| What's on ALL4's Calendar? |
 At ALL4, we like to get out and about -- whether presenting or taking part in technical and regulatory conferences. Stop by and see us at these upcoming events.
October 23 - PA Chamber Environmental Issues Compliance Conference - Pittsburgh, PA
October 28 - PA Chamber Environmental Compliance Issues Conference - Camp Hill, PA
November 6 - PA Chamber Environmental Compliance Issues Conference - King of Prussia, PA
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| Continuous Parameter Monitoring Systems: Regulatory Changes to Affect Over 1/4 Million Sources & Cost Over $175 Million |
 Long Awaited New Installation and Quality Assurance Requirements Proposed by U.S. EPA for Systems Installed Under 40 CFR Parts 60, 61, and 63
On October 9, 2008, U.S. EPA proposed for comment the long awaited Performance Specification 17 (PS-17) and Procedure 4 (P-4) to evaluate the acceptability of continuous parameter monitoring systems (CPMS) that monitor specific process or control device parameters pursuant to 40 CFR Parts 60, 61, and 63 (with exemptions). U.S. EPA estimates this action will affect over one quater of a million sources and cost facilities over $175 million in the first five-year period. PS-17 describes the requirements for the initial installation and performance procedures for the CPMS while P-4 describes the requirements for ongoing quality assurance (QA) and quality control (QC) of those CPMS. PS-17 and P-4 would apply to CPMS that are used to monitor temperature, pressure, liquid flow rate, mass flow rate, pH, and conductivity as indicators of good control device performance or emission source operation. Read on as ALL4's Eric Swisher answers the following questions:
Please contact Eric Swisher at 610.933.5246 x17 or eswisher@all4inc.com should you have any questions regarding Continuous Parameter Monitoring Systems. |
| ALL4 Joins Climate Registry |
The Climate Registry, which is a unified registry with transparent standards for calculating, verifying and publicly reporting greenhouse gas emissions for businesses and governments in North America, has just welcomed All4 Inc. (ALL4) as a new reporting member. Beginning in 2009, ALL4 will report their GHG emissions to the Climate Registry. In addition to ALL4 joining The Climate Registry as a reporting member, the Pennsylvania Department of Environmental Protection (PADEP) officially adopted The Climate Registry as its voluntary GHG reporting program per the recommendations of the Pennsylvania Climate Change Advisory.
For more information regarding Climate Change activity, please visit ALL4's Climate Change News page or contact Cara Fox at 610.933.5246 x23 or cfox@all4inc.com. | |
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| U.S. EPA Lowers Air Quality Standard for Lead to a Level 10 Times Lower Than the Current Standard |
 On October 16, 2008, U.S. EPA Administrator Stephen Johnson announced that U.S. EPA is revising the primary and secondary National Ambient Air Quality Standards (NAAQS) for lead. U.S. EPA is setting both the primary (health-based) and secondary (welfare-based) standard at 0.15 µg/m3, measured as total suspended particles (TSP). The previous standards, set in 1978, were 1.5 µg/m3. In addition, U.S. EPA has changed the calculation method for the averaging time used to determine whether an area meets the new standards from calendar quarters to a rolling three-month average. A three-year period, without any of the rolling three-month averages above the new standards, will be required to demonstrate compliance. U.S. EPA's action to lower the air quality standards for lead will become effective 60 days after publication in the Federal Register.
The new lead NAAQS rule also redesigns the nation's lead monitoring network by requiring states and local agencies to, at a minimum, place monitors near sources that emit one ton or more of lead per year and in each urban area with a population greater than 500,000. About half of the newly required lead monitors are to be operational by January 1, 2010, with the other half to be operational by January 1, 2011.
States are required to submit recommendations for area attainment designations by October 2009. U.S. EPA will make final attainment designations no later than January 2012. Where sufficient data is available from the existing monitoring network, U.S. EPA intends to complete initial designations as soon as possible. By June 2013, states must submit their State Implementation Plans (SIPs) describing how they will meet the new lead standards. Attainment of the new lead standards must be achieved no later than January 2017.
If you have any questions regarding the revised lead NAAQS, please contact ALL4's Neal Lebo at 610.933.5246 x13 or nlebo@all4inc.com. |
| How Do You Keep Up-To-Date on Changes in Environmental Regulations?? |
 Let me guess...your desktop has a stack of papers on it just like this. Tomorrow you'll get to reviewing the ever growing stack of new proposed and promulgated regulations that may have an impact on your business. Tomorrow comes and goes....but you have to review them or you may just miss that one regulation that has a major impact on your business. What if there was a more efficient way? How about eliminating that stack all together? Click on the stack of papers to find out how.... |
| The Most Extensive Revisions to Ohio's Water Quality Standards in 30 Years |
 The Ohio Environmental Protection Agency (Ohio EPA) has recently released three (3) of four (4) draft water quality rule packages. The draft rule packages for Water Quality Standards, Antidegradation, and Section 401 Water Quality Certifications have been released for public review and comment. The fourth draft rule package for the Stream Mitigation Protocol will be released in early 2009 and comments on all four (4) rule packages will be due 60 days after the release of the fourth package by Ohio EPA. According to Ohio EPA, these draft rules contain the most extensive revisions to Ohio's water quality standards in 30 years and will impact virtually all industry sectors in Ohio.
The revisions to these rules will:
- Update surface water standards to reflect the most recent scientific information and U.S. EPA guidance;
- Expand the number of beneficial uses of water recognized in the Ohio water quality standards to include drainage, navigation and primary headwater habitat;
- Update the antidegradation rule to improve protection of high-quality waters;
- Reduce the time and work needed to issue permits, especially Section 401 water quality certifications;
- Establish a method to implement protective stream mitigation requirements in Section 401 water quality certifications; and
- Create a State Water Quality Permit to regulate impacts to "waters of the state" that no longer fall under Clean Water Act jurisdiction.
These rule revisions will increase the complexity and stringency of the water rules and will affect anyone who holds a National Pollutant Discharge Elimination System (NPDES) wastewater discharge permit in Ohio. If you have questions regarding the draft rules, please contact ALL4's Marvin Gregory at 740.286.5375 or mgregory@all4inc.com. |
| EnviroReview Extract |
 EnviroReview is ALL4's regulatory update product which summarizes multimedia environmental changes at the Federal, state, and local level. Being on top of the regulatory development process is paramount to continued environmental compliance. "EnviroReview Extract" is a monthly feature sharing several highlights of the previous month's EnviroReview. This month's highlights include:
Federal News
U.S. EPA has submitted an existing Information Collection Request (ICR) to the Office of Management and Budget (OMB) for review and approval. U.S. EPA, under authority of section 112d of the Clean Air Act (CAA), established National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Hazardous Waste Combustors, including hazardous waste burning incinerators, cement kilns, lightweight aggregate kilns, industrial/commercial/institutional boilers and process heaters, and hydrochloric acid production furnaces. These NESHAPs are found in 40 CFR Part 63, Subpart EEE. Hazardous waste combustors are required to meet emission levels that reflect the Maximum Achievable Control Technology (MACT) standards. 40 CFR Part 63, Subpart EEE requires hazardous waste combustors to perform testing and monitoring, submit various reports, and perform recordkeeping activities in order to demonstrate compliance with emission standards. Comments on this ICR should be submitted to U.S. EPA on or before October 23, 2008.
Federal News
U.S. EPA is announcing the release of a pre-dissemination external review draft titled "Problem Formulation for Human Health Risk Assessments of Pathogens in Land-applied Biosolids" for both public comment and external peer review. The 45-day public comment period began September 19, 2008 and will end November 3, 2008. An external peer-review workshop to review the draft document will be held on November 19, 2008.
Federal News
U.S. EPA Regions 1, 2, 3, 5, 6, 9, and 10 have finalized the National Pollutant Discharge Elimination System (NPDES) general permit for stormwater discharges from industrial activity, also referred to as the Multi-Sector General Permit (MSGP). The MSGP consists of 34 separate Regional U.S. EPA permits that may vary from each other based on state or tribal water quality-based requirements. This permit replaces the existing permits that expired on October 30, 2005 and authorizes the discharge of stormwater associated with industrial activities in accordance with the terms and conditions described therein. Industrial dischargers have the choice to seek coverage under an individual permit. An individual permit may be necessary if the discharger cannot meet the terms and conditions or eligibility requirements in the permit. This permit was effective September 29, 2008 in order to provide dischargers with the immediate opportunity to comply with Clean Water Act requirements in light of the expiration of the MSGP 2000 on October 30, 2005.
Michigan News
U.S. EPA is proposing to disapprove certain revisions to the State of Michigan's prevention of significant deterioration (PSD) State Implementation Plan (SIP), and in the alternative to approve the revisions if the deficiencies in the rules involved are corrected, as proposed by Michigan, and approved by U.S. EPA. These revisions are included in Michigan Rule R 336.2816, and set out the mechanisms which facilitate the participation of a potentially affected Federal Land Manager (FLM) in the State's permitting process for purposes of protecting either the increment or the Air Quality-Related Values (AQRVs) associated with a Class I area from potential impacts from a proposed major source or major modification. The Michigan Department of Environmental Quality (MDEQ) submitted these revisions as part of the SIP package on December 21, 2006. In a separate action in the Federal Register, U.S. EPA is conditionally approving all other portions of Michigan's PSD SIP revision submission.
New York News
The New York State Department of Environmental Conservation (NYSDEC) has proposed amendments to existing 6 NYCRR Parts 200 (General Provisions), 201 (Permits and registrations), and 231 (New Source Review in Nonattainment Areas and Ozone Transport Regions) and proposes to include these revisions in the State Implementation Plan (SIP). The purpose of the amendments is to comply with the 2002 Federal New Source Review (NSR) reform rule and to correct deficiencies identified by U.S. EPA. Written comments on the proposed revisions will be accepted through October 24, 2008. |
| ALL4's Podcast....October's Feature: John Slade on the CAIR Vacature.... |
 The Clean Air Interstate Rule (CAIR) Vacature has been a hot topic the last few months. Click here to listen to ALL4's John Slade discuss the CAIR Vacature and express his thoughts on how best to preserve the Phase I CAIR emissions reductions.
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| Careers @ ALL4 |
 At ALL4, we are constantly growing: personally, professionally, and as a company. Because growth is so present in our organization, we are continually looking to hire environmental professionals that share our same vision and passion for helping our clients be successful. If you are an environmental professional that wants to......
- Work in a relaxed and employee-centered work environment,
- Be given the opportunity to measure success based on your own merits,
- Make a tangible contribution to the growth of the company,
- Work in a culture of accountability,
- Be rewarded for your efforts that go above and beyond "business as usual,"
- Receive a benefits package that is unmatched in our industry,
- Have access to mentoring and hands-on training from experienced experts in the environmental consulting business,
- Constantly challenge yourself both technically and personally,
- Have the opportunity to contribute to the management and the direction of the company,
- Be asked your opinion and given the freedom to put it into action, and
- Be part of an organization that is striving to be "best in class" every day,
.....then you need to contact ALL4 now at humanresources@all4inc.com.
Even if you personally do not have an interest in joining ALL4, but know someone who might, please inquire about our "Referral Rewards" program. For more information, please check out our career section and/or email us at humanresources@all4inc.com.
Check out this podcast to learn why Dan Dix likes working at ALL4. |
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 We hope you've enjoyed our October 2008 4 The Record. Feel free to forward suggestions, thoughts, and/or comments to kgordon@all4inc.com.
Sincerely,
All4 Inc.
Kristin M. Gordon, P.E.
Your environmental compliance is clearly our business.
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