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Zephyr
The Newsletter of the Allegheny Mountain Section
of the Air and Waste Management Association
   Volume 25/ Issue 6/  June 2007 Our Sponsors | Advertisers | Luncheon | Events | Contact |  Home | 

The Zephyr

The Zephyr covers news and events of the Allegheny Mountain Section of the Air & Waste Management Association plus regional and national environmental news in the fields of air pollution, water, wastewater, solid waste and environmental management. The Zephyr is published monthly 10 times per year, around the first of the month as a service to Section members. Archive versions of previous editions for the last year can be found here. Print versions are mailed to Section members on request.

Contributions, questions, suggestions, or comments on the Zephyr are welcome and should be submitted by email to rmclaren @ city-net.com  Publication deadline is the 17th of the month for distribution around the first of the following month. The editors reserve the right reject or edit contributed articles as they feel appropriate.

In This Issue:
© Copyright 2007 Allegheny Mountain Section A&WMA. All rights reserved.     

 

From the Chair

Randy York, Chair
Allegheny Mountain Section

randall.york @ erm.com




So we are heading into the home stretch. Most of the “I”s have been dotted and the “T”s have been crossed. The organizing committee continues to push forward, but the prize is in sight!. The Centennial Celebration and Annual Conference and Exhibition is just around the corner. I am looking forward to seeing all of you there. If you haven’t registered, you still have time! Call me, or any of the section officers if you have any questions, or need information. We will all do our best to accommodate you.

After the conference, the Section will take a well-deserved break, but we will be back in full force in September. The Program Committee has been diligently lining up some nice programs for when we get back. Watch your emails through the summer, and the Zephyr will emerge again in September.

Now, I hope it isn’t too soon to go to the well again, but as is often the case, we need your help again. For those of you who have been paying attention, you might have noticed that those of us who joined the environmental profession in the early days of the Clean Water Act, RCRA, CERCLA, the Clean Air Act, and even the 1990 Amendments have become a little “long in the tooth”, as they say. As go the demographics of the profession, so goes the demographics of the Association. One of the missions of the Air & Waste Management Association is to promote the environmental profession and to support those who will continue to carry the torch. We have recently formed a Young Professionals Committee to help our section better serve the needs of those who have recently entered the workforce. The next step in our planning for the future is to re-energize our focus on students.

Most of you know that our Allegheny Mountain Section includes in our ranks two Professional Chapters – Northwest PA and West Virginia. But how many of you knew that we also have two Student Chapters – Three Rivers and Slippery Rock? Unfortunately, activities at these chapters have been somewhat in the doldrums over the last few years. I am now asking for your help. We need to assemble a group of you who would be interested in engaging the local universities, working with our partners in academia, and finding ways to bring the value of the Air & Waste Management Association to the next generation of environmental professions. PLEASE – if you enjoy working with young adults, and wish to give back to the profession, call me at 724-933-5444 or email me at randall.york@erm.com. We will be planning over the summer and hope to have a Student Focus Steering Committee up and running for the start of 2007-2008 school year. The Steering Committee will work with the Membership Committee and the Young Professions Committee to help boost our student involvement and jumpstart our Student Chapters. I look forward to hearing from you.


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Section News

News about and of interest to

members of the

Allegheny Mountain Section

Editor-in-Chief: Arijit Pakrasi, 412/858-3921, e-mail:Arijit.Pakrasi @ shawgrp.com

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See The Show




In just a few short weeks (June 26th), the curtain will open on the 2007 Centennial Annual Conference and Exhibit of the Air & Waste Management Association (A&WMA) here in Pittsburgh. As all who have been following Zephyr already know, this year’s event offers much: provocative keynote speakers; a sold-out exhibit hall; hundreds of paper presentations; technical and social tours; boat rides; receptions and even a golf outing (June 25th at Highland Country Club – replaces the Allegheny Mountain Section’s annual outing this year).

If you have not done so already, please consider registering for the Conference, even if only for one day. As listed elsewhere in this Zephyr, there are some nice discounts available for members of our Allegheny Mountain Section, including the West Virginia and NW PA Chapters. We are hoping for 100% participation from our Section.

We are still looking for volunteers to help monitor sessions, staff our local Section booth and otherwise help us host our visitors. Volunteer monitors earn a free day of registration for each day they volunteer. Holding this Conference in Pittsburgh is an opportunity that, at best, comes only once per generation. Come, see the show.


Joe Duckett
May 15,2007
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AMS Monthly Board of Directors Meeting Summary


The AMS Monthly Board of Directors Meeting was held at the ACHD Conference Room on May 7, 2007.

Randy York reported that the Business of Brownfields Conference went well and that several vendors were advised to sign up for the ACE exhibit. The Conference also generated general membership interest was generated through exhibit visitors as well.

Jill Pouliot reported that 30-35 people attended the first Young Professional’s event that was held on May 3rd during happy hour at Station Square.

Dave Testa reported that the Scholarship Committee met last month and reviewed three applications for the scholarship. Two were awarded to future Penn State students and they were also invited to the May and June luncheons. The Board voted that the Section pay for all three applicants’ student memberships.

Harilal Patel reported that the Education Committee distributed 250 letters for the 2007-2008 Adopt-a-School program.

Randy York shared three iterations of the Sections & Chapters poster for the ACE. He and Matt Milanek will finalize.

Respectfully submitted,

Meghan Blaney, Secretary


Scholarships Awarded

This year’s Allegheny Mountain Section scholarship program was quite a success! Two (2) $1,500 scholarships were awarded, one to Mr. Daniel Pollak, who will be a freshman at Penn State’s Main Campus majoring in Meteorology, and another to Mr. Jeffrey Attig, who will also be a freshman at Penn State’s Main Campus majoring in Environmental Resources Management.

Congratulations to Daniel and Jeffrey and here’s to seeing you both as student members while in college and international members as successful environmental professionals.

I would very much like to thank Meghan Blaney and Jill Pouliot, both from ERM, for their help in reviewing the scholarship applications.

Dave Testa, QEP
Allegheny Mountain Section, Scholarship Chairman


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Feature Articles

News about and of interest to

members of the

Allegheny Mountain Section


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PA NSR RULES NOW EFFECTIVE


The new Pennsylvania air construction permit rule was published on Saturday, May 19, 2007 at 37 Pa. B. 2365 or www.pabulletin.com/secure/data/vol37/37-20/924.html. The new rules are effective immediately and apply to all permit applications under review on May 19th in Pennsylvania (and probably Allegheny County as well). Although this rule became effective with a couple of weeks of the date DEP projected six months ago, DEP has not provided any training to its staff or the public on how to implement the new rules, which is certain to delay processing of new permits and hurt economic development efforts. I personally think this is outrageous, and you should bring this reflection of DEP Air Quality’s “business friendly” attitude to the attention of your Pennsylvania legislators.

DEP has established a committee to talk about NSR training, but no schedule was available. AMS-AWMA will provide a program on this rule if DEP cannot get its act together.

Harry Klodowski, Esquire
724-940-4000
Harry@KlodowskiLaw.com

DEP RETIRMENTS WILL HAVE AN IMPACT

Due to some wrinkle of the State Retirement Benefit Program, a remarkable number of senior DEP personnel have announced retirements in June 2007.

In the Central Office, Air Quality, Wick Havens, John Slade, and Mike Zuvich have announced retirement. Rick St. Louis, who retired in April, has been replaced by Dean Van Orden on an acting basis. Terry Black retired the day before trout season opened, good timing, Terry!

In the Pittsburgh Regional Office, the retirements are unprecedented. In Air Quality, Bill Charlton, Don Dodge and Bruce Frye are retiring. In other programs, a large group of program managers are retiring, including Gale Campbell (Tanks), John Matviya and Jim Shack (ECP), Steve Balta (Water), and Jay Tarara and Dave Plank (Drinking Water). Zelda Curtis of the Pittsburgh legal staff is also retiring.

These retirements will result in the loss of hundreds of years of experience at DEP. We should take the opportunity to thank these individuals for their many years of dedicated public service and devotion to the cause of environmental protection. ( I personally thank some of them for the work they have created for me over the years!) These moves will also create opportunities for others to move up. Everyone expects a serious budget cut at DEP in July, and it is not clear whether there will be money to replace some of the positions. We will be seeing the impact of these changes for months, perhaps years, to come.
Harry Klodowski, Esquire
724-940-4000
Harry@KlodowskiLaw.com

PA Glass Furnace Rule Announced


At the May 17, 2007 Air Quality Technical Advisory Committee (AQTAC) meeting DEP released a draft of a Pennsylvania Glass Furnace proposed rule which would apply to all glass, and fiberglass, melting furnaces with emissions or potential emissions of more than 50 tpy NOX annually. The rule is essentially borrowed from a San Joachin, CA APCD rule and imposes emission limits of 4 pounds per ton NOX for container glass and fiberglass furnaces, and 9.2 pounds for flat, pressed or blown glass, effective May 1, 2009. The draft allows for facility wide averaging, averaging among PA. furnaces under common ownership, and purchase of CAIR NOX allowances to cancel excess emissions. CEMS are required for compliance monitoring.

DEP requested the AQTAC to approve this rule at the next meeting on July 26 2007 and submit it to the EQB in October 2007. DEP did not present any information on the facilities affected, cost of controls, or the anticipated emission reduction from this rule, and appears to have done little independent evaluation of this proposal.
There is no indication DEP considered why the applicability threshold is so low-50 tpy; whether the rule would achieve any significant reduction from existing smaller glass operations, or considered the financial impact on smaller plants. The proposed text is available at: http://www.dep.state.pa.us/dep/subject/advcoun/aqtac/2007/5-17-07/GLASSANNEXA05172007AQTAC.doc


Harry Klodowski, Esquire
724-940-4000
Harry@KlodowskiLaw.com


Twisted Facts: "Soot Soars in city, but smog drops" article published May
1, 2007 Post-Gazette

Yesterday's "Soot Soars in City" article was a triumph of alarmism over
facts. The article was based on an American Lung Association study that
rated Pittsburgh just below Los Angeles for dirty air. A simple check of
the Lung Assn. website ( which, by the way, was referenced incorrectly in
the article) revealed that the study was about as unscientific as you can
get.
For their study, the air quality of each entire county in the US was based
only on the highest pollution measurement within that county. For areas
with only one monitoring site, this may make sense. Allegheny County,
however, has eight separate monitoring stations , only one of which ( the
Liberty station) exceeded the national standards for particulate pollution
during the study period. All seven of the other stations were at or below
the federal standards for both annual and daily measurements. Further, in
the first nine months of 2006 ( the most recent period for which data have
been reported) , even the Liberty station experienced no 24 hour levels
above the standard. So much for a "trend toward increased airborne
particulate pollution...".
Using one bad station to indicate air quality throughout the entire
metropolitan area is like rating the Pirates as a strong hitting team
based solely on Ryan Doumit's .429 batting average. It doesn't make common
sense, much less scientific sense.
This is not the first year that the P-G has reported the conclusions of
the Lung Association's annual study as if they were valid. The facts,
easily available on the Allegheny County Health Department website, paint
a very different picture. How about reporting facts instead of propaganda?

Joe Duckett
5 South Fork Drive
Pittsburgh, PA 15229

( 412) 365-3707
joseph.duckett@snclavalin.com
__________________________________

Pittsburgh is NOT the 2nd worst city in air quality

On May 1, 2007 the American Lung Association (ALA) released its 2007 "State
of the Air" report. In it the ALA listed Pittsburgh as the 2nd worst city
in the United States with regards to air quality. "This is a
misinterpretation of the air quality data of Allegheny County," says Jason
Maranche, Air Quality Engineer with the Allegheny County Health Department
(ACHD).

The Pittsburgh-Beaver Consolidated Metropolitan Area, consisting of
seven counties in southwestern Pennsylvania, has two separate EPA-designated
non-attainment areas for fine particulate matter. One, the Liberty/Clairton
area, consists of the Allegheny County Boroughs of Glassport, Lincoln,
Liberty, Port Vue, and the City of Clairton. One of the two monitors in
this area, the Liberty monitor, has monitored data at the level of the
second highest reading in the country. This is a serious problem, and the
ACHD is well into developing a plan to bring the area into attainment.

This poor air quality affects a population of about 25,000. However, it
does not affect the air quality of the City of Pittsburgh, the rest of
Allegheny County, or the remainder of the Southwestern Pennsylvania. The 10
monitors in the rest of Allegheny County, which during the 2003-2005 period
used in the ALA study, measured levels comparable to most major cities in
the Northeast United States.


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25 YEARS AGO:
Nuclear Waste Policy Act.

"In 1982, the Congress enacted the Nuclear Waste Policy Act (NWPA) and on January 7, 1983, the President signed it into law. This legislation defined the Federal Government’s responsibility to provide permanent disposal in a deep geologic repository for spent fuel and high-level radioactive waste from commercial and defense activities. Under amended provisions (1987) of this Act, the Department of Energy (DOE) has the responsibility to locate, build, and operate a repository for such wastes. The NRC has the responsibility to establish regulations governing the construction, operation, and closure of the repository, consistent with environmental standards established by the U.S. Environmental Protection Agency."

http://www.policyalmanac.org/environment/archive/nuclear_waste.shtml

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Internet Site Review

Internet Sites of Interest to Environmental Professionals
with Kim Walker

You can contact me at Kimberly.walker @ erm.com

___________________________________



http://www.earthportal.org/

The Earth Portal, online at www.EarthPortal.org, is the authoritative, comprehensive, non-commercial source for environmental news, education and debate online. The Earth Portal is the result of the global scientific community coming together in an unprecedented way to produce the first free, expert-driven, massively scaleable information resource on the environment. In addition, it will engage civil society in a public dialogue on the role of environmental issues in human affairs.
“The Earth Portal fills a major gap in the media landscape today,” said Dr. Jane Goodall, an advisor to the Earth Portal. “If we are to serve and save our ecosystems and all the living systems they support, we must first understand them, unfiltered by advertising-driven commercial interests.”
The Earth Portal includes the rapidly-growing and expert-edited Encyclopedia of Earth; the Earth Forum, with weblogs where leading scientists engage in ongoing conversations with the public; and Earth News, the latest reporting on the state of the environment. Here one can get the latest news on climate change or link to the weblogs for an online discussion about indoor air quality or chemicals in humans.

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A Word on Water

The Latest News on Water, Wastewater
and Related Topics
with Susan Z. Forney,
susan.zummo.forney@shawgrp.com

___________________________________


EPA Extends SPCC Compliance Dates Again
On May 10, 2007 EPA Administrator Steve Johnson signed a rule
(http://epa.gov/oilspill/extension.htm) to extend the compliance dates
for owners and operators of facilities preparing or amending and
implementing spill prevention, control, and countermeasure (SPCC) plans. This final rule extends the dates by which a facility must prepare or amend and implement its SPCC plan until July 1, 2009. EPA expects to propose further revisions to the SPCC rule in 2007. EPA has extended the compliance dates in order to provide the time necessary for the regulated community to comply with the revised requirements that EPA expects to propose in 2007.

For facilities (other than a farm) that started operations on or before Aug. 16, 2002, the facility must maintain its existing SPCC plan and amend and implement the plan no later than July 1, 2009. If the facility began operations after Aug. 16, 2002 through July 1, 2009, it must prepare and implement an SPCC plan no later than July 1, 2009. If the facility starts operations after July 1, 2009, it must prepare and implement an SPCC plan before beginning operations.

If a farm started operations on or before Aug. 16, 2002, it must maintain its existing SPCC plan and amend and implement the plan when EPA promulgates a rule specific for farms. If a farm began operations after Aug. 16, 2002, then it must prepare and implement an SPCC plan when EPA promulgates a rule specific for farms.

A factsheet is also available explaining changes in the regulation of animal fats and vegetable oils under the SPCC rule. More information may be found on EPA’s SPCC web site at www.epa.gov/oilspill.



EPA Decides to Not Regulate 11 Drinking Water Contaminants
The EPA has made a preliminary determination not to regulate 11 contaminants on the second drinking water contaminant candidate list (CCL). The agency's "preliminary regulatory determination," based on an extensive review of health effects and occurrence data, concludes that the specific contaminants do not occur at levels of public health concern in public water systems.

Two other contaminants - perchlorate and MTBE - require additional investigation to ascertain total human exposure and health risks. For those contaminants, EPA is providing a summary of current health, occurrence, and exposure information. The agency is seeking comment and additional information to help EPA's evaluations.

A regulatory determination is a formal decision on whether EPA should develop a national primary drinking water regulation for a specific contaminant. The Safe Drinking Water Act requires that EPA issue a CCL every five years for at least five contaminants from the most recent CCL. In 2005, the agency published the second CCL of 51 contaminants.

The 11 contaminants include boron, pesticides, herbicides, and chemicals used (or once used) in manufacturing. EPA monitored eight of the contaminants during the first round of the unregulated contaminant monitoring program and the remaining three during previous occurrence surveys. While none of the contaminants were found nationally at levels of public health concern, EPA is recommending that health advisories for seven of the contaminants be updated to provide local officials with current health information for situations where the contaminants may occur.

Senator Boxer introduced two bills on perchlorate on the first day of Congress, both cosponsored by Senators Diane Feinstein (D-CA) and Frank Lautenberg (D-NJ). The first bill (S. 24) would assure that tap water is tested for this toxin, and that the public is told if it is found in their water. The second bill (S. 150) would order EPA to quickly establish a drinking water standard that protects pregnant women, children, and other vulnerable people from perchlorate.

MTBE is a gasoline additive that moves quickly in the environment and has caused widespread contamination of drinking water wells across the country. EPA said in 1997 that MTBE is a potential carcinogen, but has not yet set a tap water standard for the chemical.

More information may be found at www.epa.gov/safewater/ccl/reg_determine2.html.


New EPA Tool to Accelerate Watershed Planning
The EPA has released the Watershed Plan Builder (www.epa.gov/owow/watershedplanning), an interactive, Web-based tool developed to improve efforts by states and local communities in protecting and restoring local water resources. The tool will help local watershed organizations develop integrated watershed plans to meet state and EPA requirements and promote water quality improvements.

Practitioners from watershed organizations, federal and state agencies, tribes, universities, and local governments will use the Watershed Plan Builder to address polluted runoff, the largest contributor to water quality problems nationwide.

Once the data are entered, the tool produces an outline of a comprehensive watershed plan tailored to a specific watershed. It features links to EPA, other federal agencies, and state water programs.

The Watershed Plan Builder walks the practitioner through various watershed planning steps:

* Watershed monitoring and assessment
* Community outreach
* Selection and application of available models
* Best management practices
* Implementation
* Feedback

During the next several months, the Watershed Plan Builder will be available to watershed organizations, federal and state agencies, tribes, universities, and local governments to beta test the application and provide feedback. A team of experts from EPA's water programs developed the tool, with input from state, tribal, and local agency experts as well as other local watershed practitioners.


EPA, State, Environmental Groups Promote "Green Infrastructure" Solutions to Water Pollution
EPA Administrator Stephen Johnson celebrated Earth Day by signing a statement of intent at the David L. Lawrence Convention Center with four national organizations to promote the use of "green infrastructure” (www.epa.gov/npdes/greeninfrastructure) approaches, such as rain-catching roofs and gardens, to lessen sewer overflows and runoff after storms.

The statement formalizes a collaborative effort among EPA, the National Association of Clean Water Agencies (NACWA), the Association of States and Interstate Water Pollution Control Administrators (ASIWPCA), the Natural Resources Defense Council (NRDC), and the Low Impact Development (LID) Center to assist state, city, and local governments in implementing and evaluating innovative and effective green infrastructure approaches.

Through green infrastructure techniques, stormwater and its pollutants are managed using natural systems to help absorb, infiltrate, evaporate, or reuse excess stormwater instead of using traditional infrastructure that collects, stores, and transports water through large, buried sewer systems. Rain barrels and cisterns, roofs that are covered with vegetation and plantings, tree boxes, rain gardens, and pocket wetlands are just a few examples of common green infrastructure approaches. Water is treated as an important resource rather than a waste product.

A variety of initiatives are included in the statement of intent. EPA and its partners plan to offer technical assistance, training, and outreach to potential users of green infrastructure, including states, cities, counties, utilities, environmental and public health agencies, engineers, architects, landscape architects, planners, and nongovernmental organizations.

The creation of a Web-based green infrastructure resource center will assist communities in complying with requirements for combined sewer overflows and municipal stormwater permits. EPA also seeks to recognize the most effective and innovative uses of green infrastructure through awards and recognition programs to meet the Clean Water Act goals, while making models of green infrastructure techniques available nationwide.


Federal Court Blocks Attempt to Eliminate Wildlife Standards for National Forests
A federal judge rejected the Forest Service's effort to remove key environmental protections from the rules governing the 191-million-acre National Forest System.

The ruling, by U.S. District Judge Phyllis Hamilton, invalidates regulations issued in 2005 that sought to overhaul the land-management planning process for National Forests by eliminating mandatory protections for wildlife and clean water and removing public participation in the process. Among the measures discarded was a key regulatory guarantee of wildlife viability in the National Forests that had been in place since the Reagan administration.

The ruling found that administration officials had bypassed legally required environmental reviews and endangered species protections in creating a new management system for the National Forests that eliminated enforceable environmental protections from the forest planning process. Judge Hamilton also ruled that the administration had sprung its final forest planning rules on the public without sufficient notice of the "paradigm shift" that the rules accomplished.

The judge's ruling prohibits the government from "implementation and utilization" of the new forest planning rules.

The National Forest Management Act requires the Forest Service to protect wildlife on the national forests and allow citizens to participate in management decisions. The court-rejected rules would have invalidated the 1982 standards for national forest management that protected species and required public comment on national forest timber plans.

Earthjustice, representing Defenders of Wildlife, The Wilderness Society, the Sierra Club and Vermont Natural Resources Council, filed a legal challenge to the rule changes in October 2004.

Pete Frost from the Western Environmental Law Center represented Citizens for Better Forestry in a similar case that also was decided in the ruling. The State of California also filed a lawsuit against the rule changes.


Water Infrastructure Funds Surged in 2006

The Environmental Protection Agency invested more than $900 million in 2006 to help states and municipalities update their wastewater infrastructure. Combined with state contributions, total financial assistance for wastewater projects topped $5 billion for the first time, according to the just-released Clean Water State Revolving Fund (CWSRF) 2006 Annual Report. Since the CWSRF program began 20 years ago, more than 18,000 loans totaling more than $57 billion have been provided to help rebuild and refurbish the nation's wastewater infrastructure.

“The State Clean Water Funds are revolving and evolving to reach new levels of success and sustainability. EPA's national report underscores the importance of innovation and partnership to increase environmental results in watersheds and communities across America” said Benjamin H. Grumbles, EPA assistant administrator for water.

The report points to greater emphasis placed on community outreach programs last year. The programs stimulate participation and encourage new approaches to providing information about the CWSRF. Although participation is voluntary, all 50 states and Puerto Rico are now tracking the link between project assistance and environmental benefits. The low-interest loans help communities restore and protect aquatic life, recreational uses and drinking water sources.

The CWSRF is the largest federal funding program for wastewater infrastructure projects, such as treatment plants and collection systems. It is an outgrowth of 1987 amendments to the Clean Water Act. The fund is self-sustaining in that the interest derived from loans as they are repaid helps expand the program to provide even broader funding in future years.

More Information on the program can be found at www.epa.gov/owm/cwfinance/cwsrf/annreport2006.htm.


EPA Calls For Numeric Water Quality Standards for Nutrients

According to the Bureau of National Affairs, Inc. (BNA), a memo signed
May 25 by the Environmental Protection Agency's top water official is
urging states to adopt numeric water quality standards for nitrogen and
phosphorus discharges. The purpose of the memo is to encourage states
to develop numeric water quality standards for pollution from phosphorus
and nitrogen (collectively known as nutrients) instead of "narrative"
standards, wrote Benjamin Grumbles, EPA assistant administrator for
water.

According to EPA, adoption of numeric water quality standards for
nutrients would affect any stakeholder that has to obtain a National
Pollutant Discharge Elimination System permit. Specifically, the numeric
standards for nutrients would affect the fertilizer and agriculture
industries, including livestock operations, and golf courses. It also
would affect municipalities because many homeowners use fertilizers on
their yards, the agency said.

The memo reiterates EPA's position that "action is needed" to address
the growing problem of nutrient pollution. Grumbles cites the Chesapeake
Bay and the Gulf of Mexico as the "two most widely known examples" of
bodies of water suffering from an excess of nutrient pollution.

In the memo, EPA said states, tribes, and territories should develop
nutrient standards that address the sources of nitrogen and phosphorus
as well as chlorophyll levels and water transparency. Chlorophyll is
used as a measure of blooms of algae in water; transparency is a way to
measure how much light has been blocked by the blooms of algae and other
plants that thrive on nitrogen and phosphorus.

For more information, visit
http://ehscenter.bna.com/pic2/ehs.nsf/id/BNAP-73NEXZ?OpenDocument

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In the Air

News of Air Pollution Control
and Air Related Issues
with Larry Simmons

You can contact Larry at SimmonsLL @ e2minc.com

___________________________________


Clean Air Act Summary

The Congressional Research Service published a report describing the Clean Air Act's major provisions and provides tables listing all major amendments. This 25 page document gives a summary of the key provision of the Act that agencies have enforced to improve our air quality. The report can be found at:
http://fpc.state.gov/documents/organization/47810.pdf.

Wind Power Impacts

While wind power won’t make much of a dent in U.S. carbon dioxide emissions, the National Academy of Science’s National Research Council indicated it could cause environmental damage that is not well understood. The report – Environmental Impacts of Wind-Energy Projects – notes that wind energy provided about 1% of U.S. electricity in 2006 and could reduce CO2 emissions by about 4.5% in 2020.

Bird deaths from wind turbines, the report found, amounted to less than 0.003% of all bird deaths annually in 2003. As one of the report critics noted, more than a thousand times as many birds are killed flying into buildings than wind turbines.

Because of the intermittency of wind energy, the upper limit of wind power in the U.S. national grid is probably about 20%. European countries that have pushed heavily for wind – notably Denmark and Germany – have found that the maximum penetration of wind power is about 17%, given the need for backup fossil generation to support the unpredictability of wind power.

Unfortunately, wind power has bumped into the NIMBY syndrome. Impacts to local aesthetic values, low frequency harmonics and impacts to birds have been issues raised that have delayed projects.


Air Pollution Down, Air Quality Up

A look at air quality and emissions data for 2006 shows continued improvement in the nation's air quality over the long term, according to an EPA report. Emissions of six key pollutants have dropped by more than half since 1970 and the national average concentration for each criteria pollutant is below the level of its air quality standard.




As shown by this graphic from the EPA report, air quality improvements have occurred even with a significant increase in population, energy consumption, and vehicle miles traveled. These data can be found at:
http://www.epa.gov/airtrends/econ-emissions.html.

New EPA Tool Helps Answer Air Quality Questions

AirCompare, a new EPA-developed air quality tool, provides local air quality information. AirCompare uses EPA's popular Air Quality Index (AQI) to explain air quality from a health perspective. A person with asthma, for example,
can use AirCompare to select up to 10 counties across the country – and with the click of a button, find out how many days the air was unhealthy for asthmatics last year.

AirCompare searches EPA air quality databases to pull information about pollutants reported under the AQI - and to translate it into charts that show simply whether the previous year's air quality was healthy, unhealthy, or unhealthy for specific groups more susceptible to pollution. The tool also can provide a multi-year snapshot of a county's air quality, based on a particular health issue.

Go to http://www.epa.gov/aircompare/ to use this tool. It only works for those counties with air quality monitoring stations.

Tougher Refinery Standards Proposed

The EPA is proposing to reduce emissions from new, modified or reconstructed process units at petroleum refineries. The proposed amendments would update the existing standards of performance for petroleum refineries. Under the proposal, new, modified or reconstructed units would be required to add emission controls that reflect demonstrated improvements in emission control technologies, in addition to changing certain work practices.
Over the next five years, the proposed standards are estimated to reduce the combined emissions of particulate matter, SO2, and NOx emissions by nearly 56,000 tons per year. The estimated benefits of the proposed rules would be more than $950 million, 17 times the expected costs.

Coal Still King

Despite the political enthusiasm for alternative fuels such as wind, solar, and hydrogen, coal will continue to be the dominant fuel for electric power generation into the future, according a recent Department of Energy study.

The report—Tracking New Coal-Fired Power Plants, Coal’s Resurgence in Power Generation—finds that coal’s abundance and ability to be delivered cheaply, trump all of the fuel’s environmental disadvantages. According to the report, coal will overtake natural gas as a new generating fuel after 2010.

According to the report, some 151 proposed and online coal-fired plants are already in the pipeline, representing some 90 GW of generating capacity and $145 billion in investment. The DOE predicts that 145 GW of new coal capacity will be added to the U.S. generating mix by 2030. That will be 59% of all new capacity additions.

The bulk of new coal supply (25GW) will come from subbituminous coal (Powder River Basin) according to the DOE report, while eastern bituminous coal will account for most of the rest (13 GW). Lignite, waste coal, and coal and petroleum coke will be niche fuels. Anthracite will be insignificant.


EPA Publishes Greenhouse Gas Inventory

EPA has released the national greenhouse gas inventory, which finds that overall emissions during 2005 increased by less than one percent from the previous year. Total emissions of the six main greenhouse gases in 2005 were equivalent to 7,260 million metric tons of carbon dioxide. The report indicates that overall emissions have grown by 16 percent from 1990 to 2005, while the U.S. economy has grown by 55 percent over the same period.

Radical Engine Redesign

Researchers have created a computational model to track engine performance from one combustion cycle to the next for a new type of engine that could dramatically reduce oil consumption and the emission of global-warming pollutants. A key portion of the research hinges on designing engines so that their intake and exhaust valves are no longer driven by mechanisms connected to the crank shaft.

In today's internal combustion engines, the pistons turn a crankshaft, which is linked to a camshaft that opens and closes the valves, directing the flow of air and exhaust into and out of the cylinders. The new method would eliminate the mechanism linking the crankshaft to the camshaft, providing an independent control system for the valves. Because the valves' timing would no longer be restricted by the pistons' movement, they could be more finely tuned to allow more efficient combustion of diesel, gasoline, and alternative fuels, such as ethanol and biodiesel.

The concept, known as variable valve actuation, would enable significant improvements in conventional gasoline and diesel engines used in cars and trucks and for applications such as generators, he said. The technique also enables the introduction of an advanced method called homogeneous charge compression ignition, or HCCI, which would make it possible to improve the efficiency of gasoline engines by 15 to 20 percent and reduce exhaust emissions.

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International
Focus

News of Environmental Trends and Regulations
in Other Countries

with Kim Walker

You can contact me at Kimberly.walker @ erm.com

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European Liability Directive Ensures Polluters Pay


European Union legislation laying down liability rules for damage to the environment was set to become effective on April 30. The groundbreaking new directive (http://europa.eu.int/comm/environment/liability) is the result of discussions which started in the late 1980s and is the first EU law specifically based on the "polluter pays principle" set out in the EC treaty. It will ensure that future environmental damage in the EU is prevented or remedied, and that those who cause it are held responsible. EU Environment Commissioner Stavros Dimas said: "The idea that the polluter must pay is a cornerstone of EU policy and with this legislation we are putting it into practice. The environmental liability directive will provide a strong incentive to prevent damage from happening at all, and enables governments to seek redress from the culprit when serious damage does occur."

The directive establishes a framework based on environmental liability to ensure that environmental damage is prevented or remedied. Environmental damage includes damage to species and natural habitats protected at EU level under the 1979 directive on the conservation of wild birds and the 1992 directive on the conservation of natural habitats, damage to waters covered by the 2000 Water Framework Directive, as well as land contamination which causes significant risk of harming human health. There will be no retrospective effect.

The parties potentially liable for the costs of preventing or remedying the environmental damage are the operators of the risky or potentially risky activities listed in the environmental liability directive. These include activities that release heavy metals into water or into the air, installations producing dangerous chemicals, landfill sites, and incineration plants. Other economic operators may also be liable for the costs of preventing or remedying damage to protected species and natural habitats, but only if they are found to be at fault or negligent.

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Solid Waste Views

with John Scrabis, P.E.

You can contact me at: jmscrabis @ mactec.com

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Pennsylvania’s Brownfield Action Team is Ready to Help

The Brownfield Action Team (BAT) is designed to streamline the revitalization of Pennsylvania’s Brownfields sites. BAT enhances the interaction between the Department of Environmental Protection (DEP) and local communities by designating a single point of contact within DEP for locally designated priority brownfield or abandoned mine land redevelopment projects. The Brownfield Action Team represents an evolution of the Pennsylvania Land Recycling Program and provides an enhanced management process for community revitalization. BAT can…

· Expedite permits needed for remediating pollution and redeveloping brownfield sites to allow these sites to be used safely for new businesses;

· Coordinate funding with the Department of Community and Economic Development, the Governor’s Action Team, the Community Action Team, and other state agencies; and

· Help remediate properties receive liability protection under the
Land Recycling Program.

For more information on the Brownfield Action Team and how they can help with your brownfield project, go to the PADEP website at the following address: http://www.depweb.state.pa.us/landrecwaste/cwp/view.asp?a=1243&q=462059


EPA Extends Comment Period on Proposed Changes to Definition of Solid Waste

EPA recently extended the comment period to proposed changes to the Definition of Solid Waste until June 25, 2007. The proposal is intended to modify the existing definition of solid waste to exclude certain hazardous secondary materials from being regulated as solid (and therefore hazardous) wastes when the materials are recycled.

The proposal modifies the current hazardous waste regulations in an attempt to increase the recycling of hazardous secondary materials. Currently, some recycling is discouraged because of the high costs associated with meeting Resource Conservation and Recovery Act Subtitle C (hazardous waste) facility requirements, including the high cost of facility permits. The proposal excludes those hazardous secondary materials that are generated and reclaimed under the control of the generator from the definition of solid waste. It also excludes other hazardous secondary materials that are transferred by a generator to a reclamation facility, provided certain conditions are met. The proposed rule also provides a petition process for non-waste determinations of other hazardous secondary materials.

This regulation would modify and build upon EPA’s 2003 proposal that would have limited the exclusion to materials generated and reclaimed in a continuous process within the same industry. The same industry would have been defined by a four-digit North American Industrial Classification System (NAICS) code. The same industry limitation produced many adverse comments to the proposal and was eliminated.

Under the current proposed rule recycling would not have to occur within the same industry to qualify for the exclusion. The basis of the current proposal is that secondary materials are not discarded if they are recycled and therefore should not be regulated as solid wastes. Hazardous secondary materials burned for energy recovery, used in a manner constituting disposal or that are inherently waste-like under the current regulations are not eligible for the exclusion. The proposal requires that the generator of the hazardous secondary material provide a notification to the authorized regulatory agency that the facility intends to recycle hazardous secondary material. Similarly, if the material is shipped offsite for recycling to a different facility owned by the same company, a notification is required from the receiving facility.

The rule would also allow recycling of hazardous secondary materials via a tolling agreement mechanism. In this instance a generator and recycling facility must have a contract in place whereby the recycler assumes responsibility for the material. The management and recycling of the material is done under the control of the tolling company (recycler). Generators would have to maintain records for three years; if managed within land-based units (e.g. waste piles) the material would have to be contained in the units; and generators would have to make reasonable efforts to ensure the materials will be legitimately recycled. Generators would also have to submit a one-time notification to the state; comply with speculative accumulation restrictions; and ensure that the material is not handled by anyone other than the generator, transporter, or the designated reclamation facility. Reclamation facilities would also have to notify the regulatory agency; maintain shipping records for three years; manage the material as the analogous raw material; manage recycling residuals to protect human health and the environment; and comply with financial assurance requirements that apply to similarly permitted facilities.

Also available to a generator would be a case-specific non-waste determination process that allows a generator to petition the regulatory agency that the hazardous secondary material is not a solid waste. The petition would be based on the material being recycled in a continuous industrial process; or would be indistinguishable from a product or intermediate; or would be recycled via certain contractual arrangements. The facility would submit a petition to the regulatory agency. The agency would then evaluate the application and provide notification to the public in a newspaper or on the radio, and receive comments on the petition, and then make a determination granting or denying the petition.

The proposal also intends to codify two of the four legitimacy criteria that are presently used to determine what constitutes legitimate recycling. The hazardous secondary material being recycled must provide a useful contribution to the recycling process or to the product of the recycling process, and the recycling process must produce a valuable product. The other two criteria, management of materials prior to recycling, and toxics along for the ride (TARS) in recycled products would have to be considered on a case-by-case basis. TARS refer to potentially increased levels of toxic materials found in the recycled product when compared to a similar product produced without recycled hazardous secondary materials.

If finalized, EPA estimates the proposal will deregulate 650 million tons of hazardous waste annually, and provide a cost savings to industry of approximately $107 million per year. EPA has requested that the regulated community and regulatory agencies submit comments on many areas of the proposed rule. The public comment period originally published as closing on May 25 was extended to June 25in the April 24, 2007 Federal Register Notice.

For more information, contact Ed Karmilovich by e-mail at ekarmilovi@state.pa.us or by telephone at 717-787-6239.


EPA Study Looks for Better Asbestos Removal Technology

The EPA announced last week the release of a draft report (http://www.epa.gov/region06/6xa/asbestos.htm) that evaluates an alternative demolition process for buildings containing asbestos. Scientists and engineers from EPA's National Risk Management Research Laboratory and the Dallas regional office compared the current process of demolishing a dilapidated, asbestos-containing structure with a new
method called the Alternative Asbestos Control Method or AACM. The first demonstration project was successfully completed in Fort Chaffee, Arkansas. Preliminary findings show the AACM procedures to be protective for clean-up of many asbestos-containing buildings.

Two similar buildings at Fort Chaffee, Arkansas, containing similar types and quantities of asbestos, were demolished in April 2006. One demolition utilized the alternative method and one utilized the standard National Emissions Standards for Hazardous Air Pollutants (NESHAP) method. As they were demolished, environmental emissions were monitored to determine if the alternative protected the environment as well as the
NESHAP method.

The current NESHAP process involves removal of some asbestos materials prior to demolition of the structure. This process can be time-consuming and expensive. After demolition, the removed asbestos and the demolished structure are both disposed in approved landfills. Similarly, the alternative method removes some friable (capable of becoming airborne) asbestos materials, but some asbestos-containing materials are allowed to remain. The structure is then wetted with amended water to control asbestos fiber release prior to and during demolition. Demolition debris and several inches of affected soil from the AACM process are disposed as asbestos-containing debris at an approved landfill. Data from the evaluation demonstrated lower than expected levels of asbestos and reduced potential for worker exposure. The cost and time-savings for the
first study were significant.

The draft report has been released for public comment and for peer review by a select panel of experts. The public is invited to review the draft report and submit comments by June 11, 2007.

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ENVIROCABULARY

Environmental Acronyms, Obscure Words
and Other Lingo
with Kim Walker

You can contact me at Kimberly.walker @ erm.com

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Each month, the Envirocabulary staff will scour the latest environmental literature for new and breaking terms of interest to our readers. This month's term is…


Pneumoconiosis

Health conditions characterized by permanent deposition of substantial amounts of particulate matter in the lungs and by the tissue reaction to its presence; can range from relatively harmless forms of sclerosis to the destructive fibrotic effect of silicosis.

Types of pneumoconiosis include asbestosis, silicosis, siderosis of the lung, and coal worker’s pneumoconiosis.

Sources: Office of Communications, Education, and Media Relations: Terms of Environment: Glossary, Abbreviations, and Acronyms (Revised December 1997) (Glossary) and Aetna’s InteliHealth - http://www.intelihealth.com/IH/ihtIH/WSIHW000/9339/25657.html

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P2 Forum

News on Pollution Prevention,
Recycling and Related Issues
with Michael Stepaniak

You can contact me at michaels @ ccicenter.org

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This Month:

EPA Report on Environmental Impacts of Energy Use in Leading Manufacturing Sectors Now Available

Poor Tire Maintenance Increases Gas Consumption, Reduces Tire Life, and Puts Consumers at Risk

Pollution Prevention Search Tool

EPA REPORT ON ENVIRONMENTAL IMPACTS OF ENERGY USE IN LEADING MANUFACTURING SECTORS NOW AVAILABLE - The EPA has recently released a report http://www.epa.gov/sectors/energy/index.html on energy use trends in major manufacturing sectors that targets the environmental implications of energy use. These sectors account for about 85% of all U.S. industrial energy use. The analysis includes a general overview of the barriers to energy efficiency and use of clean fuel technologies, and offers some possible policy options for government to help address these obstacles. The report examines each sector's current energy consumption trends and the associated environmental impacts, expressly emissions of air pollutants and carbon dioxide. According to the EPA, if current business practices remain the norm, energy consumption across many of these sectors will increase by 20% from 2004 levels by 2020, and carbon dioxide emissions will increase by 14%. The twelve sectors analyzed are aluminum, cement, chemical manufacturing, food manufacturing, forest products, iron and steel, metal casting, metal finishing, motor vehicle manufacturing, motor vehicle parts manufacturing, petroleum refining, and shipbuilding. The report outlines how each sector could improve environmental performance by becoming more energy efficient or by using clean fuel technologies. It also identifies five strategies http://www.epa.gov/sectors that could be implemented to achieve these goals. They include: 1) Switching to cleaner fuels. 2) Using combined heat and power. 3) Retrofitting or replacing older equipment. 4) Making process improvements. 5) Investing in research and development. Based on the insights garnered from this report, EPA will now work with industry partners to explore the best ways to boost energy and environmental outcomes in each sector.

POOR TIRE MAINTENANCE INCREASES GAS CONSUMPTION, REDUCES TIRE LIFE, AND PUTS CONSUMERS AT RISK – In the next few months many of us will be driving to vacation destinations or taking road trips to favorite spots. The only things separating you and yours from the road are your tires. In a recent survey conducted by Rubber Manufacturers Association (RMA), only 55% of drivers said they checked their tire pressure within the past month compared to 70% last year when fuel prices peaked. Maximizing tire performance depends on regular maintenance. This upkeep can dramatically affect gas mileage, tire life, and passenger safety. According to the National Highway Traffic Safety Administration (NHTSA), low tire pressure-related crashes are to blame for 660 fatalities and 33,000 injuries each year. NHTSA estimates that about one in four cars and one in three light trucks has at least one significantly under inflated tire. These alarming statistics demonstrate the real need to educate drivers about tire maintenance in order to increase vehicle safety and tire performance, extend the life of the tires, and save money on gas. RMA urges motorists to follow several maintenance tips, including: 1) Measuring tire pressure monthly, using a good quality tire gauge. A visual inspection is not sufficient to detect under or over-inflated tire problems. 2) Having tires aligned regularly and checking owner's manual for specific recommendations. A pulling or vibration sensation means that alignment should be checked sooner. 3) Rotating tires regularly, usually every 5,000-8,000 miles. 4) Monitoring tread wear and replacing tires when tire tread is worn down to 1/16 of an inch. Proper tire tread prevents skidding and hydroplaning. 5) Balancing tires periodically or when feeling a vibration. 6) Conducting a visual check for embedded stones, glass, and other foreign objects that could work their way into the tire and cause a leak. RMA tire care brochures are available at most tire retail locations. Many of these same locations also provide free tire pressure services. For more information on RMA’s tire program visit http://www.rma.org/tire%5Fsafety/tire%5Fmaintenance%5Fand%5Fsafety/.
POLLUTION PREVENTION SEARCH TOOL - The Great Lakes Regional Pollution Prevention Roundtable (GLRPPR), located in Illinois, has produced a "P2 Search" http://www.glrppr.org/search/ tool that allows individuals to search 37 web sites simultaneously for pollution prevention (P2) and related information. These sites include the U.S. EPA http://www.epa.gov web site, each of the Pollution Prevention Resource Exchange (P2Rx) http://www.p2rx.org Center web sites, all of the National Compliance Assistance Centers http://www.assistancecenters.net/, the Department of Energy’s Energy Efficiency and Renewable Energy http://www.eere.energy.gov/ web site, and the Office of Science and Technical Information http://www.osti.gov/ site, P2 Gems http://www.p2gems.org/, the Canadian Centre for P2 (C2P2) http://www.c2p2online.com/, Environment Canada's Canadian Pollution Prevention Information Clearinghouse (CPPIC) http://www.ec.gc.ca/cppic/en/index.cfm, the United Nations Environment Programme (UNEP) http://www.unep.org/, and Australia's environmental portal http://www.environment.gov.au/. When individuals type in a search phrase, the results page will feature links at the top allowing you to refine your search by limiting the search to the compliance assistance centers, energy efficiency-related sites, international sites, the P2Rx centers, or to U.S. government sites.


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Compliance Corner

What's New with Regulatory Compliance,
Environmental Management
and Related Issues
with Dan Hagerty, CHMM

You can contact me at daniel_hagerty @ hotmail.com


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New TRI Reporting Requirements

EPA's Toxics Release Inventory Program recently issued a final rule expanding reporting requirements for the dioxin and dioxin-like compounds category. There are seventeen distinct members of this chemical category listed under TRI. The final rule requires that, in addition to the total grams released for the entire category, facilities must report the quantity for each individual member on a new Form R Schedule 1. EPA will then use the individual mass quantity data to
calculate TEQ values that will be made available to the public along with the mass data. The final rule also removes the requirement to report the single distribution of compounds in the category.

EPA currently requires that facilities report, in grams, the total amount of dioxin and dioxin-like compounds released from the facility. When available, the facility must also provide a single "distribution," showing how that total is divided among the individual dioxin and dioxin-like compounds. This single distribution must represent either total releases, or releases to the media (air, land, water) for which the facility has the best information.

Although useful, total releases are not the best measure of the actual toxicity of these compounds because each compound has its own level of toxicity. To account for how compounds vary in toxicity, weighted values called toxic equivalents (TEQs) are used. To calculate TEQs, a value is
assigned describing how toxic each dioxin and dioxin-like compound is compared to the most toxic members of the category: 2,3,7,8-tetrachlorodibenzo-p-dioxin and 1,2,3,7,8-pentachlorodibenzo-p-dioxin.

Expressing data for dioxin and dioxin-like compounds as TEQs allows the public to understand the toxicity of releases and waste management at facilities that report under the TRI program. For example, a facility releasing 3 grams of some combination of dioxin and dioxin-like compounds may or may not be of greater interest than a facility releasing 1 gram of a different combination. However, a facility releasing 3 grams TEQ of dioxins is of greater environmental importance
than one releasing 1 gram TEQ to the same environmental medium (e.g., air, land, water).

TEQs will allow the public to make more informed environmental decisions within their communities. Expressing dioxin releases and waste management information in grams TEQ will also permit easier comparisons between TRI data and other EPA and international data.
TRI Dioxin and Dioxin-like Compounds Toxic Equivalency Final Rule --
Federal Register Notice
http://www.epa.gov/tri/tridata/teq/TRI%20TEQ%20Final%20Rule.pdf

FDA Clears First Respirators for Use in Public Health Medical
Emergencies

The U.S. Food and Drug Administration (FDA) cleared for marketing the first respirators that can help reduce the user's exposure to airborne germs during a public health medical emergency, such as an influenza pandemic.

These two filtering facepiece respirators, manufactured by St. Paul, Minn.-based 3M Company (and called the 3M Respirator 8612F and 8670F), will be available to the general public without a prescription.

The devices are also certified as N95 filtering facepiece respirators by the National Institute for Occupational Safety and Health (NIOSH). NIOSH certifies respirators for use in occupational settings in accordance with an appropriate respiratory protection program.

An N95 filtering facepiece respirator is a type of face mask that fits tightly over the nose and mouth. It is made of fibrous material that is designed to filter out at least 95 percent of very small airborne particles. The filter and a proper fit determine the effectiveness of
the product.

Many companies make N95 respirators for workplaces, including health care settings. However, the 3M respirators are the first devices to receive FDA clearance for use by the public during public health medical emergencies to reduce exposure to airborne germs.

Under Occupational Safety and Health Administration and other occupational health regulations, respirators used in the workplace must be individually selected for each worker and tested to ensure a proper fit. This kind of fit testing is not generally employed outside the workplace now and would probably not be feasible during a public health medical emergency.

FDA is requiring those who want to market respirators for use during public health medical emergencies to assure that they are certified by NIOSH to provide adequate filtration without hampering people's ability to breathe. In addition, companies must conduct fit assessment testing, conduct biocompatibility testing to reduce the chance for allergic skin reaction, and provide instructions that will enable wearers to achieve a protective fit and use the devices properly.

3M evaluated fit characteristics in healthy adults to determine that a user could achieve a protective fit following the instructions on the label. They measured how many airborne test particles were able to get inside the respirator through small leaks between the edges of the
respirator and the wearer's face. While individual results varied, all participants tested achieved some reduction in exposure to airborne test particles.

FDA will soon issue a guidance document outlining its regulatory approach to this new type of device.

Inhaling particles is just one route of exposure to disease-causing organisms. Others include touching contaminated surfaces and coming into close contact with those who have infectious diseases. A total approach to personal protection includes hand hygiene, cough etiquette and other protection practices such as avoiding crowded settings.


What Does "Weekly" Mean?
Environmental regulations require you to inspect, report, monitor, or keep records according to specified frequencies, such as daily, weekly, and annually. Does weekly mean once per week or every seven days. In many cases, the regulations don't specify the difference. The Ohio EPA recently distributed guidance, which must be followed in Ohio, but would be worth considering in any state:

* "Week" means seven consecutive days.
* "Year" means twelve consecutive months.
* "Daily" means an event that must occur every day, that is, once within a calendar day period following the previous calendar day period.
* "Weekly" means an event that must occur once within a seven day period following the previous event. As an example, if you inspect the area where your hazardous waste containers are accumulated on Tuesday April 6, 2007 you must inspect the area again on or before the close of business on Tuesday April 13, 2007.
* "Annual" or "annually" means an event that must occur in the same calendar month that it occurred in the previous year.
* "Quarterly" means an event that occurs once every three months evenly spaced within a 12 consecutive month period (for groundwater monitoring the events should capture seasonal variations).
* "Semi-annually" means an event that occurs once every six months evenly spaced within a 12 consecutive month period (for groundwater monitoring the events should capture seasonal variations).
For purposes of determining your generator status, you are required to count all hazardous waste generated during a specific calendar month. For example, the waste generated from the first day of the month until the last day of the month. (i.e. January 1 through January 31 or February 1 through February 28 or 29 if leap year).

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