UV+EB Technology
Increased TSCA New Chemical Fees Update
The US Environmental Protection Agency’s (US EPA’s) decision to increase its Toxic Substances Control Act (TSCA) new chemical notification fees by as much as 540% has resulted in a significant drop in applications and has discouraged innovation, according to the Society of Chemical Manufacturers and Affiliates (SOCMA). The group is calling on the agency to halve its fees for submitting premanufacture notices (PMNs) and significant new use notices (SNUNs) to reverse the “chilling effect” the higher rate has had on annual submissions. SOCMA’s request comes as the agency begins work to revise its fee schedule for TSCA, with a proposal expected in December 2020 before a final rule in October 2021, according to the latest regulatory agenda. A 50% reduction in PMN and SNUN fees would help encourage submissions while still factoring in the work the agency staff put into reviewing the case, it argued.
US EPA Proposes SNURs for Certain Chemical Substances
US EPA proposed significant new use rules (SNURs) under TSCA for chemical substances that are the subject of premanufacture notices (PMNs): 85 Fed. Reg. 52294. This action would require EPA notification at least 90 days before commencing manufacture (defined by statute to include import) or processing of any of these chemical substances for an activity that is designated as a significant new use by this proposed rule. This action would further require that neither manufacture nor processing for the significant new use begin until a Significant New Use Notice (SNUN) has been submitted, and EPA has conducted a review of the notice, made an appropriate determination and taken any risk management actions required as a result of that determination.
NSR Plantwide Applicability Limitation Provisions Guidance
The US Environmental Protection Agency issued a guidance memorandum on plantwide applicability limitation (PAL) provisions under the New Source Review (NSR) regulation. The agency promulgated the PAL regulations as part of the 2002 NSR Reform. A PAL is an optional flexible permitting mechanism available to major stationary sources that involves the establishment of a plantwide emission limit. Once a PAL is established, changes to facility operations that affect that pollutant can forego NSR, a costly and time-consuming process for industry. The purpose of the memorandum was to provide guidance on the PAL regulations to address specific concerns. Read the memorandum at https://www.epa.gov/sites/production/files/2020-08/documents/pal_guidance_final_-_signed.pdf
eGRID Website Updated
Facilities calculating their carbon footprint utilize information found on the US EPA Emissions & Generation Resource Integrated Database (eGRID) website. eGRID is a comprehensive source of data on the environmental characteristics of almost all power generated in the US. The data include emissions, emission rates, generation, heat input, resource mix and many other attributes. eGRID is typically used for greenhouse gas registries and inventories, carbon footprints, consumer information disclosure, emission inventories and standards, power market changes and avoided emission estimates. Learn more at www.epa.gov/egrid.
SGP Working Toward Offering Supplier Certification
The Sustainable Green Printing Partnership (SGP), the leading authority in sustainable printing certifications for print manufacturers, has announced it is working toward offering a sustainability certification for suppliers to the printing industry. The criteria for SGP Supplier certification are similar to those for SGP Printers in that they specify the requirements for management and production operations that define sustainable practices encompassing the economic, environmental and social areas of sustainability. The draft criteria document, based on SGP’s successful printer certification efforts, defines the core elements of the SGP certification program, including development and adoption of a sustainability management system (SMS) and best practices. Learn more at www.sgppartnership.org or contact Doreen Monteleone at doreen@radtech.org.
Doreen M. Monteleone, Ph.D.
Director of Sustainability & EHS Initiatives
RadTech International North America
doreen@radtech.org
News from the West Coast
SCAQMD Fails to Meet Federal Standards
According to the US Environmental Protection Agency (EPA), the South Coast Air Quality Management District (SCAQMD) has failed to meet National Ambient Air Quality Standards (NAAQS), prompting the issuance of a new rule declaring the failure by the attainment date. The EPA first promulgated the NAAQS for PM2.5 in July 1997. The 24-hour PM2.5 standard was set at a level of 65 micrograms per cubic meter (μg/m3). The annual PM2.5 standard was set at a level of 15 μg/m3. In 2006, the EPA strengthened the 24-hour standard to 35 µg/m3. The annual standard stayed at 15 µg/m3 until December 14, 2012, when it was reduced to 12 µg/m3. Since the Basin did not meet the federal 2006 24-hour PM2.5 standard by the 2019 deadline, the Clean Air Act requires that a revision to the State Implementation Plan (SIP) be submitted to EPA within 12 months after the applicable attainment date to demonstrate attainment of the standard no later than five years from the date of the EPA’s final determination of failure to attain the standard. In addition to the attainment demonstration, the updated SIP also must address several other federal CAA requirements. A minimum of 5% annual reductions in directly emitted PM or PM precursor (such as VOCs, ammonia and sulfur oxides) is required. SCAQMD prefers what it calls a “NOx heavy” strategy, as it is believed that a reduction of NOx is the most efficient approach. According to SCAQMD staff, the South Coast Air Basin is expected to attain the 2006 24-hour PM2.5 standard during or before 2023. Given the plan is due to the EPA by December 31, 2020, the first year to demonstrate the 5% reduction is 2021, and the last year is 2023 – the new attainment date. Staff believe that existing regulations already achieve more than the 5% NOx emissions reductions per year required by EPA. The PM2.5 Plan revisions also include an analysis of Reasonably Available Control Technology/Reasonably Available Control Measures (RACT/RACM). A final draft of the plan was expected to be released in November 2020, and revisions are scheduled to be presented to the SCAQMD board in December 2020. The plan then will move on the California Air Resources Board and, subsequently, to the EPA for approval.
California’s EICG/CTR Regulations
The California Air Resources Board (CARB) scheduled a public hearing in November 2020 to consider amendments to parallel regulations for (1) Emission Inventory Criteria and Guidelines (EICG) Report for the Air Toxics “Hot Spots” Program and (2) the reporting of criteria air pollutants and toxic air contaminants (CTR). Approximately 60,000 California facilities will be affected by the regulations.
EICG. Under this program, stationary sources are required to report the types and quantities of certain toxic substances their facilities routinely release into the air. The program requires collection of emission data, identifying facilities having the potential for localized impacts, ascertaining health risks and requiring that owners of significant-risk facilities reduce their risks below the level of significance. Additionally, CARB is to compile a list of “substances of concern” identified by other agencies and scientific bodies. Since the 2007 EICG update, CARB staff identified more than 1,000 new substances that meet the criteria for reporting under the Hot Spots Act. The compliance requirements and the economic impact of the proposed amendments would begin with the 2023 reporting year, based on emissions data from 2022.
CTR. CTR requires the annual reporting of criteria pollutant and toxic air contaminant emissions by facilities subject to the applicability requirements of the regulation. Effective January 1, 2020, the CTR established statewide annual reporting of criteria air pollutant and toxic air contaminant emissions data for three facility categories: (1) subject to Greenhouse Gas Mandatory Reporting Regulation, (2) authorized to emit > 250 tons per year of a nonattainment criteria pollutant (such as volatile organic compounds) and (3) received an “elevated Toxics Hot Spot” prioritization score. Last fall, CARB proposed to add 812 new substances to the AB 2588 Chemical List and unveiled a list of categories under review as follows:
CARB plans to implement the program in different phases, with the program only applying to facilities that have been issued a Permit to Operate by a California air district, so low-VOC operations – such as UV/EB processes that are exempt from permitting – would not be subject to the reporting. The agency expects the rulemaking to be finalized in late 2020.
Rita Loof
Director of Regional Environmental Affairs
RadTech International North America
rita@radtech.org
