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Emerging Regulatory and Technical Topics
- Pulp and paper ICR: U.S. EPA is planning to issue an Information Collection Request (ICR) to all major source facilities owned by nine companies as part of their technology review and gap filling work on the pulp and paper rules in 40 CFR Parts 60 and 63. ALL4 is working with AF&PA members to provide feedback to EPA on draft ICR materials. The questionnaire will likely be issued in late 2024 and due in mid-2025, with emissions testing required in 2025 and 2026. The information gathered is expected to lead to substantive new requirements in 40 CFR Part 63, Subparts S and MM.
- PCWP MACT: After receiving many comments on the proposed updates to the Plywood and Composite Wood Products (PCWP) MACT rule, EPA is back to the drawing board, determining what additional information should be gathered to support a 2025 supplemental proposal and a 2026 final rule. ALL4 is working with the American Wood Council (AWC) to strategize around what additional information the industry can provide to EPA to support a good outcome.
- AERR delayed: After receiving many comments from industry, states, and environmental groups on its 2023 proposed changes to the Air Emissions Reporting Requirements (AERR) Rule, EPA sent a final rule to the White House Office of Management and Budget (OMB) for approval. Recent indications are that OMB will not approve the rule prior to the November presidential election. If finalized, the rule will change how many facilities quantify and report HAP emissions.
- RICE rule updates: EPA recently finalized revisions to the Part 60 and 63 emissions standards for Reciprocating Internal Combustion Engines (RICE) that include the addition of electronic reporting requirements. Read Gwynith Howell’s recent ALL4 blog that describes the final revisions. Make sure to also check EPA’s CEDRI website for updates to electronic reporting templates for various federal air rules.
- PM2.5 NAAQS: It’s been four months since the lowered annual particulate matter less than 2.5 microns (PM2.5) National Ambient Air Quality Standard (NAAQS) became effective on May 6, 2024. EPA has released guidance lowering the significant impact levels (SILs), posted a compilation of permitting tools for PM2.5 under the PSD permitting program, and published design values for 2021-2023 ambient monitor data. See Dan Dix’s recent blog for details.
- Reclassification of HAP major sources: EPA recently published final revisions to the 40 CFR Part 63 general provisions that add restrictions on facilities that reclassify from major to area source status for hazardous air pollutant (HAP) emissions. Facilities subject to certain Part 63 standards remain subject to them, even upon reclassification. Check out Amy Marshall’s recent blog for details.
- Boiler MACT news: The DC Circuit Court recently issued its unanimous decision in the litigation on the 2022 Boiler MACT revisions. In short, the court determined that EPA was wrong to determine that a source is new based on the original proposal date of 2010 and that EPA was allowed to use the prior dataset to recalculate the standards. It remains to be seen if EPA will file a petition for rehearing and what this means for the new source standards that were revised in 2022. In a recent presentation, EPA indicated that it has begun work on the Boiler MACT Risk and Technology Review, so more proposed changes to the rule are coming. ALL4 will keep on top of Boiler MACT related issues – look for a future blog with updates.
Industry News
- July 22, 2024 Clearwater to focus on paperboard after $1B tissue business sale Read more
- July 24, 2024 Suzano starts operation of the world’s largest pulp production line Read more
- July 29, 2024 Total U.S. Containerboard Production Increased 7 Percent in Q2 2024 Read more
- Aug.7, 2024 Willamette Falls Paper Mill to Lay Off 158, May Close Permanently Read more
- Aug. 15, 2024 Graphic Packaging announces 2050 net zero goal Read more
- Aug. 16, 2024 First Quality Tissue to expand manufacturing capabilities Read more
- Aug. 20, 2024 Fiber end users forecast ‘relatively stable’ OCC market Read more
- Aug. 27, 2024 Interfor to cut down Georgia, South Carolina lumber plants Read more
- Sept. 3, 2024 Domtar Kingsport Mill Receives Business Recycler of the Year Honors in Tennessee Read more
- Sept. 4, 2024 Silgan Containers, Smurfit Westrock reported layoffs in August Read more
- Sept. 4, 2024 Veritiv to acquire Orora Packaging Solutions for $1.2B Read more
4 The Record: Behind the Scenes is ALL4’s podcast, which we use to keep you informed on the latest changes in the world of environmental regulations and technology. Hosted by Colin McCall, Chief Technical Officer. Click here to view the library of current and archived recordings, including the latest podcast where Colin talks Air Quality Regulatory updates with Amy Marshall.
Upcoming Events Conferences
- NCASI Conference October 1-3, 2024 – Vancouver, WA https://www.ncasi.org/events/2024-ncasi-conference/
- Carolinas Air Pollution Control Association (CAPCA)October 23-25, 2024 – Myrtle Beach, SC https://www.capca-carolinas.org/2024-fall
Training
- ESG & EHS Business Drivers for Digitization: A Crash Course for IT Directors
- Philadelphia – October 10th from 1-5 PM – The Windsor Suites, Philadelphia, PA – Learn more
- Boston – October 15th from 1-5 PM – Westin Waltham, Waltham, Mass – Learn more
- Air Quality 101 (AQ 101)AQ101 Training provides a comprehensive and foundational knowledge of the Clean Air Act (CAA) and its various regulatory programs. The program covers the history of the CAA, National Ambient Air Quality Standards (NAAQS), and an overview of regulatory programs that impact industrial operations (e.g., New Source Performance Standards, Prevention of Significant Deterioration, air quality modeling, etc.). The program also covers more focused topics that are encountered day to day by facility environmental personnel such as the basics of emissions testing and continuous emissions monitoring. NEW FOR 2024: A new Digital Track is now being offered as an alternative (or addition) to the traditional AQ101 program. The traditional AQ101 program will now be referred to as the NSR Track. Learn more
Click here for a list of ALL4 conferences, webinars, trainings, and other events.
Upcoming Regulatory Deadlines
- TSCA Chemical Data Reporting (CDR) is due September 30
- Quarterly reports are due in October – if you need help with continuous monitoring system (CMS) reports or automating your reporting process, reach out to Aditya Shivkumar on our CMS tech team.
- One time TSCA PFAS reporting will not begin in November – it has been delayed until July 2025
- Risk Management Program (RMP) Notification Exercise Due December 19, 2024: Program 2 and Program 3 RMP facilities have a new emergency response notification exercise requirement under 40 CFR 68.96(a) of the RMP rules that is due no later than December 19, 2024 and annually thereafter. The facility must ensure that appropriate mechanisms are in place to notify emergency response agencies about chemical releases at the regulated facility. The process must include details to provide timely data about the nature of the release. This notification can be combined with other Federal, State, or Local notification requirements or be combined as part of table top or field exercises required by the RMP rule.
- If your facility is subject to the Lead and Copper Rule Revisions (LCRR), the service line inventory compliance date is October 16, 2024. ALL4’s webinar on this topic can be found at https://www.all4inc.com/recording-lead-and-copper-rule-revisions-lcrr-rundown/.
Tips & Tricks
Note that EPA’s electronic reporting portal, CDX, has transitioned to using Login.gov for user verification, including common environmental reporting services such as CEDRI, e-GGRT, NetDMR, RCRAInfo, and TRIMEweb. This change is part of ongoing efforts to enhance security and streamline access to EPA services. Using the Login.gov access will allow one account for multiple governmental agency access.
This change will incorporate a new 12-character password and two-factor authentication. See the CDX FAQ page for a link to instructions on how to migrate your account to login.gov.
Did you know?
ALL4 has a comprehensive health and safety practice! Our health and safety professionals and industrial hygienists have extensive experience and knowledge across a wide range of workplace safety and health issues. ALL4 works with a variety of industries including specialty manufacturing, pulp and paper, automobile, food and beverage, pharmaceutical, energy, and federal defense agencies. Our client work ranges from small, one-off projects at the local facility level to high-level strategic safety and risk management planning for global corporations. Each of our clients and their operations have a unique set of health and safety responsibilities and challenges. ALL4 takes this into account when working with our clients to develop site-specific strategies for reducing workplace accidents and injuries and managing risk. Whether it is safety program development, job site inspections, compliance auditing or industrial hygiene services such as occupational exposure assessments, ALL4 provides an unbiased and objective review of each issue with our client’s environmental, health and safety consultation team. If you need assistance with H&S compliance, please reach out to our H&S tech team leader, Meg Reese: mreese@all4inc.com.
I hope you found our inaugural forest products newsletter helpful and informative. We hope to publish this compilation of information on a quarterly basis and would love your feedback on how we can make this newsletter more useful. ALL4 has significant forest products industry experience and our goal is to partner with the industry to promote positive outcomes on projects, regulations, and environmental policies. If you have any questions, please reach out to your ALL4 Project Manager or you are welcome to contact me directly. I hope I see you at an upcoming conference or event!
Thanks,
Amy Marshall, Air Quality Practice Director
