Proposed Addition of Chemical For Toxic Release Inventory

Under a recently proposed rule change, Minnesota facilities that are subject to annual Toxic Release Inventory (TRI) reporting may need to review their use of an additional chemical. EPA is proposing to add ortho-nitrotoluene (o-nitrotoluene) to the list of chemicals subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and section 6607 of the Pollution Prevention Act (PPA).

o-Nitrotoluene has been classified by the National Toxicology Program in their 12th Report on Carcinogens as "reasonably anticipated to be a human carcinogen." EPA believes that o-nitrotoluene meets the EPCRA section 313(d)(2)(B) criteria because it can reasonably be anticipated to cause cancer in humans. Based on EPA’s review of the available production and use information, the agency believes that o-nitrotoluene is expected to be manufactured, processed, or otherwise used in quantities that would exceed the EPCRA section 313 reporting thresholds. Comments on the proposed addition of o-Nitrotoluene to the list of TRI chemicals must be received on or before May 13, 2013.

Click here for further background on the addition of o-nitrotoluene and the criteria for adding chemicals to the Section 313 list of chemicals.

Caltha LLP provides specialized expertise to clients in Minnesota in the preparing and submitting annual toxic release inventory reports, and preparing cost-effective chemical tracking procedures.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Petition To Remove Acetonitrile For Section 313 Chemical List - Minnesota TRI Requirements

EPA has announced that it is denying a petition to remove acetonitrile from the list of chemicals subject to reporting requirements under section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and section 6607 of the Pollution Prevention Act of 1990 (PPA). EPA reviewed the available data on this chemical and determined that acetonitrile does not meet the deletion criterion of EPCRA section 313(d)(3), specifically due to its potential human health impacts.

As background, Section 313 of EPCRA requires certain facilities that manufacture, process, or otherwise use listed toxic chemicals in amounts above reporting threshold levels to report their environmental releases and other waste management quantities of such chemicals annually. These facilities must also report pollution prevention and recycling data for such chemicals, under section 6607 of the PPA. Congress established an initial list of toxic chemicals subject to reporting that comprised more than 300 chemicals and 20 chemical categories.

EPCRA section 313(d) authorizes EPA to add or delete chemicals from the list and sets criteria for these actions. EPA may add a chemical to the list if any of the listing criteria in Section 313(d)(2) are met. To remove a chemical from the list, EPCRA requires that EPA demonstrate that none of the listing criteria are met. The EPCRA section 313(d)(2) criteria are:

1. The chemical is known to cause or can reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequently recurring, releases.
2.  The chemical is known to cause or can reasonably be anticipated to cause cancer or teratogenic effects, or other serious or irreversible chronic health effects.
3. The chemical is known to cause or can be reasonably anticipated to cause significant adverse effect on the environment, because of its toxicity, persistence in the environment, or tendency to bioaccumulate in the environment

Caltha LLP provides expert environmental consultant services in Minnesota to assist facilities in preparing and submitting Toxic Release Inventory reports required under EPCRA Section 313 and the annual Pollution Prevention (P2) Plan for submission to the Minnesota Emergency Planning and Community Right-to-Know Act Program.

For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Phone: (763) 208-6430
Website: http://www.calthacompany.com/
Two Minnesota offices - Minneapolis and Pine River

Section 313 Reportable Chemical Releases To Great Lakes Basin In 2011

According to the U.S. Environmental Protection Agency’s annual Toxics Release Inventory (TRI) report releases of EPCRA Section 313 reportable chemicals into surface waters in the Great Lakes Basin increased by 12 % from 2010 to 2011. Nitrates and pesticides from municipal wastewater treatment plants and agriculture account for most of the releases from surface water discharges to the Great Lakes Basin. Nitrates were also discharged by primary metals facilities, such as iron and steel mills and smelters, and food and beverage manufacturers.

For the summary, the Great Lakes Basin consists of Lakes Superior, Michigan, Huron, Erie and Ontario; a number of other smaller lakes and waterways; and the surrounding watershed. The watershed covers parts of Illinois, Indiana, Minnesota, Michigan, New York, Ohio, Pennsylvania and Wisconsin, and parts of Ontario in Canada. Despite increases from 2010 to 2011, overall Section 313 releases in the Great Lakes Basin have decreased about 40 % since 2003 and are currently at the second-lowest level in a decade. Surface water, air and land releases in the basin increased by 12, 1 and 4 % respectively, while underground injection decreased 5 % from 2010 to 2011.

Read summary of national EPCRA TRI releases for 2011.

Facilities in Minnesota must report their Section 313 chemical releases to EPA under the Emergency Planning and Community Right-to-Know Act (EPCRA 313) by the beginning of July each year, as well as prepare a Pollution Prevention Plan.. The Pollution Prevention Act of 1990 also requires information on waste management activities related to TRI chemicals. Caltha provides technical support to facilities nationwide to determine if they have processed or otherwise used Section 313 chemicals above reporting thresholds, and if so, to assist in the preparation of Form R TRI reports.

Do you miss submitting your 2011 TRI report, which was due on July 1, 2012? Contact Caltha to discuss options for submitting later Form R Toxic Release Inventory.


Caltha LLP provides expert environmental consultant services in Minnesota to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs. For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Phone: (763) 208-6430
Website: http://www.calthacompany.com/
Two Minnesota offices - Minneapolis and Pine River

Minnesota Environmental, Permitting and Compliance Consultant

Caltha LLP provides expert environmental health and safety consultant services to clients across Minnesota. Services provided include:

Minnesota Air Permitting Consultant - MPCA Air Emission Compliance Expert
Compliance Auditing in Minnesota
Waste Water Permitting Support
Due Diligence Services In Minnesota
Stormwater Permitting and Compliance Expert
ISO 14001 Consultant - Environmental Management Systems
Spill Control - SPCC Plans and SPCC Rule Compliance
Short term Temporary EH&S staffing in Minnesota
Hazardous Waste training - RCRA training in Minnesota
Pre Demolition Hazardous Material Survey in Minnesota
Minnesota Hazard Communication Expert - HazCom training



For further information click on topic above or contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Revised Industrial Boiler Maximum-Achievable Control Technology Standard "Boiler MACT"

US Environmental Protection Agency (EPA) has released air pollution rules regulating hazardous air emissions from industrial boilers and process heaters. This includes a revised version of the Industrial Boiler Maximum-Achievable Control Technology standard (Boiler MACT).

The final combustion rule package addresses major and area source industrial boilers, as well as commercial and industrial solid waste incinerators (CISWI). These rules provide new emissions limits, compliance dates and important clarifications on how the rules are to be implemented. The rule package also includes guidance for defining whether non-hazardous secondary materials (NHSM) are to be considered a solid waste or a fuel, which is a critical decision for determining whether combustion of such materials must be regulated under the generally more stringent incinerator CISWI rules or the revised Boiler MACT rules.

Read a summary of the key changes from the March 2011 rules

Caltha LLP provides expert environmental consultant services in Minnesota to obtain MPCA air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs. For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Phone: (763) 208-6430
Website: http://www.calthacompany.com/
Two Minnesota offices - Minneapolis and Pine River

Proposed TSCA and EPCRA Rules On Nonylphenol and NPE

EPA has initiated rulemaking to restrict the use of nonylphenol (NP) and its ethoxylates (NPEs) under a proposed significant new use rule (SNUR) using existing Toxic Substances Control Act (TSCA) authority. EPA plans to issue the proposal in the next year. NP and NPEs are used in industrial laundry detergents, oil spill dispersants, personal care products, industrial soaps, and other products, but the agency has raised concerns that the chemicals are highly toxic to aquatic life, environmentally persistent, moderately bioaccumulative and potential endocrine disruptors.

As part of the action plan, EPA is working with the industrial laundry industry to phase out that use of the chemicals by the end of 2014. The action plan also says the agency intends to encourage manufacturers of all NPE-containing direct-release products, such as firefighting gels and foams, dust-control agents and de-icers, to move to NPE-free formulations. Earlier this year the agency released an alternatives assessment for NP and NPEs through its Design for the Environment program that identified eight safer alternatives. The TSCA section 5 SNUR would serve as the next step under EPA's action plan, complementing the phaseout by restricting industry from reintroducing the chemical in new applications.

The SNUR would require persons who intend to manufacture, import, or process certain NP and NPE chemicals for an activity that is designated as a significant new use by the proposed rule to notify EPA at least 90 days before commencing that activity. The notification would provide EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs to prevent unreasonable risk to human health or the environment.

The action plan also indicates EPA may add the chemicals to its EPCRA Section 313 Toxics Release Inventory (TRI) list, and has proposed under TSCA section 5(b)(4) to put NPs and NPEs on a list of chemicals that present or may present an unreasonable risk of injury to health or the environment. The chemicals-of-concern list alone would have no regulatory consequences or trigger a rule.


 Caltha LLP provides expert environmental consultant services in Minnesota to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs. For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Phone: (763) 208-6430
Website: http://www.calthacompany.com/
Two Minnesota offices - Minneapolis and Pine River

AHMP-NSC General Meeting - Packaging Issues To Reduce Mercury Release From Fluorescent Bulbs

The North Star Chapter of the Alliance of Hazardous Materials Professionals (AHMP) is announcing its November General Membership Meeting. This month’s meeting will hosted by the University of Minnesota- Midwest Center for Occupational Health and Safety and will include a presentation by a U of M research on packaging issues related to reducing breakage and resulting mercury release from bulbs in transport.

Date: Thursday November 29, 2012
Time: 3:00 – 4:30 PM
Location: Room 114 Centers for Public Health Education and Outreach
University of Minnesota 2221 University Avenue, S.E. Minneapolis, Minnesota

Parking is available at the Maroon Lot which is about two blocks from the building.

Agenda:
Designing Better Packages to Prevent Mercury Vapor Release During Fluorescent Bulb Recycling Dr. Lisa Brosseau, U of M
This presentation will describe research examining the effect of different types of shipping package designs on preventing release of mercury vapor from broken fluorescent lights during shipment to recycling facilities.

A brief general membership meeting will follow.

Membership: The General Meeting is open to all North Star Chapter members – anyone else can become a member at the North Star Chapter website, or can print out the membership application ( http://ahmp-nsc.org/pdfs/memberap.pdf  ) and bring it to the general meeting.

You do not need to be a Certified Hazardous Material Manager, or a member of the national AHMP group to be a member of the North Star Chapter.