Regulatory Alert- June 2017
Aegis Environmental, Inc. extends this brief update of pertinent news and regulatory compliance requirements:
Air Quality
Virginia DEQ Proposes Significant Increases to Air Permit and Emissions Fees
Virginia DEQ is proposing significant increases to permit and emissions fees in 2018 and beyond. As examples, the following are proposed for 2018: Major NSR permit application fee of $63,000 (in 2017, this fee is $31,894 on the Application Fee Form), Title V permit renewal application fee of $15,000 (in 2017, $10,631), Minor NSR permit application for synthetic minor sources $3,000 (in 2017, $531). Therefore, if you have a Title V renewal or NSR permitting activity coming up, you could save significantly on permit application fees if you submit your application (and don’t amend your application) prior to the end of 2017. The proposed regulation can be found here beginning on Page 2198: http://register.dls.virginia.gov/vol33/iss20/v33i20.pdf. A public hearing is being held July 6, 2017 at 10 a.m. at the DEQ, 629 East Main Street, 2nd Floor Training Room in Richmond. The deadline for public comment is July 28, 2017. For more information, please contact Kelly Bonds at kbonds@aegisenv.com.
United States to Withdraw from Climate Accord
President Trump announced on June 1, 2017 that the U.S. would withdraw from the international Climate Accord. Because there are different legal routes by which that could be accomplished, it is uncertain how quickly this could take effect, with the longest estimates at about 3 or 4 years (as reported from the president of the European Commission). Within the U.S., a group of 30 mayors, three governors, 80+ universities and more than 100 businesses, representing some 13 states, have come together to negotiate with the UN to stay within the Climate Accord despite the U.S. withdrawal. On June 5th, Virginia joined this alliance as the 13th state to continue upholding the Paris Climate Agreement.
EPA Issues Stay for Revisions to the Risk Management Program (RMP)
On January 13, 2017, USEPA published revisions to the RMP rule for preventing chemical facility accidents. Petitions were received from industry groups and a group of states requesting reconsideration of the “extensive new requirements” on emergency responders and state and local governments. Of concern are the public disclosure requirements for easy access to on-site chemical information which the parties believe will create security issues. On March 26, 2017 and April 3, 2017, EPA published a notice for comment on the delay until February 19, 2019 to evaluate these concerns. Comments were due by May 19, 2017. For additional information, see Federal Register April 3, 2017 or contact Sandy Morse at smorse@aegisenv.com
EPA Issues Stay for NSPS Subparts XXX and Cf for MSW Landfills
In July 2016, the USEPA published updated requirements for NSPS Subparts XXX and Cf (emission guidelines) for Municipal Solid Waste landfills. Many petitions were received requesting reconsideration of the following: 1) tier 4 surface emission monitoring, 2) annual liquids reporting, 3) corrective action timeline procedures, 4) overlapping applicability with other rules, 5) definition of cover penetration, and 6) design plan approval. By notice in the May 31, 2017 Federal Register, USEPA granted a stay for both rules until August 29, 2017. USEPA expects to issue a notice of proposed rulemaking to obtain comments on these issues. For additional information, see Federal Register May 31, 2017 or contact Sandy Morse at smorse@aegisenv.com
Water Quality
Environmental Groups sue EPA over Virginia Water Quality Assessment Report
Several non-government environmental organizations have sued the USEPA over its approval of the Virginia 2014 305(b)/303(d) Water Quality Assessment Integrated Report. In the Report, Virginia indicated it was unable to assess the water quality in areas of the Shenandoah River due to excessive algae bloom. The lawsuit asks USEPA to revoke the approval and require Virginia to evaluate data and information from water quality experts and the Shenandoah Riverkeeper of algae bloom impairment. To read the complaint, see http://www.courthousenews.com/wp-content/uploads/2017/05/ShenandoahAlgae.pdf. For more information, please contact Jessica Gunter at jgunter@aegisenv.com.
Hazardous Waste
TRI Reporting
Toxic Release Inventory reporting is due to USEPA July 1, 2017. Should you need assistance preparing your TRI submittal contact Jessica Gunter, jgunter@aegisenv.com, immediately and Aegis can assist.