Clean-Up Act (A.C.A. 8-7-1101 et seq.).
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The Arizona Department of Environmental Quality will be drafting a new regulation to set out how these certifications will be implemented. After the regulations are finalized, all site assessment consultants and remedial action contractors must meet the certification standards of the new regulation.
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Kensington Mine Receives a Notice of Violation for Sediment Discharges
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The Alaska Department of Environmental Conservation (DEC) issued a notice of violation to Kensington Mine for exceeding water quality standards from activities inspected at the site on November 3, 2005.
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ôDECÆs authorization for Kensington construction activities requires that the water quality be protected,ö said DECÆs Director of Water Lynn Kent. ôWe inspected a number of sites, and it was apparent that there were problems at two sites where sediment from construction activity was reaching nearby Johnson Creek. In such cases, the permit requires that operations contributing sediments be suspended and the problem fixed.ö
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Kent said that the violations stemmed from two direct discharges of sediment into Johnson Creek. DEC took four water samples, two upstream of construction and two downstream, and found the downstream samples exceeded water quality standards due to erosion and sediment runoff from mine construction activity. Because southeast Alaska gets a lot of rain, significant erosion and sediment control measures are necessary to control storm water runoff and to protect surface waters.
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New Limits on Cruise Ship Emissions in California
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The California Air Resources Board adopted an airborne toxic control measure (ATCM) for onboard cruise ship incinerators. This action implements and supports state legislation (Assembly Bill 471) passed in 2004 that prohibits cruise ships from incinerating waste while operating within three miles of the California coast.
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ôTodayÆs decision by the Board will protect people who live or work near ports from cruise ship emissions that can pose serious health risks,ö said ARB Acting Chair Barbara Riordan. ôCurrently, there are no state or local air pollution control regulations that limit emissions by cruise ships from onboard incinerators.ö
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The ATCM is expected to reduce exposure to emissions from toxic airborne contaminants such as metals, as well as dioxins and furans. The ARBÆs action is expected to reduce the cancer risk from cruise ship incineration to less than two cancer cases per one million people in California. In 1990, the ARB adopted an ATCM for medical waste incinerators to cut emissions of these same toxic compounds
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Travel aboard cruise ships has grown increasingly popular. Based on 2004 data, 11 cruise ship lines had approximately 45 vessels that entered one or more California ports; in all, there were roughly 650 visits to California ports of call. According to a survey of ship operators by ARB staff, cruise ship visits to California ports may increase by 25 percent within the next decade.
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In addition to prohibiting onboard incineration within three miles of the California coast, the ATCM requires cruise ship operators to maintain records containing detailed information for each segment of a voyage where the ship cruises within the three-mile limit, and to keep those records onboard for two years. A cruise ship is defined as a vessel having the capacity to carry 250 or more passengers and having berths or overnight accommodations. Our readers are encouraged to take a cruise to see how well the new requirements are working.
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Proposed Changes to TX Air Permits by Rule
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Notice of this standard permit is also published in the current issue of the Texas Register. These changes are proposed to help reduce excess emissions and improve overall air quality in Texas. In all cases, any authorized portion of normal operations must comply with national ambient air quality standards (NAAQS) and state emission standards, and be protective of public health and welfare. It is the commissionÆs intention to allow predictable, preventative MSS operations to be authorized. This would include periodic plant turnarounds, which are very extensive facility or plant-wide maintenance events that occur every few years. It would also allow companies to group the MSS emissions of similar facilities and activities into one authorization.
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The commission is proposing to revise the requirements for authorization by permit by rule (PBR). These revisions include limiting emissions of carbon monoxide (CO) and nitrogen oxides (NOx) to 100 tons per year (tpy) per PBR claim, and limiting emissions of hazardous air pollutants (HAPs) to 10 tpy for an individual HAP and 25 tpy for combined HAPs. The commission proposes these changes to prohibit use of PBRs to authorize major sources. The commission is also proposing to repeal 106.261 and 106.262 and replace them with a new 106.261 that contains updated technical requirements and emission limitations. The proposed changes to 106.261 would further increase protectiveness of that PBR, which was found to be used frequently at some facilities.
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In addition, the commission proposes amendments to 106.2, 106.4, 106.6, 106.8, and 106.50 that are intended to more effectively focus commission resources, update administrative and technical requirements for certain PBRs, streamline the air quality PBR process where appropriate, and address unnecessary registration and fee requirements.
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á revisions to its state implementation plan (SIP) that will authorize all types of routine operations (production, maintenance, start-up and shutdown (MSS), and certain anticipated and quantifiable emissions) under 30 TAC Chapters 101 and 116.
Florida Suspends Preapproved Advanced Cleanups
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FloridaÆs Preapproved Advanced Cleanup Program is designed provide an opportunity for site rehabilitation to be conducted on a limited basis at contaminated sites, in advance of a site's priority ranking, to facilitate property transactions or public works projects. When there is an actual application period announcement, an application shall be submitted to the department.
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The Department of Environmental Protection announced that it will not have a PAC application period between November 1, 2005, and December 31, 2005. Due to the limited number of PAC applications received during the previous PAC application period and the current backlog of work orders awaiting funding availability, the DEP has decided to keep trust fund monies available to fund approved work orders.
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Indiana Issues NOVs for Failure to Submit Hazardous Waste Annual Reports
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The Indiana Department of Environmental Management recently issued notices of violation to the following companies to submit annual manifest reports: United Parcel Service, Chip Ganassi Racing Teams, Inc., Slone Collision Center, Universal Blower Pac, Keller Manufacturing Co, Spears Automotive, Old Hickory Furniture Company, and American Finishing Resources.
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Michigan Fines Contractor for Monitoring Violations
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MichiganÆs Department of Environmental Quality has reached a settlement with NSI Engineers & Contractors, Inc., an environmental engineering and consulting firm based in Spring Lake, MI. The settlement stems from NSIECÆs failure to sample and report wastewater discharge monitoring data as required by the National Pollutant Discharge Elimination System permit that the company was issued for a groundwater remediation project being conducted in Alcona County.
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ôThe state must rely on permit holders to properly monitor their discharges and report the results," said DEQ Director Steven E. Chester. "This is essential to ensure that the operation meets the limits established by law to protect our water quality and the health of MichiganÆs citizens.ö
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NSIEC was contracted by the State of Michigan to perform a groundwater cleanup project, funded by the Clean Michigan Initiative, on the site of a former service station located in Lincoln. NSIEC failed to sample various discharge parameters on 12 occasions and failed to submit monitoring data by the required permit deadline for the entire time period the cleanup project was in operation. NSIEC has agreed to pay $27,717 in civil fines and avoided costs, and has agreed to pay partial reimbursement to the state for the costs of investigation and enforcement of the case.
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Kansas DonÆt Spoil It: 2006 Calendar
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The Kansas Department of Health and Environment, Bureau of Waste Management, gave Kansas school students (grades K-12) a chance to use their artistic talent to help raise environmental awareness, have their artwork featured in a calendar distributed statewide; get their picture taken with the Governor of Kansas, win a $50 U.S.Savings Bond and "Kansas Don't Spoil It" merchandise, and help educate others about how to preserve the environment. One piece of student art is featured each month of the calendar year. The grand prize winner's work is featured on the cover of the 2006 calendar.
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EPA Takes Five Enforcement Actions against New England Companies
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EPA has taken legal action against five New England companies ù four in Mass. and one in NH, for failing to comply with federal chemical emergency response and prevention laws. The companies have allegedly violated community right-to-know and chemical safety laws that are designed to reduce the risk of accidents from hazardous chemicals. The facilities face penalties and have spent more than $1.5 million in safety improvements.
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ôIn the wake of the Gulf Coast hurricanes, and for the recent flooding in New Hampshire and Taunton, Mass., federal and state emergency responders relied heavily on the information contained in chemical management databases for determining reconnaissance and response priorities,ö said Robert W. Varney, administrator of EPAÆs New England office. ôHaving up-to-date and accurate information about chemical storage and releases is not just an important environmental concern û it is vital for our national security and the health and welfare of citizens that live near these facilities. It is critical that companies continually analyze the risks that their chemicals pose and act to prevent releases from occurring.ö
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The events of September 11, and Hurricanes Katrina and Rita, have highlighted the importance of preparing for, preventing and responding quickly to chemical releases in our communities. A number of large and small chemical releases by local companies have led EPAÆs New England office to intensify efforts to make sure manufacturers report chemical use, take the necessary steps to prevent chemical accidents, and immediately report releases, as required by the Emergency Planning and Community Right-to-Know Act (EPCRA), the Clean Air Act (CAA), and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
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EPAÆs recent enforcement actions include:
- áááááááá On November 18, Crystal Warehouse Corporation, Wilmington, Mass, agreed to pay $17,973 to settle claims that it violated federal chemical inventory reporting regulations. Crystal Warehouse stores hydrofluoric acid, which is classified as an extremely hazardous substance under EPCRA. According to EPA, the manufacturer failed to file required inventory forms for this chemical from 2002 until 2004 even though it stored more than 10 times the reporting threshold.
- áááááááá On Sept. 23, EPA issued a complaint proposing that Nova Chemicals, Indian Orchard, Mass, pay $39,663 for alleged CAA and CERCLA violations found during an investigation of a Jan. 7, 2004 chemical accident that released 4,500 pounds of styrene monomer to the environment. EPA alleged that Nova failed to design and maintain a safe facility or to take steps necessary to prevent a release; minimize the consequences of an accidental release; and failed to immediately notify the National Response Center of the release. The penalty actions taken are particularly notable, as they are the first cases nationally where EPA has proposed administrative penalties under the ôGeneral Duty Clauseö of the CAA. The General Duty Clause provides that owners and operators of stationary sources that produce, process, handle or store extremely hazardous substances, have a general duty to identify potential hazards and to design and maintain safe facilities to minimize consequences of accidental releases. Facilities that do not meet these standards may expose people and property to extremely hazardous substances.
- áááááááá On September 30, EPA issued an administrative complaint and order against Callahan Chemical Company, Walpole, Mass, a bulk chemical delivery company, proposing a $113,640 penalty. The complaint cites the company for violations of the General Duty Clause of the CAA by failing to employ adequate safeguards to prevent and mitigate two releases of acetone û one of about 1,300 gallons on December 6, 2004 and another of 200 gallons on January 14, 2005. Both spills allegedly occurred because of human error, and the company was cited for failing to follow accepted safe operating procedures. EPA also alleged that Callahan violated provisions of CERCLA and EPCRA by failing to give timely notification of the first release to the National Response Center and the local emergency planning committee.
- áááááááá Northeast Refrigerated Terminals, Middleboro, Mass agreed on September 27 to pay $18,045 and spend an additional $30,000 to make environmental improvements after anhydrous ammonia was released from a faulty valve at the facility in April 2004. The company has installed an advanced ammonia detection and automatic shut-down system. Although there were no reported injuries, the local fire department responded and evacuated 30 to 40 homes in the area. After learning about the incident, EPA conducted an inspection and filed a complaint on June 29, citing the companyÆs failure to have a risk management program, notify the National Response Center of the release, and file required chemical inventory forms.
- áááááááá Osram Sylvania Products, Exeter, NH, a maker of glass and ceramic products, agreed to pay $14,000 to settle claims that it violated federal clean air and chemical release notification rules in 2003. According to EPA, OSRAM violated the CAA and CERCLA by failing to have an adequate risk management plan for a hydrofluoric acid process at its facility and by failing to properly notify the National Response Center of an accidental release of hydrofluoric acid in May 2003. In the settlement, finalized last June, Osram neither admitted nor denied the allegations and there were no injuries reported as a result of the release. The alleged violations were discovered during an EPA audit of the facility and an investigation of the hydrofluoric acid release. The investigation revealed that human error likely led to the release.
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Most facilities can prevent similar enforcement actions by:
- áááááááá Working closely with local emergency planning committees to make them aware of chemicals they use and store at their facilities.
- áááááááá Being prudent about assessing the potential for chemical hazards, and taking steps to prevent releases, such as adding redundant controls where control failure results in significant risks
- áááááááá Reporting significant releases to emergency responders and the National Response Center immediately. Do not wait to calculate the amount of chemical released. You may be fined for late reporting if EPA determines that you should have known that the release exceeded reportable quantities of chemical before precise calculations are complete.
- áááááááá Ensuring that you have a system for ensuring compliance with EPCRA and other chemical safety laws, including the CAA and OSHA. The system should survive staff turnover.
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Oregon DEQ Penalizes Portland Nearly $450,000 for Sewer Overflows
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The Oregon Department of Environmental Quality (DEQ) has issued penalties totaling $449,800 against the City of Portland for numerous raw sewage overflows into the Willamette River and several streams that flow into the Willamette. Sixty-seven discharges over a period of about four and a half years occurred from the cityÆs sewage collection system at multiple locations throughout Portland. Discharges also were reported to the Columbia River and Columbia Slough. The 67 discharges totaled about 1,875,000 gallons of sewage. Most of the overflows were caused by blockages in pipes carrying sewage to treatment plants, DEQ water quality officials said.
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ôWhile we appreciate the progress made by the city in constructing a new system to control pollution, it is essential that the city make every effort to prevent raw sewage discharges to the Willamette and its tributaries,ö said DEQ Director Stephanie Hallock.
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The discharges occurred between March 2001 and November 2005 into the Willamette River and several of its tributaries, including Stephens, Fanno, Johnson and Cedar Mill creeks, as well as the Columbia Slough and Columbia River. Most of the discharges ranged between 1,000 and 10,000 gallons.
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The largest discharges included a 660,000-gallon discharge into the Willamette near 3001 SW Moody St. on Sept. 8, 2005 and a 511,714-gallon discharge to Fanno Creek near 6900 SW Railroad on Oct. 4, 2005. Since 1998, DEQ has fined the city seven times for water quality violations.
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Oregon environmental law prohibits sewage overflows to state waters because sewage contains disease-carrying bacteria that are a threat to public health and the environment. Many of these discharges occurred during dry weather, when there was a greater likelihood of human contact with sewage in local streams and the Willamette. Sewage is also a significant water pollutant that can harm aquatic life and cause public waters to be unsuitable for recreation, commercial and agricultural uses.
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DEQ officials noted that the Willamette River is already significantly polluted by wet-weather discharge of raw sewage from the cityÆs combined sewers. These combined sewer overflows (CSOs) are not subject to DEQ enforcement action, as outlined in an agreement between DEQ and the city to allow the city to complete timely construction of its updated CSO facilities.
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DEQ has worked closely with the city to take a holistic look at its CSOs, stormwater management and sewage collection system maintenance problems to address water quality issues. The city has responded to individual overflows in a timely manner, DEQ water quality officials noted.
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Zero Oil Spills Goal of WashingtonÆs Proposed Oil-Transfer Regulations
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Changes to state environmental regulations proposed by the Washington state Department of Ecology (Ecology) should reduce the risk of oil spills into Washington's waters during oil transfers. Aiming for a goal of zero oil spills, Ecology developed the draft rules with a special advisory committee made up of oil industry, representatives, and citizen advocates.
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Changes in state oil-transfer regulations were requested by the 2004 Legislature following the Dec. 30, 2003, spill of 4,700 gallons of heavy oil into Puget Sound while a tank barge was receiving oil cargo from a Richmond Beach oil-storage facility near Seattle.
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"We believe these new standards can make a significant difference in the amount of oil that is both catastrophically and cumulatively dripped, leaked and spilled into our waters," said Dale Jensen, manager of Ecology's spills program.
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Jensen said his agency is in the early stages of working with the many industries affected by the changes. "We want to get advice about what changes make sense," he said. "We are still touching bases with many sectors in the oil-transfer world, such as small marinas and other fueling facilities, so we still have a lot of work ahead to be inclusive." Jensen said Ecology is not seeking public comments on the changes yet, but that it would in the coming months.
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Annually, billions of gallons of oil are transferred in thousands of separate transactions at hundreds of locations across the state. Most of these transfers take place over or near water. Each poses a risk to the environment that can be reduced or eliminated through prevention and response measures. The proposed changes include:
- áááááááá Advance notice to the state prior to oil transfers over state waters.
- áááááááá New guidance about "pre-booming," which is the pre-positioning of oil-containment devices in the water to contain and collect oil before it can spread and hit the shoreline.
- áááááááá Improved training for oil deliverers, and more response equipment kept on hand at transfer locations.
- áááááááá Expand oil-spill prevention and response planning to include mobile operations (tank trucks).
- áááááááá Set simple standards for response and training at marinas and small facilities that deliver fuel to commercial vessels.
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The new rules do not affect recreational or pleasure boats. Ecology's "Spills Aren't Slick" campaign targets this group. Ecology has sent posters to marinas across the state with advice to report all spills immediately by calling 800-OILS-911. Ecology's goal is to finalize the oil-transfer rule by June 2006.
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Contractor Fined $14,000 for Polluting Creek
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The Washington Department of Ecology (Ecology) has fined West Coast, Inc. of Everett for a landslide that muddied Portage Creek in Arlington and for other violations earlier this year.
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The company's contractor pumped muddy storm water from a construction site on Crown Ridge Boulevard onto the bank of a ravine above the creek on April 6. The bank eroded into the creek. Citizens noticed muddy water flowing into Pioneer Ponds and contacted the City of Arlington.
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City inspectors traced the source of muddy water to the West Coast construction site, cited the contractor, and notified Ecology. The next day Ecology responders inspected the eroded bank and noticed muddy water flowing onto the boulevard. The water entered unprotected storm drains that flow into a detention pond that empties into a tributary of Portage Creek. The pumping to the ravine had been discontinued.
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"This was completely avoidable," said Kevin Fitzpatrick, a manager in Ecology's water-quality program. "West Coast's stormwater permit for the project requires specific steps to prevent muddy water releases. Contractors on comparable projects use similar practices every day."
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Ecology directed the contractor to take corrective steps and returned to inspect the site two more times. The contractor had installed a filtering system to treat water that discharged into the street, but the water continued to violate state water quality standards.
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Portage Creek is a salmon-bearing stream. It runs through the Portage Creek Wildlife Sanctuary, a county park. Local organizations and hundreds of volunteers have planted trees along the stream - in the park and elsewhere - to restore salmon habitat.
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Ohio EPA, DOT Resolve Drinking Water Violations at Rest Areas
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Drinking water quality and monitoring at three highway rest areas will improve under an agreement between Ohio EPA and the Ohio Department of Transportation.
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The agreement requires drinking water at northbound and southbound rest areas on Interstate 75 in Hancock County and the east rest area on Interstate 76 in Portage County to address total coliform bacteria contamination. It requires regular monitoring for total coliform bacteria, notification to the public about past violations and submission of complete monthly operation reports.
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Corrective measures also are required to address drinking water violations at six other rest areas statewide and the District 5 office and garage in Licking County.
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The water supplies at the highway rest areas are subject to specific treatment and monitoring requirements. All three rest areas had samples that tested positive for total coliform bacteria in the past. The presence of total coliform is an indication that other pathogens may be present in the water.
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ODOT failed to conduct routine sampling for total coliform at the Interstate 75 rest areas and failed to conduct the required follow-up sampling at all three rest areas after total coliform was detected. The agency also failed to submit timely operation reports to Ohio EPA.
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ODOT agreed to pay a $110,400 civil penalty for the violations. Of that, $22,080 will be paid to Ohio EPA's Clean Diesel School Bus Fund and $2,400 will be contributed to the Local Technical Assistance Program for four water quality courses for ODOT employees. Additionally, $58,320 of the penalty will be used by ODOT to hire a laboratory to conduct daily water monitoring at the Hancock County rest areas. The remaining $27,600 civil penalty will go to Ohio EPA's drinking water protection fund.
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California Foam Manufacturer to Pay Fine and Close Site Rather than Install Pollution Control Equipment
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As part of a recent settlement with the EPA and the South Coast Air Quality Management District, Falcon Foam will pay $369,000 for air pollution violations. Under the terms of the joint settlement agreement, Falcon Foam in Los Angeles decided to terminate its expanded polystyrene foam manufacturing operations by December 31, 2005 rather than install emissions controls.
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The SCAQMD, which has jurisdiction over air permits in the Los Angeles Basin, requires that manufacturing and storage emissions be limited to no more than 2.4 lb of volatile organic compounds per 100 lb of raw materials used in the process or be controlled through the use of an adequate air pollution control device. Falcon Foam, a division of Atlas Roofing, did not meet this limit.
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"Companies like Falcon Foam must comply with the Clean Air Act and local air quality rules to prevent volatile organic compounds from contributing to air pollution," said Deborah Jordan, the EPA's Air Division director for the Pacific Southwest region. "We will continue to pursue joint enforcement actions with local air districts in order to protect air quality."
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Pay as You Throw
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Traditionally, residents pay for waste collection through property taxes or a fixed fee, regardless of how muchùor how littleùtrash they generate. Pay-as-you-throw (PAYT) breaks with tradition by treating trash services just like electricity, gas, and other utilities. Households pay a variable rate depending on the amount of service they use.
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Most communities with PAYT charge residents a fee for each bag or can of waste they generate. In a small number of communities, residents are billed based on the weight of their trash. Either way, these programs are simple and fair. The less you throw away, the less you pay. This creates a direct economic incentive to recycle more and to generate less waste. Over 5,000 communities use this innovative system.
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Public Comment Period Extended on Proposal to Help States Meet Fine Particle Standards
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EPA is extending until Jan. 31, 2006 the public comment period on the agency's proposed rule outlining steps that state, local and tribal governments must take to reduce fine particle pollution (PM2.5) in areas that do not meet EPA's health-based air quality standards. The proposed rule, known as the PM2.5 Implementation Rule, describes the planning framework and requirements for state, local and tribal governments to consider when developing their plans to reduce air pollution to meet the PM2.5 standards. Areas meeting the standard must show how they will ensure that PM2.5 levels remain below the standards.
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EPA will hold a public hearing on the proposed rule from 9 a.m. to 5 p.m., Wednesday, Nov. 30, at the Capitol Hilton, 1001 16th St. N.W., Washington, D.C. 20036.
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EPA To Grant Additional Comment Time on the Clean Air Interstate Rule
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EPA is granting the public additional time to comment on certain aspects of the Clean Air Interstate Rule (CAIR). CAIR requires 28 states and the District of Columbia to reduce emissions of nitrogen oxides (NOx) and sulfur dioxide (SO2) from power plants. This action will not delay implementation of the rule, which is intended to achieve the largest reduction in air pollution in more than a decade. EPA issued the final CAIR on March 10, 2005.
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EPA has received 11 requests from states, environmental groups and power companies to reconsider certain parts of the final CAIR rule. The agency is confident that the rule's basis is sound, however, it has agreed to provide an additional opportunity for public comment on the following four issues:
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1. Analysis done by EPA to address claims regarding alleged inequities resulting from the method used to allocate SO2 emissions allowances to sources for those states that participate in EPA's trading program
2. The method used to establish state NOx allocation budgets, specifically the use of fuel adjustment factors
3. Certain parts of the modeling EPA used to determine whether Minnesota's PM2.5 emissions require inclusion in the CAIR region
4. EPA's determination that Florida should be included in the CAIR region for ozone
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EPA will hold a public hearing on these four issues on Dec. 14, 2005 in Washington, D.C. and will continue to accept public comments until Jan. 13, 2006. The agency expects to take final action on these issues by March 15, 2006.
Environmental News
Trivia Question of the Week
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According to the California Integrated Waste Management Board, how much wrapping paper and other holiday related waste between Thanksgiving and the New Year?
a. 1 million pounds a week
b. 1 million pounds a day
c. 10 million tons a day
d. 1 million tons a week
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