Regulatory Updates

1-bromopropane (1-BP) Listed as Hazardous Air Pollutant

New permit requirements may apply to some Nevada businesses Effective February 4, 2022, the US EPA listed 1-bromopropane (1-BP), also known as n-propyl bromide (nPB), as a Hazardous Air Pollutant (HAP) that “may reasonably be anticipated to cause adverse effects to human health”. The addition of 1-BP to the HAP list could have an impact on the air quality permitting requirements for some businesses in Nevada. Used primarily as a cleaning solvent, 1-BP may be found in a wide variety …

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Spring Cleaning at Your Facility?

CONSIDER A PLANNED EPISODIC GENERATION EVENT FOR SMALL AND VERY SMALL QUANTITY GENERATORS Are you planning a spring cleaning at your facility that could involve disposing of hazardous materials? If so, you should consider taking advantage of a new provision in Nevada which allows an annual planned episodic hazardous waste generation event to clean up and dispose of old chemicals, tank residues, and outdated lab chemicals without changing your generator status.An important rule to follow for a planned episodic generation …

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Updates Planned for Class II General Air Quality Operating Permit for Temporary Construction Sources

NDEP to Host In-Person and Virtual Workshop to Discuss Changes on March 24th at 2:00pm If you are a construction facility (hot mix asphalt, concrete batch plant, or sand/gravel crushing and screening) and have an Air Quality permit with the Nevada Division of Environmental Protection (NDEP) or are planning on applying for or renewing your permit, you should be aware of the upcoming updates to the Class II General Air Quality Operating Permit for Temporary Construction Sources. This permit is …

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EPA Announces New TSCA Fees

In accordance with the Toxic Substances Control Act (TSCA), the US Environmental Protection Agency (EPA) is required to adjust the TSCA fee requirements every three years. The new fees will go info effect on January 1, 2022.TSCA addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls (PCBs), asbestos, radon and lead-based paint.To learn more about how the new fees were determined and to review the new TSCA fee schedule, click here.

PERC Dry CLeaning – Proposed Changes

On December 1st, the US Environmental Protection Agency (EPA) proposed amendments to the 1993 National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Perchloroethylene (PCE) Dry Cleaning facilities. The deadline for the final rule is December 1, 2022.As a result of a technology review, EPA is proposing to add provisions to the rule which will require all new and existing dry-to-dry machines to have both refrigerated condensers and carbon adsorbers as secondary controls. Even though almost all currently operating dry cleaning machines …

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Oil and Gas Industry Emissions Reductions

The US Environmental Protection Agency (EPA) is proposing a new rule that will reduce methane and other air pollutants from new and existing sources in the oil and natural gas industry. One method for accomplishing this would include a monitoring program to require companies to find and fix leaks at new and existing site and compressor stations.  The EPA will be hosting a virtual training for small businesses, tribal communities, and environmental justice communities on November 16th –  18th from 9:30 AM – 3:30 PM, …

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Attention Large Quantity Generators: Biennial Reports Due March 1, 2022

Is your facility a Large Quantity Generator (LQG)? A LQG facility generates at least 2,200 lbs of non-acute hazardous waste, or more than 2.2 lbs of acute hazardous waste in a month. If this status applies to your facility, then a Biennial Hazardous Waste Report must be filed with the Nevada Division of Environmental Protection by March 1, 2022. Who must file a Biennial Hazardous Waste Report? Any facility that generated at the LQG levels for at least one month in 2021 or is permitted …

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Final Rule for the Phasedown of Hydrofluorocarbons

Final Rule Notice Signed by US EPA Administrator September 23, 2021 What are hydrofluorocarbons? Hydrofluorocarbons (HFCs) were initially manufactured as replacements for ozone-depleting substances in refrigeration, air conditioning, aerosols, fire suppression, and foam blowing sectors. While helping protect the stratospheric ozone layer, HFCs are unfortunately also greenhouse gases that contribute to the warming climate. What is required? The American Innovation and Manufacturing Act (AIM) authorized EPA to address HFCs in three ways: (1) phasing down production and consumption, (2) maximizing reclamation …

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Toxic Substances Control Act (TSCA) Inventory

Did you know that the US Environmental Protection Agency (EPA) maintains a list of all “existing” chemicals called the Toxics Substances Control Act (TSCA) Inventory? This is a requirement of Section 8(b) of the Toxic Substances Control Act. Why is this important? If you plan to manufacture a chemical you must first check the TSCA Inventory to see if the chemical exists and if there are any importing or manufacturing restrictions. If the chemical does not exist, you must follow EPA’s review …

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