What’s on EPA’s Agenda?

October 22, 2018

In the past, EPA and other federal agencies published their regulatory agendas every six months. The current administration has renamed the publication to “Unified Agenda of Regulatory and Deregulatory Actions” in order to embrace its commitment to remove two regulations for every new regulation that is enacted. The following are some of the proposals listed on EPA’s agenda:

NPDES Updates	EPA is developing a final rulemaking on the remaining subset of provisions included in the Agency's proposal to update specific elements of the existing National Pollutant Discharge Elimination System (NPDES) regulations. The rule would make additional targeted revisions to outdated application, permitting, monitoring, and reporting requirements in order to eliminate inconsistencies between regulations and application forms, improve permit documentation and transparency, and clarify existing regulations.
Direct Discharge Permits	Section 401 of the Clean Water Act requires a Federal permit to conduct an activity which may result in a discharge into a water of the US, and a certification from the state in which the discharge would originate that the discharge will comply with applicable effluent limitations, water quality standards, toxic and pretreatment effluent standards as well as other appropriate provisions of state law. EPA is considering whether the Section 401 certification process would benefit from updated rulemaking to promote nationwide consistency and regulatory certainty for states, permit applicants, and other stakeholders.
Carcinogens in Drinking Water	EPA plans to develop one national primary drinking water regulation (NPDWR) covering up to 16 carcinogenic volatile organic compounds (VOCs) as a group, rather than individually, in order to provide public health protections more quickly and also to allow utilities to more effectively and efficiently plan for improvements. Perchloroethylene (PCE) and trichlorethylene (TCE), which the EPA determined to be candidates for regulatory revision under the second six-year review of the existing NPDWRs, would be included in the VOC drinking water standard. Besides PCE and TCE, the group may include up to six additional regulated VOCs and up to eight unregulated VOCs from the EPA's Contaminant Candidate List.
EPCRA Streamlining	EPA is considering addressing Tier 2 reporting thresholds for rock salt, sand, gravel and other chemicals that may pose minimal risk. By proposing to provide relief from routine reporting of substances with minimal hazards and minimal risk, State and local officials may be able focus on chemicals that may pose more significant hazard or present greater risks to the community.
Greenhouse Gas Permits	EPA is planning to establish a Greenhouse Gas (GHG) Significant Emission Rate (SER) under the Prevention of Significant Deterioration (PSD) air permitting program and finalize certain revisions to the provisions of the PSD and Title V GHG Tailoring Rule. The GHG SER would establish an appropriate threshold level below which Best Available Control Technology (BACT) is not required for a source's GHG emissions. The Tailoring Rule revisions will allow us to revise certain GHG permitting regulatory provisions, which include the PSD GHG Plantwide Applicability Limits (PALs), and will also implement a recent Court of Appeals for the District of Columbia decision that ordered, among other things, that the Tailoring Rule regulations under review be vacated to the extent they require a stationary source to obtain a title V permit solely because the source emits or has the potential to emit GHG above the applicable thresholds.
Stratospheric Ozone	EPA is planning to revise the listing under SNAP Rule 20 for aerosol propellant use of HFC-134a as it pertains to bear sprays and certain other fog-type defense aerosol sprays.
CO2 Emissions	This proposed action will establish the treatment of biogenic carbon dioxide (CO2) emissions from the use of certain biomass feedstocks at stationary sources under the Prevention of Significant Deterioration (PSD) and title V permitting programs. The proposed action will be based on the Agency's policy regarding the treatment of biogenic CO2 emissions under the Clean Air Act.
Boiler NESHAP	On January 31, 2013, EPA promulgated amendments to the NESHAP for Major Source: Industrial, Commercial, and Institutional Boilers and Process Heaters. Environmental groups and industry filed for judicial review of the amended final rule. The court vacated some of the MACT standards certain industry subcategories. This proposal would address the issues that were remanded in the court decisions and give an opportunity for public comment on the EPA's responses.
TCE Vapor Degreasing	Section 6(a) of the Toxic Substances Control Act (TSCA) provides authority for EPA to ban or restrict the manufacture (including import), processing, distribution in commerce, and use of chemical substances, as well as any manner or method of disposal. Section 26(l)(4) of TSCA authorizes EPA to issue rules under TSCA section 6 for chemicals listed in the 2014 update to the TSCA Work Plan for Chemical Assessments for which EPA published completed risk assessments prior to June 22, 2016, consistent with the scope of the completed risk assessment. In the June 2014 TSCA Work Plan Chemical Risk Assessment for TCE, EPA characterized risks from the use of TCE in commercial degreasing and in some consumer uses. EPA has preliminarily determined that these risks are unreasonable risks. On January 19, 2017, EPA proposed to prohibit the manufacture, processing, distribution in commerce, or commercial use of TCE in vapor degreasing. A separate action (RIN 2070-AK03), published on December 16, 2016, proposed to address the unreasonable risks from TCE when used as a spotting agent in dry cleaning and in commercial and consumer aerosol spray degreasers.
TCE SNUR	EPA is developing a significant new use rule (SNUR) under section 5(a)(2) of the Toxic Substances Control Act (TSCA) for trichlorethylene (TCE). The SNUR would require manufacturers (including importers) and processers of TCE for an activity that is designated as a significant new use to notify EPA at least 90 days before commencing that activity. The notification would initiate EPA's evaluation of the intended use within the applicable review period. Manufacture and processing for the significant new use would be unable to commence until EPA has conducted a review of the notice, made an appropriate determination on the notice, and taken such actions as are required in association with that determination.
NMP Regulation under TSCA	Section 6(a) of TSCA enables EPA to ban or restrict the manufacture (including import), processing, distribution in commerce, and use of chemical substances, as well as any manner or method of disposal. Section 26(l)(4) of TSCA authorizes EPA to issue rules under TSCA section 6 for chemicals listed in the 2014 update to the TSCA Work Plan for Chemical. On January 19, 2017, EPA preliminarily determined that the use of NMP in paint and coating removal poses an unreasonable risk of injury to health. EPA also co-proposed two options for NMP in paint and coating removal. The first co-proposal would prohibit the manufacture, processing, and distribution in commerce of NMP for all consumer and most commercial paint and coating removal and the use of NMP for most commercial paint and coating removal. The second co-proposal would require commercial users of NMP for paint and coating removal to establish a worker protection program and not use paint and coating removal products that contain greater than 35% NMP by weight, with certain exceptions; and require processors of products containing NMP for paint and coating removal to reformulate products such that they do not exceed 35% NMP by weight, to identify gloves that provide effective protection for the formulation, and to provide warnings and instructions on any paint and coating removal products containing NMP.
Hazardous Waste Pharmaceuticals	Some pharmaceuticals are regulated as hazardous waste under RCRA. Healthcare (and associated) facilities that generate hazardous waste pharmaceuticals. EPA is considering a final rule that will revise the regulations to improve management and disposal of hazardous waste pharmaceuticals. The revisions are also intended to clarify regulation of a major mechanism used by healthcare facilities for management of unused and/or expired pharmaceuticals, known as reverse distribution.
Classification of Aerosols as Universal Waste	EPA has proposed to classify hazardous waste aerosol cans as universal waste. The streamlined universal waste regulations are expected to ease regulatory burdens on retail stores and others that discard aerosol cans, promote the collection and recycling of aerosol cans, and ncourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.
Recalled Airbags	In order to address the urgent public health issue posed by recalled Takata airbag inflators that are currently installed in vehicles, EPA is developing an interim final rule to facilitate the speed and efficiency of the Takata airbag recall by exempting the collection of defective airbags and airbag inflators from auto dealers and scrap yards from hazardous waste requirements, so long as certain conditions are met to ensure the airbags and airbag inflators are safely disposed.
Reclassification of CAA Major Sources	These amendments would address when a major source can become an area source, and, thus, become not subject to national emission standards for hazardous air pollutants (NESHAP) for major sources under Clean Air Act (CAA) section 112. The amendments will implement the EPA's interpretation CAA section 112 definitions of "major" and "area" sources as discussed in the January 2018 William Wehrum memorandum titled "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act." (See 83 FR 5543, February 8, 2018.)
Motor Vehicle Air Conditioner Servicing	This action would establish servicing and equipment provisions, as required by the Clean Air Act, for new alternative refrigerants in the motor vehicle air conditioning end-use currently listed as acceptable subject to use conditions under the Significant New Alternatives Policy (SNAP) program and being used in cars on the road today.

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Proposed EPA Uranium Environmental and Health Safeguards Withdrawn

In 1983, EPA issued standards in response to the statutory requirements of the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA). Since the standards were originally issued, they have been amended several times. The Obama Administration had proposed updates to the 1983 standards, which have now been withdrawn by the current Administration.

Acting EPA Administrator Andrew Wheeler said, “In a rush to regulate during the waning hours of the previous administration, the Agency proposed a regulation that would have imposed significant burdens on uranium miners and the communities they support, Today’s action is an important step in rebalancing EPA’s role with the Nuclear Regulatory Commission’s with respect to protecting public health and the environment alongside supporting modern methods of uranium extraction.”

“Today’s announcement is the right decision,” said Senate Environment and Public Works Chairman John Barrasso. “The Nuclear Regulatory Commission – our nation’s principal nuclear regulator – has said there is no health or safety justification for EPA’s midnight rule. The NRC has regulated in situ uranium recovery for nearly 40 years. The agency has never found an instance of ground water contamination that would be addressed by this rule. I’m glad the Environmental Protection Agency has acknowledged this reality. I applaud it for withdrawing this punishing and unnecessary regulation on America’s uranium producers.”

EPA released a statement indicating that the Agency believes existing regulatory structures are sufficient at this time to ensure the protection of human health and the environment at current uranium in-situ recovery (ISR) activities. In addition to questions about legal authority and EPA's belief that regulatory structures already in place are sufficiently protective under current conditions, EPA is withdrawing the proposed regulation because the once anticipated influx of new ISR license applications is not likely to materialize.

Short EPA Survey to Help Improve Its Toxics Release Inventory Website

The EPA Toxics Release Inventory (TRI) Program wants to make sure it is easy to find the information needed on the TRI website, and that the content of the website is complete and understandable. To improve their website, EPA released a short survey to inform on what they like about the TRI website and how they can improve it. The survey will be available until November 5, 2018.

$77,093 Fine for Improper Storage of Hazardous Waste

An Ohio company has agreed to come into compliance with state and federal hazardous waste laws and to pay a penalty of $77,093 to settle claims by the US Environmental Protection Agency that it violated state and federal hazardous waste laws at its facility in North Clarendon, Vt.

Ellison Holdings, the owner of the Vermont facility, and Ellison Surface Technologies, the operator of the facility, agreed to correct all violations of the federal Resource Conservation and Recovery Act and state hazardous waste management laws and to stay in compliance with both laws.

"Protecting New Englanders from hazardous chemicals is a top priority at EPA," said EPA Regional Administrator Alexandra Dunn. "It's important to make sure our regulated community is in compliance with laws that keep facilities safe for workers and the community, which is why the settlement with Ellison Holdings is so important."

"We strive to work with companies to ensure they can operate in compliance with environmental regulations, and take responsibility for protecting public health and the health of our land, air and water," said Vermont Department of Environmental Conservation Commissioner Emily Boedecker. "Taking care to comply with environmental requirements helps to prevent contamination, and is good for business and good for Vermont."

EPA inspectors found that the Ellison Surface Technologies Vermont facility was storing numerous drums of hazardous waste for more than 180 days without a license. EPA also found that they were storing incompatible hazardous waste without segregating them. These sorts of violations are important to the health and safety of facility workers and the local community because this sort of storage could result in hazardous waste being released into the environment. This settlement will reduce the likelihood of a release of hazardous waste to the surrounding North Clarendon community.

The company, headquartered in Mason, Ohio, makes coatings for industrial and aerospace parts. Ellison operates another facility in Vermont, as well as facilities in Kentucky, Tennessee, Canada and Mexico. The North Clarendon facility is a small quantity generator of hazardous waste, including hydrochloric and nitric acid, sludge from the acetone filtration process and universal wastes including batteries and light bulbs.

Heritage Environmental Services to Spend over $500,000 to Settle Incinerator Violations

The Department of Justice and the EPA entered into a settlement agreement with Heritage Thermal Services Inc., a subsidiary of Heritage Environmental Services LLC, resolving allegations that the company violated the Clean Air Act at its hazardous waste incinerator located in East Liverpool, Ohio.

Some of the alleged violations arose from an explosion at the incinerator on July 13, 2013, which ruptured incinerator ducting, releasing untreated flue gas, steam, and boiler ash beyond the incinerator’s fence line.

“Today’s settlement will bring the Heritage plant into compliance with Clean Air Act regulations, preventing incidents like the July 2013 explosion,” said EPA Office of Enforcement and Compliance Assurance Associate Administrator Susan Bodine. “In addition, Heritage will perform a project that will help to protect people, especially children, from the harmful health effects of lead exposure.”

“The July 2013 explosion at the Heritage incinerator was a consequence of systemic failures to comply with the Clean Air Act, which protects communities and American workers from harmful releases of air pollutants,” said Acting Assistant Attorney General Jeffrey H. Wood. “This settlement requires the company to comply with Clean Air Act requirements and to perform important lead abatement work to make the East Liverpool community a safer and healthier place for workers and residents.”

The U.S. alleges that Heritage violated the Clean Air Act on hundreds of days beginning in November 2010 and continuing thereafter, including violations emanating from the July 13, 2013 explosion. The violations include failures to comply with applicable emissions limits, operating parameter limits, and other Clean Air Act regulatory requirements.

The settlement, which was lodged in federal court for the Northern District of Ohio, requires that Heritage undertake extensive measures designed to bring its operations into compliance with the Clean Air Act. For instance, Heritage will not accept certain wastes that cause the kind of excess emissions that contributed to the July 2013 incident. Heritage is also required to investigate and implement corrective measures to reduce future emissions and will study whether other changes in its production process would also prevent Clean Air Act violations. Heritage is also required to pay a penalty of $288,000, and to spend at least $302,500 performing lead hazard abatement work at properties within 25 miles of East Liverpool, Ohio where the owners cannot afford to undertake lead abatement or replacement of lead water service lines.

The Department of Justice and EPA will hold a public meeting at the East Liverpool City Council Chambers on November 7, 2018, from 6:30 pm to 8:30 pm EDT to provide the public with information about the settlement and to answer questions by the public.

The proposed settlement is subject to a 30-day public comment period and final court approval.

Ohio Waste Exchange Is a Valuable Resource

Ohio EPA Director Craig W. Butler highlighted early successes of the Ohio Materials Marketplace (OMM) and invited businesses and organizations across the state to join the free online service for advertising and acquiring potentially useful products and materials that might otherwise be destined for disposal in landfills.

“Ohio businesses diverted 3.5 million pounds of ‘waste material’ from landfills this year as a result of exchanges on our marketplace, saving businesses an estimated $200,000 in disposal costs,” Director Butler said. “I encourage large and small businesses and organizations throughout Ohio to join this free service. It makes good business sense and represents a new way of thinking about how we can reuse materials that might otherwise be thrown away in landfills.”

Launched by Ohio EPA in 2017, more than 750 Ohio businesses and organizations have signed up for OMM, which currently features 155 items listed as available and several hundred materials listed as wanted.

Among the diverse items exchanged between businesses this year are wood pallets, plastic and steel storage containers/drums, expanded polypropylene packaging, spent lime and industrial machinery.

OMM is managed by Ohio EPA staff, who market the site to potential users, verify that users (and items posted) meet qualifications to participate, and actively work to facilitate connections between users. The site is specifically designed as a business-to-business or business-to-community exchange for recyclables and reusable materials. Products and byproducts recirculate productively through reuse, remanufacturing, recycling and maintenance. Users of OMM can make or save money by finding a market for their unwanted materials and reducing disposal costs; buyers save money by accessing sellers’ discounted (or free) materials; and Ohio’s environment benefits by removing more material from the waste stream.

The program was launched with support from the not-for-profit United States Business Council for Sustainable Development. For more information or to sign up for the Ohio Materials Marketplace go to: ohio.materialsmarketplace.org.

Turning Greenhouse Gases into Useful Products

A new report from the National Academies of Sciences, Engineering, and Medicine outlines a research agenda for improving the commercial viability of technologies that turn greenhouse gases from the burning of fossil fuels into useful products such as fuels, construction materials, and chemicals. The report urges the U.S. government and private sector to support research and development to advance these technologies and coordinate their efforts.

“Carbon utilization technologies have a role to play in future carbon management, offering the potential to reduce emissions and in some cases generate positive economic returns,” said David Allen, chair of the committee that conducted the study and wrote the report, and Gertz Regents Professor of Chemical Engineering and director of the Center for Energy and Environmental Resources at the University of Texas, Austin.

Reducing greenhouse gas emissions in a way that limits increases in global temperature will require a range of approaches, the report notes. Some, such as expanding the use of cleaner energy sources, will prevent emissions. Other approaches involve capturing greenhouse gases and either sequestering them or finding productive uses for them.

Previous assessments have concluded that roughly 3.6 billion tons of carbon dioxide per year – more than 10 percent of current global carbon dioxide emissions – could feasibly be utilized within the next several decades if certain technological advancements are achieved. While the eventual scale of carbon utilization will be determined by a variety of technical, economic, and policy drivers over multiple decades, carbon utilization technologies could be instrumental in achieving a “circular carbon economy” in which some carbon waste gases are captured and converted into resources.

One technology – mineralization – transforms carbon dioxide into mineral carbonates, which can be used to make concrete and cement. Because these building construction materials are used at an enormous scale and have product lifetimes that span decades, mineralization represents a significant opportunity for long-term carbon storage as well as utilization, the report says. A variety of processes that use carbon dioxide in the production of concrete and cement are already operating at limited commercial scales.

Other technologies use chemical and biological processes to transform carbon dioxide and methane into fuels, polymers, and chemicals. Some of these processes are already operating commercially to produce high-value chemicals.

The report offers a comprehensive agenda for research to advance these technologies, including R&D to improve particular utilization methods. For example, research is needed on how to integrate mineralization processes with existing technologies for capturing carbon dioxide, in order to improve the efficiency and performance of this process. Other recommended research cuts across technology types; for instance, many technologies could benefit from advances in understanding chemical and biological processes that would facilitate discovery of faster and more energy-efficient reactions of carbon dioxide and methane.

The report also recommends work to advance “enabling” technologies that will be needed for carbon utilization to be viable. For example, carbon and methane waste gases may contain contaminants – such as nitrogen oxides, hydrogen sulfide, and sulfur dioxide – that can pose barriers to the utilization of the gases. Finding cost-effective methods for separating contaminants from usable waste gases will be important for carbon utilization, the report says. Improvements are also needed in tools used for evaluating the economic and environmental attributes of carbon utilization technologies.

The U.S. government and the private sector should support such research, the report says. Currently R&D on aspects of carbon utilization is scattered throughout various federal research portfolios, including those administered by the U.S. Department of Energy, the U.S. Department of Defense, and the National Science Foundation. Coordination and communication among these R&D programs could lead to more rapid advancements, the report says.

Federal science agencies should also coordinate carbon utilization R&D efforts with private sector activities in the United States and with international activities in the private and public sectors. Support for R&D should include technologies throughout different stages of maturity, from fundamental research through commercialization, and evaluate them using a consistent framework of economic and environmental criteria.

The study was sponsored by the U.S. Department of Energy and Shell. The National Academies of Sciences, Engineering, and Medicine are private, nonprofit institutions that provide independent, objective analysis and advice to the nation to solve complex problems and inform public policy decisions related to science, technology, and medicine. The National Academies operate under an 1863 congressional charter to the National Academy of Sciences, signed by President Lincoln. For more information, visit http://national-academies.org.

Cherry Growers Fined for Stormwater Violations

The Oregon Department of Environmental Quality has fined Oregon Cherry Growers LLC. $9,372 for failing to perform stormwater monitoring at its facility off Woodrow Street in Salem.

The company’s National Pollutant Discharge Elimination System 1200-Z Permit requires it to take samples to measure various pollutants up to four times a year.

The company failed to conduct monitoring of impairment pollutants for the 2017-2018 monitoring year.

Monitoring can reveal the presence of harmful levels of pollutants that pose a threat to waters of the state. Monitoring also allows permittees and DEQ to gauge the effectiveness of stormwater controls and practices aimed at reducing stormwater runoff.

The company has until Oct. 31 to appeal the fine.

MPCA Fined Environmental Violators $203,000

The Minnesota Pollution Control Agency concluded 39 enforcement cases in 26 counties throughout Minnesota during the third quarter of 2018. Penalties from all 39 cases totaled just over $203,000.

Environmental enforcement investigations often take several months, and in highly complex cases more than a year. Although, in rare instances, they can involve courts, they are most often negotiated settlements where the goal is compliance with environmental rules. Fines issued are targeted to match the environmental harm, economic advantage gained or environmental corrective actions.

In addition to these 39 recently-completed cases, the MPCA also has 37 ongoing enforcement investigations, 17 of which were opened as new cases during the third quarter of 2018. Not all investigations lead to fines or other official action.

Imposing monetary penalties is only part of the MPCA’s enforcement process. Agency staff continue to provide assistance, support, and information on the steps and tools necessary to achieve compliance for any company, individual, or local government that requests it.

The following is a brief summary of all 39 cases completed during the third quarter of 2018:

Ardent Mills LLC, Hastings, for air quality violations, $32,485
Casey’s General Stores Inc., Ellendale, for construction stormwater violations, $20,000
Minnesota Power, a division of ALLETE Inc., Boswell and Hibbing, for air quality violations, $15,000 (this includes a $7,500 supplemental environmental project)
American Crystal Sugar Co., Crookston, for air quality violations, $9,950
Mackner Excavating Inc., Detroit Lakes, for solid waste violations, $9,000
Harmony Enterprises Inc., Harmony, for hazardous waste violations, $8,875
Federal-Mogul Powertrain LLC, Lake City, for air quality violations, $8,820
T.A. Lauritsen Septic and Drain Inc., Montevideo, for subsurface sewage treatment system violations, $8,000
SCS Elevator Products Inc., Red Wing, for hazardous waste violations, $7,683
AAR Aircraft Services Inc., Duluth, for air quality and hazardous waste violations, $7,650
DKMC Development LLP, Rochester, for construction stormwater violations, $7,390
Green Plains Otter Tail LLC, Fergus Falls, for wastewater violations, $6,880
Tri-City Wastewater Treatment Systems Board, Wells, for municipal wastewater violations, $6,854
Hodgman Drainage Company Inc., Dexter, Fairmont and Glennville, for solid waste violations, $6,840
Greg Strobel, Janesville, for construction stormwater and feedlot violations, $4,300
Stack Bros. Mechanical Contractors Inc. and Andrew Hagglund, Duluth Township, for solid waste violations, $3,750
Fitzgerald Excavating and Trucking Inc., Goodhue, for asbestos violations, $3,675
M&M Contractors LLC, Breckenridge, for solid waste violations, $3,500
Lazy U Community LLC, Medford, for municipal wastewater violations, $3,045
Eaton Bros. Properties LLC, Waseca, for solid waste violations, $2,810
Metropolitan Airports Commission, Minneapolis, for industrial wastewater violations, $2,800
Jonathan Rohloff, Menahga, for solid waste violations, $2,600
Phil Stoll, Dent, for subsurface sewage treatment system violations, $2,310
Premier Fleet Services, Shakopee, for air quality violations, $2,150
Andrew Stoskopf, Warroad, for solid waste violations, $2,100
Early Iron Restoration LLC, Rochester, for air quality violations, $1,950
John Kamphake, Parkers Prairie, for solid waste violations, $1,875
Sanford Health of Northern Minnesota, Bemidji, for air quality violations, $1,750
Randall Abbott, Erhard, for subsurface sewage treatment system violations, $1,535
American Crystal Sugar Co., Moorhead, for wastewater violations, $1,350
Credit River Township, Prior Lake, for municipal wastewater violations, $1,100
Jon Mutschler, Bricelyn, for subsurface sewage treatment violations, $1,000
Shawn Ehrich, Elmore, for subsurface sewage treatment violations, $1,000
Rud Construction Inc., Northfield, for construction stormwater violations, $910
City of Mounds View, Mounds View, for municipal separate storm sewer system (MS4) violations, $840
LKQ Smart Parts Inc., Northfield, for construction stormwater violations, $700
Hooter’s Lumber True Value, Chokio, for subsurface sewage treatment system violations, $600
Dahmon Gullard, Fairmont, for solid waste violations, $500
Bruce Nagel, Stewartville, for solid waste violations, $350