EPA Finalizes Hazardous Waste Generator Improvements Rule.
On November 28, 2016, the U.S. Environmental Protection Agency (EPA) published in the Federal register the final Hazardous Waste Generator Improvements Rule. This regulation amends the requirements governing hazardous waste generators under the Resource Conservation and Recovery Act (RCRA). Even though EPA states that the new regulation was needed to improve clarity and flexibility of hazardous waste generator requirements, the rule will add regulatory burdens, including new recordkeeping, labeling and notification requirements, with minimal benefit to human health or the environment.
TRI Form R Reporting Threshold Determinations for Manufactured Metal Compounds in Plating Baths.
EPA has recently acted to enforce the reporting obligation contained in Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) that applies to surface finishing processes. The rules require facilities that manufacture, processes or otherwise uses a toxic chemical in an amount exceeding an applicable threshold quantity of that chemical during a calendar year to report releases of listed hazardous substances. If a facility is required to report such releases, a toxic release inventory (TRI) Form R must be submitted to EPA and to the state. In the surface finishing process intermediate compounds are coincidentally manufactured as the metal is brought into solution. For example, copper, nickel, zinc and chromium compounds are being formed and unformed through the chemical reactions in the plating bath. These manufactured metal compounds must be calculated to determine the amount of chemical compounds that are manufactured, processed or otherwise used for threshold reporting levels. NASF has produced compliance assistance tools to help.
Regulatory Alert: California Targeting Finishing Air Emissions Below Nanogram Levels
POSTED: March 30, 2017
Prompted by concerns over elevated air monitoring levels of hexavalent chromium in a southern California neighborhood, the South Coast Air Quality Management District (SCAQMD) is expected to propose revisions to its Rule 1469 - Hexavalent Chromium Emissions from Chrome Plating and Chromic Acid Anodizing Operations and Rule 1426 - Emissions from Metal Finishing Operations. Read more ...
NASF Finalizing Metals Discharge Study: Presentation to EPA at April Washington Forum
POSTED: March 30, 2017
The NASF through its Government Advisory Committee is nearing completion of a milestone review and case study of the industry's progress in reducing wastewater discharges throughout a nearly 30-year period. The study compares metals discharged by permitted finishing operations in Milwaukee from 1989 to 2016. It evaluates total metals reductions from companies to the municipal treatment plant, average reductions on a per facility basis, and the relative contribution of the finishing industry versus the larger universe of industrial dischargers in the community. Read more ...
POSTED: December 6, 2016
The U.S. Environmental Protection Agency in early December proposed a new Superfund cleanup rule that NASF members should watch closely. The new proposal stems from an agency hazardous waste initiative under the Obama Administration that covers metal finishing as well as several other manufacturing sectors.
The latest proposed rule, which industry anticipated throughout 2016, would subject hard rock mining companies to a determination of future cleanup responsibilities and require each company to obtain bonds or insurance or self-assure to cover the cost of that clean up.
This is an important development for NASF members and finishing operations nationwide. A few years ago, EPA listed metal finishing on the list of sectors that would be targeted for what would be new, extremely burdensome requirements under the federal Superfund law that could potentially bankrupt both small and large companies.
NASF Has Advised Dropping Financial Assurance Requirements
NASF has been monitoring the rule’s progress for several years and held discussions with EPA, arguing that the agency’s approach was misguided on several fronts. EPA more recently expanded the metal finishing category to cover more facilities in the larger fabricated metals sector.
Outgoing EPA Assistant Administrator Mathy Stanislaus, who heads the federal hazardous waste program, argues that the agency’s approach of requiring a company to secure a bond, letter of credit or other financial assurance mechanisms would lead to more cleanups in the U.S.
“This proposed rule, once finalized, would move the financial burden from taxpayers, and ensure that industry assumes responsibility for these cleanups,” Stanislaus said. “The proposed rule would also give companies an economic incentive to use environmentally protective practices that can help prevent future releases.”
Mining Industry Shared “Case Study” with NASF Members in Washington
This past year, attendees at the NASF Washington Forum heard from National Mining Association’s Tawny Bridgeford, who highlighted the mining industry’s experience as a “case study.” She noted that the onerous EPA requirements in the pipeline for miners would severely impact surface finishing facilities if the rules weren’t curbed early in the process.
The proposed rule, which wasn’t yet published in the Federal Register at press time, formally identified the next group of sectors in the pipeline for financial assurance rules, specifically electric power generation, transmission and distribution, petroleum, and coal products manufacturing.
The results of the presidential election, however, clearly will have some bearing on the outcome of the regulations in 2017. Because the agency released its proposal so late in the year, it’s possible that a new EPA under the incoming Trump administration will elect not to make the rule final in the new year.
NASF Leadership Conference
Feb. 26 - March 2, 2017
NASF Washington Forum
April 25-27, 2017
June 19-21, 2017
The Foundation was constituted in 2006 to support the emerging demands of global surface technology value chain. Our Educational Programs are well recognized in the industry and include:
- Class Room Courses
- Home Study
- Custom Courses
- Advanced Surface Technology
We offer globally recognized certification, starting with the basic level Certified Electroplater-Finisher (CEF), all the way to Master Surface Finisher (MSF). To find out more about AESF Foundation educational materials, register for courses on-line, or down load a course catalog, click here.
STERC ONLINE TOOLS
To supplement our free on-line compliance assistance resources, we have developed special educational materials. These include:
- A Library - Extensive on-line technical library (over 8,000 documents)
- Pollution Prevention & Control Technology Manual - Comprehensive book covering pollution prevention and control technologies
- Hard Chrome Plating Course (book and on-line)
- On-line Tools such as the Plating Calculator and other resources
These items can be purchased as single products or combined into affordable packages. For more information, click here.