Pharmaceuticals Proposed as Universal Waste

October 31, 2005
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The Florida Department of Environmental Protection has proposed to classify hazardous waste pharmaceuticals as universal waste.á A public hearing on the proposal was held on October 21, 2005. The proposed rule will also set standards for pharmaceutical reversed distribution. A copy of the proposal can be found at this link.á In Michigan, waste pharmaceuticals have been classified universal waste since 2004.á A copy of the Michigan rule can be found here.á Washington has relaxed its dangerous waste regulations for pharmaceutical waste that is designated as non-RCRA state-regulated dangerous waste.
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California Hazardous Waste Verification Questionnaire

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Generators of hazardous waste in California must complete an annual verification form, which was planned to be mailed during the last week of October. The DTSC recently published a list of frequently asked questions
á to help you better understand the form and its requirements.

DOT Proposes Aluminum Cylinder Testing

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On September 10, 2003, the Research and Special Programs Administration--the predecessor agency to the Pipeline and Hazardous Materials Safety Administration published a notice of proposed rulemaking (NPRM) to propose an inspection and testing program for early detection of sustained load cracking in certain cylinders manufactured with aluminum alloy 6351-T6. Based on comments received in response to that NPRM, the proposal, published on October 26, 2005, is to adopt a maximum service life for cylinders manufactured with aluminum alloy 6351-T6 and to prohibit the use of these cylinders after the expiration of their maximum service life.
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Test Your Brain

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The Indiana Department of Environmental Management has created a fun way to test your knowledge on critical environmental issues. Play the game at Test Your Brain.á If you get 100%, send an e-mail to service@ercweb.com and weÆll send you a free 2006 Environmental Compliance Calendar.
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Missouri Hazardous Waste Regulation Changes

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Missouri Senate Bill 225 made a number of significant changes in the Hazardous Waste law dealing with the regulation of generators. Those changes include:
  • áááááááá Out-of-state generators who bring waste into Missouri are no longer required to register, report or pay fees directly to the Hazardous Waste Program
  • áááááááá Two fees previously assessed on hazardous waste, the Category Fee and Generator Fee, were eliminated and replaced by a single fee
  • áááááááá Establishes a fee to be paid by Missouri treatment, storage and disposal facilities on all hazardous waste they receive from generators located outside of Missouri
  • áááááááá Establishes a sunset date of December 31, 2011 for the hazardous waste fees under the new structure
  • áááááááá Establishes a fee of fifty cents for each lead-acid battery 6 volts or greater sold at retail to be paid by consumers and collected by retailers
  • áááááááá Establishes that the Department of Natural Resources will request general revenue funding from the legislature for any state match obligation owed to the U. S. EPA for cleanup work at Superfund sites in Missouri
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E-Scrap Workshops

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The Kentucky Division of Waste Management is holding workshops on recycling and managing electronic waste. The sessions are geared to entities that generate high volumes of electronic scrap. Sessions are scheduled Nov. 9 at Barren River State Resort Park; Feb. 22, 2006 at General Butler SRP; and March 22, 2006 at Natural Bridge SRP. For more information, call Tom Heil or Dara Carlisle at (502) 564-6716 or e-mail Thomas.Heil@ky.gov or Dara.Carlisle@ky.gov.á There is no charge for the workshops, but registration is required.á á


New York Adopts New Manifest

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All states will be using the new hazardous waste manifest beginning September 5, 2006. New York recently adopted the changes required by EPA. The state regulations are somewhat more stringent than the federal.á The DEC has published a list of the state differences.
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Clear Skies and Legislative and Regulatory Analyses Released

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EPA Administrator Stephen L. Johnson announced the results of the most detailed, comprehensive analysis of several cap-and-trade approaches aimed at reducing sulfur dioxide, nitrogen oxides, and mercury emissions from coal-fired power plants.
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"This additional information answers any remaining questions," said Johnson.á "This is an apples-to-apples comparison that shows Clear Skies legislation is the clear choice for cleaner air and healthier lives."
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According to EPA, Clear Skies will significantly expand the Clean Air Act's most innovative and successful program to cut power plant pollution of sulfur dioxide, nitrogen oxides and, for the first time, mercury by an unprecedented 70% in two phases.á These cuts in pollution will provide substantial health benefits by imposing a mandatory multi-pollutant cap on emissions from more than 1300 power plants nationwide, reducing pollution by as much as 9 million tons annually at full implementation.á The country will achieve this by spending more than $44 billion in large part to install, operate and maintain pollution abatement technology on both old and new power plants.
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The study incorporated the latest computer models and assumptions to create a side-by-side comparison of the Clear Skies legislation to several alternatives introduced on Capitol Hill.
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The legislative and regulatory analyses project potential costs and benefits for public health, air quality, and the power sector for the years 2010, 2015, and 2020.á The legislative and regulatory proposals analyzed:
  1. ááááá Clean Air Planning Act (Carper, S.843 in 108th)
  2. ááááá Clean Power Act (Jeffords, S.150 in 109th)
  3. ááááá Clear Skies Act of 2005 (Inhofe, S.131 in 109th)
  4. ááááá Clear Skies Act of 2003 (Bush Administration proposed bill, S.485 in 108th)
  5. ááááá Clear Skies Manager's Mark (of S.131)
  6. ááááá Clean Air Interstate Rule (CAIR), Clean Air Mercury Rule (CAMR), Clean Air Visibility Rule (CAVR)
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Nominations Being Accepted for "Green Chemistry" Awards

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EPA is now accepting nominations for the 2006 Presidential Green Chemistry Challenge Awards.á These awards recognize innovative chemical technologies that incorporate green chemistry into chemical design, manufacture and use -- and that have broad applications in industry.
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Nominated technologies should reduce or eliminate the use or generation of hazardous substances from a chemical product or process.á Any individual, group or organization, both nonprofit and for-profit, including academics, government and industry, may nominate a green chemistry technology for these awards.á Self-nominations are welcome and expected.á Typically, five awards are given each year:á one to an academic researcher, one to a small business, and the others to larger companies for specific areas of green chemistry.á Each nominated technology must have reached a significant milestone within the past five years in the United States.á
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Examples of last year's nominations and award winners are available online. Nominations must be postmarked by Dec. 31, to be eligible for the 2006 awards, which will be presented at the National Academy of Sciences in Washington, D.C., on June 26, 2006.
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EPA Green Power Partnership Tops 3 Billion Kilowatts, Enough to Power 300,000 Homes

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EPA's Green Power Partnership has grown to 600 partner organizations purchasing more than 3 billion kilowatt hours (KWh) of green power annually, enough to power 300,000 American homes each year.á This voluntary program includes Fortune 500 companies, universities, and local, state, and federal agencies.
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Green power is electricity generated from environmentally preferable, renewable resources such as mainstream the purchasing of green power electricity generated by renewable energy sources including solar, wind, water (hydro), geothermal, biomass (combustion of organic materials) and biogas (combustion of naturally-produced methane).á Green power currently accounts for just 2% of America's electricity supply, but voluntary purchasing of renewable energy is accelerating the development of new renewable energy sources.á The voluntary green power market currently supports over 2,200 megawatts of new renewable generating capacity.
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The Green Power Partnership has grown dramatically since it was launched with 21 Founding Partners in 2001.á The 3 billion KWh purchased by the partnership has doubled in the past 15 months and grew 10-fold over the past four years.á This EPA voluntary program standardizes green power procurement as part of best practice environmental management.á Partners in the program pledge to switch to green power for a specified minimum percentage of their electricity needs in return for EPA technical assistance and recognition.
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EPA Recognizes 18 Leading Organizations for Efforts to Cut Energy Bills

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EPA recognized 18 organizations for achieving significant energy savings and leading their fields in responding to the agency's Energy Star Building Challenge. Those honored for achieving at least 10% energy savings included school districts, a hospital and supermarket, hotel, banking and commercial real estate companies.á They were recognized by EPA Administrator Stephen L. Johnson who also re-issued the challenge, emphasizing improved energy efficiency as a solution to rising energy costs. "Whether you are running a business, a school, or a household, getting the most out of our energy dollars just makes sense," said Johnson.á
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The organizations recognized used EPA's national building energy performance rating system which helps building managers score the efficiency of their buildings on a scale of 1 to 100, set goals for improving building efficiency, and document their improvements.á These organizations have either documented a 10% or greater improvement across all the buildings within their organization, or have earned an exemplary average rating across all of their buildings.á EPA's national building energy performance rating system has been available since 1999, and more than 20,000 buildings have been rated.
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EPA announced the Energy Star Commercial Building Challenge last spring, encouraging each building owner and manager to make their buildings more efficient.á Commercial and institutional buildings use about $80 billion worth of energy each year and contribute about 20% of U.S.
greenhouse gas emissions.á EPA estimates that if each building owner met the challenge, the annual energy savings would be $10 billion.
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The 2005 Energy Star Leaders are:á Buehler Food Markets; Cambridge Savings Bank; Colorado Springs School District 11; Columbus Hospitality; Douglas, Emmett & Company; Food Lion, LLC; Giant Eagle, Inc.; Granite Properties; Gresham-Barlow School District; H-E-B Grocery Company; Independent School District 197; New York Presbyterian Hospital; Rochester City School District; Saunders Hotel Group; South Colonie Central School District; USAA Real Estate Company; The Vanguard Group; and York County School Division.
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Restaurant Sentenced for Release of Asbestos

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On Oct. 12, Wilshire Restaurant Group, Inc., owner of Marie Callender's Pie Shops, Inc., was sentenced in U.S. District Court for the District of Utah for negligently releasing asbestos while replacing the roof of the Marie Callender's restaurant in Midvale, Utah.á The defendant will pay a $50,000 fine.á The defendant was also ordered to conduct an asbestos survey of its Utah stores, develop an asbestos management plan for the stores and properly train its executives.á In addition, the company will voluntarily contribute $50,000 to the Western States Project for use in providing environmental enforcement and investigation training to state and local government personnel in Utah.
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In January or February 1999, the defendant's employees at the restaurant noticed the roof was leaking and made temporary repairs.á In May 1999, Marie Callender's received several bids to repair the roof.á However, the firm that won the contract was not informed by Marie Callender's employees that costs for properly removing asbestos-containing materials were part of the other bids.á As a result, the asbestos underlayment was removed without following federal workplace standards, and asbestos fibers were released into the air.á
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EPA Tool Helps States Show Air Quality Improvements from Commuter Programs

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With new guidance from EPA, state and local air pollution control agencies can demonstrate air quality improvements from commuter programs that encourage carpooling, public transit or other commuting alternatives that cut emissions by reducing the number of cars on the road. EPA released its guidance document to use in determining pollution reductions for their State Implementation Plans (SIPs) and transportation conformity determinations required by the Clean Air Act. EPA is also releasing its updated COMMUTER Model, which is a software tool for estimating the benefits of these programs, such as changes in vehicle miles traveled, emissions, and fuel consumption. Programs like EPA's Best Workplaces for Commuters cut the number of vehicles on the roads, leading to reductions in air pollution. Best Workplaces for Commuters is a partnership program between EPA and the U.S. Department of Transportation, and private and public-sector employers throughout the country. Transportation planners use these types of reductions in SIP and conformity determinations. Areas that are do not meet federal standards for particulate matter and ozone may be eligible to use these credits as they demonstrate how they will meet EPA's national air quality standards. Many tools are available for quantifying the effectiveness of voluntary emission control measures. One of them is the newly revised COMMUTER Model. The model will allow planners to calculate their emission credits by including information such as number of employees, trip length, local travel information, vehicle fleet mix, and season. The model can also be used to forecast changes in emissions, vehicle miles traveled, and volume and value of fuel saved.

Mercury Marine Agrees to Three Projects and $40,000 Penalty

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EPA Region 5 reached an agreement with the Mercury Marine Division of Brunswick Corp. on alleged clean-air violations at the company's secondary aluminum production facility that makes boat motors in Fond du Lac, Wis.
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Mercury Marine has agreed to complete three environmental projects to protect public health and to pay a $40,000 penalty. For its first environmental project, Mercury Marine will install three vapor recovery systems at its Fond du Lac facilities and one vapor recovery system at its Oshkosh, Wis., plant at a cost of $27,500. For its second project, the company will install a vapor saver system costing $28,000 at its Fond du Lac facility.á The third environmental project includes spending $107,750 for the purchase and installation of diesel oxidation catalysts on vehicles owned by Mercury Marine, the city of Fond du Lac, Fond du Lac County and other municipalities in the area.
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The agreement resolves EPA allegations that Mercury Marine failed to comply with federal operating, planning, notification, reporting, testing and recordkeeping requirements for its Fond du Lac plant. Specifically, EPA said the company failed to do timely testing for dioxin and furan emissions.
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Two Pesticide Manufacturers Fined for Failure to Report and Improper Label

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EPA has issued Consent Agreement and Final Orders (CAFO) to two companies for violating the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The McGregor Company of Colfax, Washington was cited for failing to report a pesticide in an annual production report. Libertas Now, Inc. of Washington, D.C. was cited for failure to properly label a pesticide imported into Washington State. According to EPA officials: The McGregor Company produces pesticides in twenty-eight locations across Idaho, Oregon and Washington State. In June 2004, the Washington Department of Agriculture inspected McGregorÆs Waitsburg, Washington facility. The inspectors found that the facility was producing a pesticide called Harmony Extra XP. McGregorÆs 2004 annual pesticide production report failed to include Harmony Extra XP as required under the federal pesticide law. McGregor has agreed to pay a penalty of $2,624 to settle this matter. Libertas Now, Inc. is a new pesticide registrant and recently registered a pesticide called Knockout Extra. In May 2005, the company received their first shipment of nearly 80,000 Lbs of Knockout Extra from China. At a routine import inspection EPA discovered that the individual product containers did not have end-use labels, as required by federal regulation. EPA issued a Stop Sale Order on May 25, which prohibited the sale and distribution of the product until properly labeled. In settling the case Libertas has also agreed to pay a penalty of $3,120. öFollowing the proper labeling and reporting requirements allows us to maintain a safe pesticide industry in the United States,ö said Scott Downey, EPAÆs Northwest Regional Pesticide Program Manager. ôMcGregor and Libertas made a mistake, owned up to it and are ready to continue to safely distribute their products.ö
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EPA Issues Penalties of $600 - $7,500 for Violations of the Risk Management Program

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EPA recently issued penalties to 21 facilities in Washington, Oregon, Idaho and Alaska. Most of the penalties were due to late refiling of Risk Management Plans (RMP's). One penalty was for an inadequate Risk Management Program. All of these penalties were conducted under EPA's Expedited Settlement Agreement process and ranged between $600 and $7,500. "RMP's are required to be fully updated and resubmitted at least every five years. Despite at least two written reminders, many facilities did not resubmit their plans timely. EPA is not able to regularly provide reminders to RMP facilities, therefore they need to be cognizant of their anniversary dates and program requirements," said Kelly Huynh, EPA's RMP Coordinator. The penalties were assessed under Section 112(r) of the federal Clean Air Act. Section 112(r) requires the development of Risk Management Programs and submittal of RMPs for all public and private facilities that manufacture, process, use, store, or otherwise handle greater than a threshold amount of a regulated substance(s) within the system. Some of the toxic and flammable chemicals covered by the program are Ammonia, Chlorine, Propane, Sulfur Dioxide, Formaldehyde. The Risk Management Program requires such elements as development of an emergency response strategy, evaluation of a worst case and more probable case chemical release, operator training, review of the hazards associated with using toxic or flammable substances, operating procedures, and equipment maintenance. RMPs are basically checklists containing the elements of the program that are used by local emergency responders in protecting the public from accidental chemical releases. There are 477 facilities in Washington, Oregon, Idaho and Alaska that need to meet the RMP and program requirements.
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Stronger Water Quality Protections Launched

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Pennsylvania Governor Edward G. Rendell announced stronger regulations for large-scale farming operations and new manure management requirements for all agricultural operations to protect Pennsylvania waterways.
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The sweeping changes go beyond federal requirements and provide a comprehensive solution to nutrient management problems in the state, balancing the needs of the stateÆs agricultural community with efforts to protect the integrity of commonwealth water resources.
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ôPennsylvania has been a leader in working with the agricultural community to address nutrient management issues,ö Governor Rendell said. ôThese regulations were crafted in partnership with the stateÆs farmers and designed to protect the rural quality of life while supporting commercially competitive agricultural production. Implementing these new rules will keep our environment clean and ensure farming remains a critical part of PennsylvaniaÆs economy.ö
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Pennsylvania was the first state to enact nutrient management laws for farms, as well as a leader in setting up a federally approved permit program for large-scale farming operations.
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These new requirements, issued by the DEP, go beyond federal regulations, expanding the number of farming operations considered Concentrated Animal Feeding Operations from 165 to 350, therefore requiring more operations to obtain permits. CAFOs are large farming operations with a high number of animals. These operations produce large amounts of animal waste, which must be properly managed to protect water quality.
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Together with nutrient management regulations developed by the Department of Agriculture and currently being implemented by the State Conservation Commission through county conservation districts, the number of highly regulated farms will jump by 600%. More than 5,000 farms soon will have full nutrient management plans as well as vegetative buffers or setbacks along the edge of streams to protect Pennsylvania waterways.
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ôWith a greater number and broader variety of farming operations now covered, Pennsylvania can boast some of the most comprehensive and progressive agricultural regulations in the nation,ö DEP Secretary Kathleen A. McGinty said.
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To enhance water resource protection and water quality, revisions were made that clarify and strengthen requirements related to agricultural operations, including provisions for manure storage facilities and land application of manure. This includes minimum setbacks and buffers along the edge of streams where no manure can be applied.
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Under the new regulations, Concentrated Animal Feeding Operations now are required to set up either a 100-foot setback or a 35-foot vegetated buffer from water bodies for manure application. Farms that import manure must meet the same setback and buffer requirements as the farm that produces the manure. More large manure storage systems also will require DEP permits.
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In addition, these revisions bring PennsylvaniaÆs program in line with the federal CAFO rule, enabling the commonwealth to maintain delegation of the National Pollutant Discharge Elimination System (NPDES) permitting program for CAFOs.
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Sunoco to Pay $123, 730 in Penalties, Emission Fees

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Pennsylvania DEP Southeast Regional Director Joseph A. Feola announced that Sunoco Inc. will pay a total of $123,730 for air quality permit violations and past emission fees for its petroleum refinery in Marcus Hook Borough, in Pennsylvania
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Penalties against the refinery have totaled more than $4 million. This settlement addresses violations noted during a DEP facilitywide compliance evaluation that began in May 2003 at the refinery. Violations include numerous record-keeping errors; incomplete reports; under-reporting emissions; and exceeding permit limits for air toxics and volatile organic compounds (VOCs).
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A total of 12 notices of violation were issued during the course of the inspections, one of which was issued in March 2005 and settled in May for $825,236. This Oct. 25 agreement settles violations noted in the remaining 11 violation notices.
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In June, DEP Secretary Kathleen A. McGinty announced PennsylvaniaÆs participation in a $6.9 million federal consent decree with the U.S. EPA, other city and state environmental agencies, and Sunoco for violations at the Marcus Hook refinery as well as the companyÆs refineries in Philadelphia; Tulsa, Okla.; and Toledo, Ohio.
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Pennsylvania will receive $900,000 of the $3 million cash portion of that settlement and an additional $300,000 of the $3.9 million slated to fund supplemental environmental projects.
Terms of the June 2005 federal consent decree also require Sunoco to install additional control equipment at its Marcus Hook refinery by 2010, further reducing sulfur dioxide and nitrogen oxides emissions. Nearly $60 million worth of environmental control equipment is scheduled for installation at this refinery over the next eight years.
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The $123,730 penalty and terms of the recent agreement are not included in the federal action.
In September 2002, DEP assessed a nearly $3.5 million civil penalty against Sunoco for failing to install reasonably available control technology air pollution control equipment on a timely basis on two nitrogen oxide-emitting boilers in Marcus Hook. Although initially appealed by the company, the Environmental Hearing Board upheld DEPÆs action and penalty amount in April 2004.
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Acid Rain Program Maintains Air Pollution Cuts

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In its 10 years the Acid Rain Program has significantly reduced acid deposition in the US by cutting sulfur dioxide (SO2) and nitrogen oxide (NOx) emissions from power plants, according to the program's annual report.á The newly released Acid Rain Program 2004 Progress Report describes the environmental advances and public health, technology, and market-based improvements accomplished by the program.á Widely acknowledged as one of the most successful environmental programs in U.S. history, the program serves as a model for a new generation of air pollution control programs, such as the Clean Air Interstate Rule, which will further reduce air pollution over the next decade.
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"Skeptics of innovative market-based solutions need only look at the phenomenal results achieved by the Acid Rain Program," said EPA Administrator Stephen L. Johnson. In 2004, electric power generation sources reduced their annual SO2 emissions by about 34% - a decrease of over 5 million tons when compared to 1990 levels.á Compared to 1980 levels, SO2 emissions from power plants have dropped by 7 million tons, or more than 40%.
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NOx emissions were down by about 3 million tons since 1990 and had decreased to nearly half the level anticipated without the Acid Rain Program.á Other NOx regulations that also affect power plants, such as the NOx Budget Trading Program in the eastern US, also contributed to this reduction.
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The key environmental driver for the Acid Rain Program is a mandatory 8.95 million ton cap on SO2 emissions.á The Program allows sources to buy and sell "allowances" (statutory authorizations to emit SO2).á By reducing emissions early, sources can save (or bank) allowances and use them to cover excess emissions in years when the energy demand is higher.á Thus, annual fluctuations in SO2 emissions are expected, but the total amount of emissions over the course of the program is fixed and will not increase.á In addition, a source's emissions may not exceed National Ambient Air Quality Standards at any time.
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Overall compliance with the Acid Rain Program has been consistently high -- nearly 100%.á In 2004, only 4 units out of the 3,391 electricity-generating units did not hold enough allowances to cover their emissions.á These sources were assessed an automatic penalty of $2,963 per ton for each of the 465 tons of SO2 emitted in excess of allowances, totaling a fine of $1.4 million.á In addition, 465 allowances were taken from sources' accounts to ensure that there would be no net increase in emissions.
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A new analysis in the Journal of Environmental Management estimates the value of the program's human health and environmental benefits in the year 2010 to be $122 billion annually.á Most of these benefits result from the prevention of health-related impacts, such as premature deaths and illnesses and workdays missed due to illness, but they also include improved visibility in parks and other recreational and ecosystem improvements.
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The Acid Rain Program has provided the most complete and accurate emissions data ever developed under a federal air pollution control program, and it made that data available and accessible for agencies, researchers, affected sources, and the public by using comprehensive electronic data reporting and Web-based tools.á The program has resulted in nearly 100% compliance through rigorous emissions monitoring and allowance tracking, and an automatic, easily-understood penalty system for noncompliance.
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Hospitals to Sign Expedited Agreement for SPCC Violations

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A hospital in Sanford, Maine and another in Exeter, N.H. have each agreed to pay $3,000 in penalties to resolve EPA claims that they had violated the federal Clean Water Act by not having proper plans in place to prevent oil spills.
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Exeter Hospital and Goodall Hospital both agreed to these reduced penalties under an expedited settlement program of EPA's New England office. These settlements represent the first two times that EPAÆs New England Office has negotiated an Expedited Settlement Agreement for a case involving violation of the Oil Pollution Prevention Regulations of the federal Clean Water Act.
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ôAll facilities, whether big or small, need to abide by the law requiring plans to prevent oil spills,ö said Robert W. Varney, regional administrator of EPA's New England regional office. ôWe do, however, appreciate such a quick response as we saw at these two hospitals, and for this reason were willing to consider reduced fines.ö
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The Expedited Settlement Agreement is designed to resolve easily correctable violations of the Oil Pollution Prevention regulations detected during an EPA inspection. Under the terms of the agreement, the facility has the option to correct the violations and pay a reduced penalty. If the facility does not sign the agreement, EPA may pursue a more traditional enforcement action, likely resulting in higher penalties.
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Facilities that can store more than 1,320 gallons of oil in above-ground tanks, or 42,000 gallons below ground, are required to have ôSpill Prevention, Control and Countermeasureö plans, also known as SPCC plans, if it could reasonably be expected that a discharge of oil from the facility would directly or indirectly reach a body of water or its adjoining shoreline in a worst case scenario. The purpose of the SPCC program is to prevent spills before they happen, thus the need for a properly prepared and implemented plan is crucial to the success of the program.
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Although both hospitals store oil in amounts above the thresholds requiring the preparation and implementation of an SPCC plan, EPA inspections revealed that they did not have such plans. Because of the relatively small quantity of oil stored at each hospital, and the fact that the hospitals had some secondary storage containment, which is a major requirement under the Oil Pollution Prevention regulations, EPA decided to use expedited agreements to resolve the violations. The expedited settlement process for violations of the Oil Pollution Prevention regulations has been used successfully in other EPA regions.
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Question of the Week


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Releases of hazardous substances to the environment must be reported immediately in accordance with 40 CFR 302.6(a) and 355.40.á It has been EPAÆs interpretation that the immediate report to be within how many minutes of discovery?
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a. 15 minutes
b. 30 minutes
c. 60 minutes
d. 90 minutes
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Answers