| 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.
May 20-22, 2009 - Association of Battery Recyclers (ABR) Spring 2009 Meeting, Amelia Island, FL (ALL4's Presentation: "Climate Regulations Charging the Lead and Battery Industries" by Dan Holland and Neal Lebo)
COMING SOON...
- ALL4 Webinar Training Series |
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Stimulus Funding and Manufacturing Facilities: Is Your Facility Prepared? |
 What is the "Stimulus Package?"
The "American Recovery and Reinvestment Act of 2009" (Act) that was passed by Congress on January 6, 2009 is more often referred to as the Stimulus Package. The Act makes "supplemental appropriations for job preservation and creation, infrastructure investment, energy efficiency and science, assistance to the unemployed, and state and local fiscal stabilization for the fiscal year ending September 30, 2009..." Two key purposes of the Act include investments to increase economic efficiency and investments in transportation, environmental protection, and other infrastructure to provide long term economic benefits.
- Where has funding been appropriated under the Act?
- How can the stimulus funding impact the operation of my facility?
- Why does my facility need to be prepared from an environmental perspective?
- What can I do to prepare my facility?
- My facility is prepared, so now what?
- What is ALL4 seeing with respect to the stimulus funding?
Please contact ALL4's Bill Straub at 610.933.5246 x12 or wstraub@all4inc.com or ALL4's Roy Rakiewicz at x27 or rrakiewicz@all4inc.com should you have any questions regarding stimulus funding and the air quality permitting considerations.
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| GUEST ARTICLE: Climate Change as a Competitive Position |
 Most environmental managers view the pending United States response to climate change as yet another command and control regulatory program. You know the drill - debate over whether the issue is real, the development of ambient criteria, the establishment of performance standards, perhaps cap-and-trade emissions limitations - all at a perceived added cost to society, and especially our companies. Or is it?
Read on as Interface, Inc.'s Wendy Porter provides more details on the subject.
Wendy Porter is the Corporate Director of Environmental Management for Interface, Inc., the largest modular carpet manufacturer in the world. Interface's goal is to provide their customers with innovation, beauty, performance, service, value, and environmentally responsible products and processes. ALL4 has been working with Interface for over eight years on projects in four states on air quality permitting, air quality compliance, environmental program management, and air quality dispersion modeling projects.
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U.S. EPA Declines Extension of Comment Period for Proposed Mandatory Reporting of Greenhouse Gas Rule |
 Although over 20 trade associations submitted requests for extensions of the comment period for the Proposed Mandatory Reporting of Greenhouse Gas Rule, U.S. EPA posted a letter to the American Petroleum Institute (API) stating that the formal comment period will NOT be extended past June 9, 2009. In the posted letter, U.S. EPA states that the decline for the extension is "due to the time sensitive nature of this rulemaking and the urgent need to finalize it to allow for 2010 data collection...."
If you require assistance with the Proposed Mandatory Reporting of Greenhouse Gas Rule or want to ensure your facility is prepared to collect data in 2010, contact ALL4's Cara Fox at 610.933.5246 x23 or cfox@all4inc.com. |
ALL4's John Slade Named to PADEP's AQTAC
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 We are pleased to announce that ALL4 Senior Consultant John Slade has been named to the Pennsylvania Department of Environmental Protection's (PADEP's) Air Quality Technical Advisory Committee (AQTAC). John will serve a two year term beginning July 1, 2009. AQTAC advises PADEP, through comments and recommendations, on the technical and economic or other social impacts of existing, new, or proposed revisions to pollution control regulations, policies, and new control techniques or technologies affecting air. The Committee, at the request of PADEP, may be utilized to provide technical advice on PADEP policies, guidance, and regulations needed to implement the Clean Air Act (CAA). The Committee may also request to review a PADEP policy, guidance, or regulation needed to implement the CAA. The Committee facilitates public participation by encouraging public input on the air quality technical matters under consideration at the Committee meetings. For more information on AQTAC and their upcoming meetings, click here. | |
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| Greenhouse Gases: Chapter 2, Endangerment |
 By making a determination that greenhouse gases (GHGs) represent a threat to public health and welfare, U.S. EPA Administrator Lisa Jackson has opened the door to the regulation of GHGs under the Clean Air Act. The determination is the conclusion to the second chapter in the GHG story. The first chapter involved the Supreme Court ruling in which the Court determined that U.S. EPA was required to make a determination concerning the potential endangerment to the public health caused by GHGs emitted from motor vehicles. U.S. EPA undertook a review of existing GHG and climate change studies and prepared a report for the Administrator to review. The Administrator conducted her review and decided that there is sufficient evidence to support the finding that GHG emissions from motor vehicles do represent a threat to the public welfare. The threats that could occur over the next 100 years include:
- Rising sea levels.
- Higher temperatures in various locations throughout the U.S. and the world.
- More intense storms and greater intensity of precipitation events.
- Migration of drought patterns.
- Harm to sensitive ecosystems and animals.
U.S. EPA will be soliciting comments on the finding during two public hearings on May 18 and 27, 2009. As necessary, U.S. EPA will respond to comments provided during the comment period. Although the endangerment finding applies to motor vehicle emissions, it's just a formality that this finding will soon encompass industry and electricity generation. There is no regulatory language contained in the endangerment finding; however, it clearly sets the stage for the third chapter in the GHG story: regulation.
Please contact ALL'4s Cara Fox of ALL4's Climate Change Team at 610.933.5246 x23 or cfox@all4inc.com for more information on this article. |
| ALL4's Greenhouse Gas Inventory Starter Kit - Get Yours Today! |
 Does your greenhouse gas inventory need to sprout?
You know you should get started determining your company's Greenhouse Gas (GHG) emissions, but you don't know how best to get started. You don't want to commit thousands upon thousands of dollars right now while regulations and reporting requirements are being sorted out.
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| New U.S. EPA Administration Reconsidering NSR Rules |
 On April 24, 2009, U.S. EPA sent out three separate letters in response to requests it had received to consider various apsects of the New Source Review (NSR) air permit rules that had been promulgated during the latter stages of the Bush Administration. Letters were sent to the following:
- Natural Resources Defense Council with regard to the December 2008 final rule about the inclusion of fugitive emissions in the NSR permitting process.
- State of New Jersey with regard to the December 2007 "reasonable possibility" rule that specified conditions for recordkeeping associated with major NSR applicability determinations.
- Earthjustice with regard to the May 2008 NSR PM2.5 rules.
In each instance, U.S. EPA agreed to reconsider the previous rulemaking and to reopen the rule for public comment. In addition, with respect to the fugitive emissions rule, U.S. EPA indicated that the December 2008 fugitive emission rule has been stayed pending reconsideration. The December 2008 rule had limited the requirement to include fugitive emissions to only the listed sources when determining rule applicability for major modifications. With the stay, the 2008 rule is no longer in effect and all major sources will need to consider fugitive emissions in applicability determinations. Similarly, U.S. EPA also stayed the grandfathering provision in the new PM2.5 rule that allowed sources that submitted complete applications prior to the July 15, 2008 effective date of the rule to address PM2.5 through the previous PM10 surrogate policy. Pending construction permits yet to be issued that were based on applications prepared under the surrogate policy will need to be reassessed with new PM2.5 data.
Copies of the U.S. EPA reconsideration letters and a fact sheet summarizing the details can be found here. These actions leave the future status of the rules uncertain and once again add confusion to the regulated community's efforts to comply with what are already some of the most complicated environmental rules on the books.
Please contact ALL4's John Egan at 610.933.5246 x14 or jegan@all4inc.com should you have any questions about U.S. EPA's reconsiderations. |
| Proposed Portland Cement MACT Rule Amendments and Performance Specifications for Mercury CEMS |
 U.S. EPA is proposing to amend the National Emission Standard for Hazardous Air Pollutants (NESHAP) rule that established Maximum Achievable Control Technology (MACT) for the Portland cement (PC) manufacturing industry. These regulations are codified at 40 CFR Part 63, Subpart LLL and are referred to as the PC MACT rules. The proposed amendments, published on May 6, 2009, will affect both major and area PC MACT sources. Included are proposed new limits for particulate matter, mercury, and total hydrocarbons (THC) from major and area HAP sources, and hydrochloric acid (HCl) limits for major HAP sources only. An important note for other MACT source categories is the inclusion in the proposal of performance specifications for the use of mercury continuous emission monitors (CEMS). Amendments and additions to Appendix B of 40 CFR Part 60 that address the mercury CEMS are also part of the proposed rulemaking package.
- Proposed emission limits for cement kilns for PM, mercury, THC, and HCl (including changes to emission limit units, averaging periods, major vs. area source applicability, and new vs. existing unit applicability).
- Proposed emission limits for clinker coolers and raw material dryers.
- New proposed performance testing and monitoring requirements.
- Compliance deadlines.
- Comment submittal details.
Please contact ALL4's John Egan at 610.933.5246 x14 or jegan@all4inc.com should you have any questions about the proposed PC MACT rule. |
| U.S. EPA Rescinds the TRI Burden Reduction Rule |
 On April 27, 2009, U.S. EPA issued a final rule to amend the Toxics Release Inventory (TRI) reporting regulations eligibility criteria for submitting a Form A Certification Statement (Form A) in lieu of the more detailed Form R. When using Form R, facilities must provide details about releases of chemicals and other waste management practices (i.e., total quantity of releases to air, water, and land; and on- and off-site recycling, treatment, and combustion for energy recovery), while Form A only requires the name of the chemical and facility identification information. This new rule returns the eligibility for use of Form A to the thresholds and eligibility requirements that were in effect prior to the TRI Burden Reduction Rule that was promulgated in December 2006. U.S. EPA took this action to comply with the Omnibus Appropriations Act of 2009 enacted on March 11, 2009.
Read on as ALL4's Neal Lebo discusses the details of the rescission and explains why the change became effective April 27, 2009.
Please contact ALL4's Neal Lebo at 610.933.5246 x13 or nlebo@all4inc.com should you have any questions related to the TRI revisions. |
| ALL4 Earth Day/Green Activities |
 ALL4 once again took part in Philadelphia's Clean Air Council 5K Run for Clean Air. ALL4 staff, friends, and family ran in the 28th annual event on April 18th. The event was much anticipated as a challenge was thrown down in the Hickey household months ago - who could finish first: Kevin or daughter Jayne? Jayne beat Kevin soundly and even captured the 1st place medal in the "females under 15" category. Congrats Jayne! Keep training Kevin, there's always next year. Also, try a better excuse than your shoe came untied, that is weak. (Kevin would like to interject that he was quite proud of Jayne however will venture from the treadmill and vary his training activities next year.) ALL4 placed 9th among the mixed teams. ALL4 would also like to congratulate Manko, Gold, Katcher & Fox for several medal places as well. Job well done!
Also on April 18th, ALL4 staff, friends, and family participated in an Adopt-A-Highway cleanup at ALL4's section of Route 113. The group once again braved the Saturday morning traffic of Route 113 in an effort to keep Pennsylvania beautiful by participating in ALL4's semiannual highway cleanup event. The group that participates in the highway cleanup event is a dedicated crew and we all appreciate their efforts. |
| U.S. EPA Compliance Warning: Risk Management Plan Updates |
 On April 27, 2007, U.S. EPA issued a press release compliance warning to facilities subject to Risk Management Program requirements: update and resubmit your plans as required by law or face penalties. The Risk Management Program is authorized under Section 112(r) of the Clean Air Act and is implemented through regulations in 40 CFR Part 68. The law and regulations require facilities that use certain specified flammable and toxic substances to prepare and implement a Risk Management Plan (RMP); the RMP must include a hazard assessment, accidental release prevention program, and emergency response program for the specified substances. Although the compliance warning was issued by U.S. EPA's Region 2, the requirement to update and resubmit RMPs every five years applies to all facilities across the country. The first RMP submittals under the law were due in June 1999; thus, for many facilities, the second five-year update is due in June 2009.U.S. EPA released a new RMP submittal tool called RMP*eSubmit in March 2009. Although not required, U.S. EPA encourages facilities to submit their plan updates using this tool. Information about RMP*eSubmit can be found on U.S. EPA's website at: http://www.epa.gov/emergencies/content/rmp/rmp_esubmit.htm.
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| 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 finalized amendments to 40 CFR Part 60, Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants (NMPPs)) that could affect crushing, screening, and conveying operations at brick and cement manufacturing facilities, fossil fuel power generation facilities, and several other industrial sectors. These final amendments include revisions to the emission limits for NMPP affected facilities that commence construction, modification, or reconstruction on or after April 22, 2008. These final amendments for NMPPs also include: additional testing and monitoring requirements for affected facilities that commence construction, modification, or reconstruction on or after April 22, 2008; an exemption for affected facilities that process wet material; changes to simplify the notification requirements for all affected facilities; changes to definitions; and various clarifications. No final action is being taken regarding the proposed amendment to 40 CFR Part 60, Subpart UUU (Standards of Performance for Calciners and Dryers in Mineral Industries) discussed in the proposed rule. The effective date of this rule was April 28, 2009.
Federal News
U.S. EPA is delaying the effective date of the final rule that amends the Spill Prevention, Control, and Countermeasure (SPCC) regulations promulgated in the Federal Register on December 5, 2008. The amendments clarify, tailor, and streamline certain existing requirements for those facility owners or operators who are required to prepare and implement an SPCC Plan to prevent the discharge of oil into or upon navigable waters of the United States or adjoining shorelines. U.S. EPA is requesting public comment on whether a further extension of the effective date may be warranted. The effective date of this rule, which was delayed until April 4, 2009, is further delayed to January 14, 2010.
Federal News
U.S. EPA is proposing to amend the National Volatile Organic Compound (VOC) Emission Standards for Aerosol Coatings (Aerosol Coatings Reactivity Rule), which establishes national reactivity-based emission standards for the aerosol coatings category (aerosol spray paints) under Section 183(e) of the Clean Air Act (CAA). This proposed action amends Table 2A of the Aerosol Coatings Reactivity Rule by adding compounds and associated reactivity factors, and by clarifying which VOCs are to be quantified in compliance determinations. Beyond minor revisions and corrections, the action also proposes changes to notification requirements for a company to certify that it will assume the responsibility for compliance with recordkeeping and reporting requirements.
Florida News
The Florida Department of Environmental Protection (FDEP) is proposing to change the name of proposed new rule F.A.C. 62-285.300 from "Electric Utility Greenhouse Gas Reduction Program" to "Electric Utility Greenhouse Gas Reduction Program - General Provisions." The purpose and effect of the rule, which is currently under development, will still include the establishment of statewide emission caps from the electric utility section, but will be expanded to include general provisions related to establishment and operation of a cap and trade program to accomplish the greenhouse gas emission reductions. FDEP is also proposing to develop four (4) additional new rule sections to implement details of the proposed cap and trade program. These details include procedures for (1) allocating greenhouse gas emission allowances to allowance tracking accounts of different types; (2) establishing allowance tracking accounts and tracking allocations, deductions, and transfers to and from such accounts; (3) monitoring and reporting of greenhouse gas emissions; and (4) creating and using greenhouse gas emissions offsets. The next rule development workshop for the Electric Utility Greenhouse Gas Reduction Program will be held on May 19, 2009.
Massachusetts News
The Massachusetts Department of Environmental Protection (MassDEP) will be holding public information sessions regarding the Global Warming Solutions Act (GWSA) and the Green Communities Act (GCA). The GWSA requires an economy-wide 80 percent reduction of greenhouse gas (GHG) emissions by 2050, with a 2020 target to be set between 10 and 25 percent below 1990 levels of GHG emissions. In addition, the GWSA requires the development of a statewide 1990 GHG emission baseline (1990 Baseline) and a projection of greenhouse gas emissions in 2020 in a "business as usual" (2020 BAU) scenario. These estimates will be used in determining the 2020 and 2050 target reductions. The GCA supports the development of renewable energy resources, creates a new greener State building code, removes barriers to renewable energy installations, stimulates technology innovation, and helps consumers reduce electric bills. The remaining public information sessions in May were held on May 11 and 14, 2009. A public hearing regarding the 1990 Baseline and the 2020 BAU will be held on May 19, 2009 and comments are due June 1, 2009. | |
| 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,
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 We hope you've enjoyed our May 2009 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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