Tag: Air

Industry Struck Out on NESHAP Petitions

Industry struck out swinging on all five parts of its petitions to the U.S. Court of Appeals for the D.C. Circuit to invalidate requirements in the EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products Manufacturing; and the NESHAP for Clay Ceramics Manufacturing (October 26, 2015, Federal Register (FR)). […]

How to Avoid RMP

Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]

RMP—No Release but a Huge Fine Anyway

It’s hard to swallow a huge fine for what might have happened. But, as part of its efforts to comply with the president’s EO to improve safety and security at chemical facilities, the EPA is hunting down companies that are required to develop RMPs but have not even though there has not been a release […]

Refrigerants—Cold Lessons Learned

A refrigerant formulator was recently fined $300,000 by the EPA and the Department of Justice for violations of SNAP regulations. First, let’s look at what the pertinent regulations say, then at what the company allegedly did, and finally what the fix will be. Note: Under SNAP, a “producer” is any person who manufactures, formulates, or […]

Managing Refrigerants—It’s a SNAP!

Many refrigerants have been determined to be ozone-depleting substances (ODS) and have been targeted for phaseout under the Montreal Protocol. Chemicals used in the Refrigeration and Air-Conditioning industrial sector is one group for which the U.S. Environmental Protection Agency (EPA) has reviewed and identified substitutes under the Clean Air Act’s (CAA) Significant New Alternatives Policy […]

Seven Tips to Make Sure Your Asbestos is Adequately Wet

Acronyms and Definitions Before we list the tips, let’s take a minute to define some asbestos terms that are applicable in demolition/renovation projects. ACM—asbestos-containing material, i.e., any material that contains more than 1% asbestos. Sometimes it is best to leave ACM in place. ACWM—asbestos-containing waste material, i.e., waste that contains commercial asbestos and is generated […]

Bike to Work and Other Commuting Incentives—Can It Pay Off for You?

Employer Trip Reduction (ETR) Under the 1990 Clean Air Act Amendments, states that have areas designated as extreme or severe nonattainment for ozone were required to revise their state implementation plan (SIP) by adopting regulations to implement ETR programs and reduce work-related vehicle trips and miles traveled by employees. In 1995, Congress amended the law, […]

Impacts of Near-Roadway Air Pollution

Impacts of Near-Roadway Air Pollution It’s the rare person that has not had the unfortunate experience of driving too close to a vehicle like a heavy-duty diesel truck and getting a car full of smelly exhaust. But the everyday impacts of the cumulative emissions on major roads are also under scrutiny by the Environmental Protection […]