Shipping Hazardous Materials In Iowa - Changes To Violation Penalties

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is revising the references in its regulations to the maximum and minimum civil penalties for a knowing violation of the Federal hazardous material transportation law or a regulation, order, special permit, or approval issued under that law. In "Moving Ahead for Progress in the 21st Century Act" (MAP-21), Congress revised the maximum and minimum civil penalties for a knowing violation of the Federal hazardous material transportation law or a regulation, order, special permit, or approval issued under that law. These changes to the civil penalty amounts apply to violations occurring on or after October 1, 2012. Accordingly, PHMSA is revising the references to the maximum and minimum civil penalty amounts in its regulations to reflect the changes to Section 5123 of the Federal hazardous material transportation law, as follows:

• Revising the maximum civil penalty from $55,000 to $75,000 for a person who knowingly violates the Federal hazardous material transportation law or a regulation, order, special permit, or approval issued under that law.
• Revising the maximum civil penalty from $110,000 to $175,000 for a person who knowingly violates the Federal hazardous material transportation law or a regulation, order, special permit, or approval issued under that law that results in death, serious illness, or severe injury to any person or substantial destruction of the property.
• Removing the current $250 minimum civil penalty and revising the minimum penalty amount to $450 for a violation related to training.

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TRI Reporting In Iowa May Include Nitrotoluene

Under a recently proposed rule change, Iowa facilities that are subject to annual Toxic Release Inventory (TRI) reporting may need to review their use of an additional chemical. EPA is proposing to add ortho-nitrotoluene (o-nitrotoluene) to the list of chemicals subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and section 6607 of the Pollution Prevention Act (PPA).

o-Nitrotoluene has been classified by the National Toxicology Program in their 12th Report on Carcinogens as "reasonably anticipated to be a human carcinogen." EPA believes that o-nitrotoluene meets the EPCRA section 313(d)(2)(B) criteria because it can reasonably be anticipated to cause cancer in humans. Based on EPA’s review of the available production and use information, the agency believes that o-nitrotoluene is expected to be manufactured, processed, or otherwise used in quantities that would exceed the EPCRA section 313 reporting thresholds. Comments on the proposed addition of o-Nitrotoluene to the list of TRI chemicals must be received on or before May 13, 2013.

Click here for further background on the addition of o-nitrotoluene and the criteria for adding chemicals to the Section 313 list of chemicals.

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2012 Chemical Data Reporting Summary Released

EPA released the 2012 Chemical Data Reporting (CDR) information on more than 7,600 chemicals in commerce. The CDR database contains use and exposure information on the most widely used chemicals in the United States. This report is for calendar year 2011. EPA received reports on 7,674 chemicals, including 354 that were reported as used in children's products. 1,704 chemicals were reported as used in consumer products and 3,073 were used in commercial applications or products. The remaining chemicals reported were for industrial use only.

The CDR information includes data on chemicals that are used in children's products such as toys, playground and sporting equipment, arts and crafts materials, and textiles and furniture. The CDR rule was issued under the Toxic Substances Control Act (TSCA). The rule requires companies that manufacture or import chemicals to report manufacturing and import data every 4 years when site-specific production volume exceeds 25,000 lb.

 In 2012, EPA required companies to substantiate confidentiality claims in order to ensure that as much information as possible is made available to the public. Also, companies are now required to provide information on chemicals used in children's and other consumer products, along with reports on commercial applications and industrial uses of chemicals. EPA has begun a process to identify potential chemicals for near-term review and risk assessment under TSCA.

In 2012, the agency released a work plan of 83 chemicals for further review as part of its existing chemicals management program. From that list, seven chemicals were identified for risk assessment development in 2012 and 18 for assessment in 2013 and 2014. In January 2013, EPA released for public comment and peer review an initial set of draft risk assessments of five chemicals for particular uses found in common household products .

Caltha LLP provides expert environmental consultant services in Iowa to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
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Iowa Hazardous Chemical Storage Reports Due March 1

Tier II Hazardous Chemical Storage Reports are due March 1 for Iowa sites subject to hazardous chemical reporting. Under the Federal Emergency Planning and Community Right-to-Know Act (EPCRA), any facility that stores hazardous chemicals can have both one-time and annual reporting, specified in Section 311 and 312 of EPCRA.

EPCRA rules apply to all types of sites, and are not limited to a particular industrial sector – reporting sites can be commercial, institutional, warehousing, retail or any other type of site which could store or use chemicals. Facilities with chemicals in quantities that equal or exceed the thresholds must report. The thresholds can be specific to different types of chemicals and can be as low as 500 pounds for some materials, and as high as 10,000 pounds.

In summary, to comply with hazardous chemical storage reporting requirements, for any hazardous chemical used or stored on-site above threshold amounts, facilities must maintain a material safety data sheet (MSDS), and submit the MSDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department. Facilities must also report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and local fire department.

Hazardous chemicals are any substances for which a facility must maintain a Material Safety Data Sheet (MSDS) under the OSHA Hazard Communication Standard – if a material has an MSDS, it is considered to be a hazardous chemical under EPCRA. This can include materials which might not immediately be considered “chemicals”, such as batteries, fuels, metals, etc.

Facilities that need to submit MSDSs or chemical lists under Section 311, also need to submit an annual inventory report for the same chemicals under EPCRA Section 312. This inventory report must be submitted to the SERC, LEPC and local fire department by March 1 of each year. Facilities provide either a Tier I or Tier II form. However, most States require the Tier II form be used.

Caltha LLP provides expert environmental consultant services in Iowa to prepare chemical storage inventory tracking systems, prepare and submit Tier II reports, and to develop cost effective compliance programs.


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Final Health Effects Report On TCE

U.S. Environmental Protection Agency (EPA) has released the final health assessment for trichloroethylene (TCE) to the Integrated Risk Information System (IRIS) database. The final assessment characterizes the chemical as carcinogenic to humans and as a human noncancer health hazard. TCE is one of the most common man-made chemicals found in the environment and is frequently found at contaminated sites across Iowa. TCE can move from contaminated ground water and soil, into the indoor air of overlying buildings (known as vapor encroachment), which is a concern to regulators. TCE toxicity values as reported in the assessment will be considered in:

1. Establishing cleanup methods at the 761 Superfund sites where TCE has been identified as a contaminant


2. Understanding the risk from vapor intrusion as TCE vapors move from contaminated groundwater and soil into the indoor air of overlying buildings


3. Revising EPA’s Maximum Contaminant Level for TCE as part of the carcinogenic volatile organic compounds group in drinking water, as described in the agency’s drinking water strategy


4. Developing appropriate regulatory standards limiting the atmospheric emissions of TCE – a hazardous air pollutant under the Clean Air Act
   

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Grant To Assist Iowa Anhydrous Ammonia Facilities With Compliance

The Iowa Department of Agriculture and Land Stewardship (IDALS) has received a $30,000 grant for EPA Region 7 to assist with outreach, education and implementation of the Clean Air Act’s Risk Management Program (RMP) at sites that handle anhydrous ammonia. All fertilizer facilities that handle, process or store more than 10,000 pounds of anhydrous ammonia are subject to EPA’s chemical safety requirements. There are approximately 700 agricultural retail anhydrous ammonia facilities in Iowa.

EPA Region 7 receives more accidental release reports for ammonia than for any other chemical. In addition to releases caused by transportation accidents, human error and equipment failure, a number of releases have been caused by anhydrous ammonia thefts.

Retailers were first required to be in compliance with the Risk Management Program in 1999. EPA then started facility inspections and enforcement of the program, which includes five components: hazard assessment system, management, accident prevention, emergency response and submittal of a risk management plan.

Caltha LLP provides expert environmental consultant services in Iowa to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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Inventory Update Reporting Rules Temporarily Suspended

EPA has passed a final rule amending the Toxic Substances Control Act (TSCA) section 8(a) Inventory Update Reporting (IUR) regulations by suspending the next IUR submission period. This final rule is effective May 11, 2011. The IUR requires manufacturers (including importers) of certain chemical substances included on the TSCA Chemical Substance Inventory (TSCA Inventory) to report current data on the manufacturing, processing, and use of the chemical substances.

In the Federal Register of August 13, 2010, EPA published proposed modifications to the IUR regulations. EPA is suspending the next submission period to allow additional time to finalize the proposed modifications to the IUR regulations, and to avoid finalizing changes to the reporting requirements in the midst of the 2011 submission period. EPA expects to finalize, in the near future, changes to the IUR reporting requirements which will supersede this action.

The IUR final rule had established June 1, 2011 to September 30, 2011, as the second of a series of recurring submission periods for the IUR. The current action suspends the second IUR submission period, which is the next IUR submission period. Thus, the submission of IUR data for the next submission period will be neither required nor accepted until the suspension has been lifted or superseded by subsequent EPA action. This is needed due to the length of time which has been necessary to complete work on the proposed modifications and to avoid finalizing changes to the reporting requirements in the midst of the 2011 submission period. This is a one-time suspension of the next submission period only, and it does not alter the timing of subsequent submission periods.

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TSCA 2010 Reports Accepted Starting June 1, 2011

Calendar year 2010 is a reporting year for the TSCA Inventory Update Rule (IUR). The IUR is one of the most widely applicable requirements under TSCA; reporting is required for both manufacturers and importers of TSCA regulated chemicals (even if chemicals were imported for your own use).

EPA is still finalizing the requirements for this reporting period, consequently, the 2010 reports cannot be submitted at the present time. EPA is expecting to publish the final guidance documents in May 2011, with the proposed reporting period beginning a month later (June 1, 2011) and continuing until the end of September. The submission will be web-based, using the EPA's Central Data Exchange (CDX) site.

Caltha LLP provides specialized expertise to clients in Iowa offering TSCA and EPCRA reporting technical support, TSCA IUR reporting, and preparing cost-effective chemical tracking & management programs.

Caltha LLP provides expert environmental consultant services in Iowa to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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Iowa Tier 2 EPCRA Reporting - Conditonal Excemption For Fuel Storage

Are EPCRA reporting facilities required to report fuels stored on-site under EPCRA 311 and 312?
In most cases, fuels must be considered under EPCRA 311 and 312, and must be reported on Tier I or Tier II forms if the maximum inventory during the reporting year exceeds the EPCRA reporting threshold of 10,000 pounds, or lower if an Extremely Hazardous Substance (EHS). There are some limited exceptions for fuel storage. However, these apply only to retail establishments and only to storage in underground storage tanks (USTs). For such facilities, the condition exemption applies only to two fuel types:

•For gasoline at a retail gas station, the threshold level is 75,000 gallons, if storage meets some specific conditions
•For diesel fuel at a retail gas station, the threshold level is 100,000 gallons, again if storage meets some specific conditions.

Caltha LLP provides specialized expertise to in Iowa in the preparing hazardous material and chemical inventories for EPCRA Tier I and Tier II reports, preparing EPCRA 311 and EPCRA 312 reports, and preparing cost-effective chemical inventory and MSDS management programs.
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Perchlorate & VOC Drinking Water Standards Proposed By EPA

U.S. Environmental Protection Agency has announced the agency’s decision to develop to regulate perchlorate in drinking water. The decision will lead to the development of the first-ever national standard for perchlorate.

According to EPA, scientific research indicates that perchlorate may disrupt the thyroid’s ability to produce hormones that are critical to developing fetuses and infants. Monitoring data show more than 4% of public water systems have detected perchlorate and 5 - 17 million people may be served drinking water containing perchlorate.

EPA expects to continue to evaluate potential perchlorate health effects and occurrence in public water systems. The agency will also evaluate the feasibility and affordability of treatment technologies to remove perchlorate and examine the costs and benefits of potential standards.

In a separate action, the agency is also plans to establish a drinking water standard to address a group of chemicals that may pose risks to human health. EPA will also be developing one regulation covering as many as 16 volatile organic compounds (VOCs), includes trichloroethylene (TCE) and tetrachloroethylene (PCE) as well as other regulated and some unregulated contaminants that are discharged from industrial operations. The VOC standard will be developed as part of EPA’s new strategy for drinking water to address contaminants as groups rather than individually in order to provide public health protections more quickly and also allow utilities to more effectively and efficiently plan for improvements.

Caltha LLP provides expert environmental consultant services in Iowa to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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Iowa TSCA 2011 IUR Inventory Update Rule Reporting

Calender year 2010 was a reporting year under the TSCA Inventory Update Rule (IUR), and operations in Iowa that are subject to IUR reporting will need to submit reports in 2011. Under Section 8(a) of the Toxic Substances Control Act (TSCA), every five years companies that either manufacture or import chemicals or mixtures of chemicals on the “TSCA List” must report their activities. The reporting requirement, referred to as the “Inventory Update Rule”, or IUR, is only one of several requirements in TSCA. The IUR requirements are the most broadly applicable of all the TSCA requirements.

When are 2011 IUR reports due?

According to the Chemical Control Division at the Environmental Protection Agency the submission period for 2011 TSCA IUR reporting is from June 1 - September 1, 2011. However, there are proposed changes to what is required for submittal. These were drafted last July, but these changes have not yet been approved. EPA expects that the submittal requirements will be finalized by at least 30 days prior to the beginning of the reporting period (by May 1, 2011).

If approved as drafted, the majority of information required will be from 2010, however, there will also be additional production data required from the years 2006 - 2010.

Caltha LLP provides expert environmental consultant services in Iowa to determine applicabilty of Inventory Update Rule reporting to operations, prepare IUR reports to be submitted to US EPA, and to develop cost effective chemical tracking programs.

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Storage of Biofuels In Iowa In UST Systems - Proposed Guidance

To help ensure that biofuels, such as ethanol and biodiesel, are safely stored in underground storage tanks (USTs), the U.S. Environmental Protection Agency (EPA) released draft guidance for UST owners and operators who wish to store these fuels. EPA is requesting comments on the proposed guidance that clarifies how an UST owner or operator can comply with the federal compatibility requirement for UST systems storing gasoline containing greater than 10 percent ethanol, and diesel containing a percent of biodiesel yet to be determined. After reviewing comments, EPA intends to issue the final guidance in early 2011.

Caltha LLP provides expert environmental consultant services in Iowa to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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Environmental Site Investigations UST Clean Up Requirements

The Iowa Environmental Protection Commission has published a Notice of Intended Action to amend Chapter 135, “Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks,” The proposed amendments revise existing rules to include the changes in review procedures and acceptance of reports from certified groundwater professionals on investigation and cleanup of petroleum contamination from underground storage tanks.

In 2010, the Iowa General Assembly enacted legislation in 2010 Iowa Acts, House File 2531, sections 169 to 174, that made changes in review procedures and acceptance of reports from certified groundwater professionals on investigation and cleanup of petroleum contamination from underground storage tanks. A groundwater professional’s site investigation, classification, and corrective action design reports must be accepted unless, within 90 days of receipt, the Iowa Department of Natural Resources identifies material information in the report that is inaccurate or incomplete. From July 1, 2010, through June 30, 2011, the Department has 120 days rather than 90 days to review and comment on the reports.

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Orphaned Hazardous Material Containers In Iowa

The USEPA is encouraging Iowa residents to report orphaned hazardous containers they discover. Recent severe storms and flooding events may have scattered tanks, drums, cylinders and barrels onto private properties and farmland especially along the Maquoketa and South Skunk rivers in Iowa. These items may contain hazardous materials such as propane and industrial chemicals and should only be handled by trained professionals.

The U.S. Environmental Protection Agency has been tasked by the Federal Emergency Management Agency (FEMA) to coordinate the collection and disposal of appliances, electronic goods and orphan containers and drums along these rivers. EPA is working with the Iowa Department of Natural Resources to identify and retrieve these materials. Drums and other materials should be reported by calling the Iowa Department of Natural Resources.

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HBCD, NP, NPE Action Plans Under TSCA

U.S. Environmental Protection Agency (EPA) released action plans to address the potential health risks of benzidine dyes, hexabromocyclododecane (HBCD) and nonylphenol (NP)/nonylphenol ethoxylates (NPEs). The chemicals are widely used in both consumer and industrial applications, including dyes, flame retardants, and industrial laundry detergents. The plans identify a range of actions the agency is considering under the Toxic Substances Control Act (TSCA).

The range of actions on these chemicals include adding HBCD and NP/NPE to EPA’s new Chemicals of Concern list, issuing significant new use rules for all three chemicals, and, for HBCD and benzidine dyes, imposing new reporting requirements on EPA’s Toxic Release Inventory and potentially banning or limiting the manufacture or use of the chemicals.

In addition to EPA actions, the Textile Rental Services Association has committed to voluntarily phase out the use of NPEs in industrial liquid detergents by Dec. 31, 2013 and industrial powder detergents by the end of 2014.

EPA first announced that it planned to develop the Chemicals of Concern list last December, which indicates that the chemicals may present an unreasonable risk of injury to health and the environment, under a previously unused TSCA authority.

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Iowa Receives Grant for RMP Compliance at Anhydrous Ammonia Sites

EPA has awarded the Iowa Department of Agriculture and Land Stewardship (IDALS) a total of $70,000 to assist with outreach, education and implementation of the Clean Air Act’s Risk Management Program (RMP). All fertilizer facilities that handle, process or store more than 10,000 pounds of anhydrous ammonia are subject to EPA’s chemical safety requirements. IDALS plans to use funding to conduct on-site audits, workshops and follow-up safety assessments at agricultural retail anhydrous ammonia facilities in Iowa.

EPA Region 7 receives more accidental release reports for ammonia than for any other chemical. In addition to releases caused by transportation accidents, human error and equipment failure, a number of releases have been caused by anhydrous ammonia thefts. Anhydrous ammonia is a key ingredient in the illegal production of methamphetamine. When stolen, the toxic gas can be unintentionally released, causing injuries to emergency responders, law enforcement personnel, the public and the criminals themselves.

Retailers were first required to be in compliance with the Risk Management Program in 1999. EPA then started facility inspections and enforcement of the program, which includes five components: hazard assessment system, management, accident prevention, emergency response and submittal of a risk management plan.

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Aerial Applicator Fined For Pesticide Drift

A Mississippi company has agreed to pay a $4,082 civil penalty to the United States for an August 2009 incident in which a liquid pesticide that it sprayed over an Iowa corn field drifted to an adjacent public use trail, and resulted in exposure of trail users to the chemical.

An investigation by the Iowa Department of Agriculture and Land Stewardship confirmed that samples of vegetation taken along the trail adjacent to the field were contaminated with residue of a fungicide. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) prohibits the aerial application of registered pesticides in ways that will result in human contact, either directly or through drifting.

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Revised Dioxin Toxicity Report

U.S. Environmental Protection Agency (EPA) has released its draft scientific report, “Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments”. The draft dioxin report is EPA’s response to key comments and recommendations made by the National Academy of Sciences on the agency’s draft dioxin reassessment. The draft report will now undergo scientific peer review by independent, external experts as well as public review and comment.

EPA’s draft scientific report will now undergo external peer review by an expert panel of scientists convened by EPA’s Science Advisory Board (SAB) in July 2010. Public comments on this draft report are being requested, and the Federal Register Notice provides details on how to submit comments.

More information on dioxin toxicity assessment report

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New TRI Chemicals Proposed - EPCRA 313

U.S. Environmental Protection Agency (EPA) is proposing to add 16 chemicals to the Toxics Release Inventory (TRI) list of reportable chemicals. TRI is a publicly available EPA database that contains information on toxic chemical releases and waste management activities reported annually by certain industries as well as federal facilities.
Four of the chemicals are being proposed for addition to TRI under the polycyclic aromatic compounds (PACs) category. The PACs category includes chemicals that are persistent, bioaccumulative, toxic (PBT) and are likely to remain in the environment for a very long time. These chemicals are not readily destroyed and may build up or accumulate in body tissue.
To review a list of the chemicals proposed for addition click here

EPA is accepting public comments on the proposal for 60 days after it appears in the Federal Register.

Click here for more information on TRI Reporting Requirements and deadlines

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New International Standard for Safe Handling of Nanomaterials

The International Organization for Standardization (ISO) recently published a technical report (ISO/TR 12885:2008, Health and safety practices in occupational settings relevant to nanotechnologies), providing guidelines on ways to prevent adverse health and safety consequences during the production, handling, use, and disposal of manufactured nanomaterials. The report addresses current information about nanotechnologies, including characterization, health effects, exposure assessments, and control practices and focuses on the manufacture and use of engineered nanomaterials.

ISO is a non-governmental organization and does not enforce the implementation of its standards. However, many ISO standards related to health, safety, or the environment have been adopted in some countries as part of their regulatory framework, or are referred to in legislation.

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