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Toxic Release Inventory (TRI) Reminder!! July 1st Deadline
At the end of March 2013, Chapter 6 of the New York Code of Rules and Regulations (NYCRR) Subpart 225-1, which imposes limits on the sulfur content of distillate oil, residual oil, and coal fired in stationary sources, was amended and adopted. Starting in July 2013, owners and/or operators of commercial, industrial, or residential emission sources that fired No. 2 heating oil had to switch to No. 2 heating oil with 0.0015 percent sulfur by weight or less (ultra low sulfur).
Per 6 NYCRR 225-1.2 (g) Owners and/or operators of a stationary combustion installation that fires distillate oil other than No. 2 heating oil are limited to the purchase of distillate oil with 0.0015 percent sulfur by weight or less on or after July 1, 2014. Most emergency generators will fall into this category and will be required to burn ultra low sulfur distillate oil by July 2014. Note that distillate oil is defined by the NYSDEC as a fuel oil consisting of distilled fractions and having a kinematic viscosity of 5.8 centistokes or less at 100 degrees Fahrenheit. This includes ASTM grade Nos. 1 and No. 2 fuel oil, ASTM grade Nos. 1-D and 2-D diesel fuel oil and proposed ASTM grade Nos. 1-GT and 2-GT gas turbine fuel oil. This definition means that No. 1 and No. 2 (diesel and heating oil) meet the definition of distillate oil. Most facilities use diesel/heating oil 1 or 2. Some continue use No. 4 heating oil; however, No. 4 is usually a blend with residual fuel oil stocks and distillate oil and considered a residual oil. In NYC, No. 4 fuel oil is being phased out. See subpart NYSDEC 225-1.2(d) and (e) for residual oil requirements.
Per 6 NYCRR-225-1.2 (g) (h) Owners and/or operators of any stationary combustion installation that fires distillate oil including No. 2 heating oil are limited to the firing of distillate oil with 0.0015 percent sulfur by weight or less on or after July 1, 2016. Many hospital boilers operating on No. 2 will have to transition to ultra low sulfur heating oil by July 1, 2016.
The New York State Department of Environmental Conservation (NYSDEC) has changed its UST operator training program. They originally allowed training to be completed using a variety of resources, including a company's internal program.
NYSDEC is instituting a new approach -- they're making all training materials available on the NYSDEC website. NYSDEC is developing the exam for Class A and Class B operators and is anticipating that this will also be available on-line.
At this point it appears that the NYSDEC will be offering the training materials and the NYSDEC exam for free.
E-Manifests in the Works
The 2012 Hazardous Waste Electronic Manifest Establish Act spearheaded the movement toward electronic hazardous waste manifests. On February 7, 2014 the EPA released the final rule allowing electronic manifests for hazardous waste transportation, as an alternative to the paper forms that have been required for tracking shipments.
As stated by the EPA, this rule affects approximately 160,000 entities in at least 45 industries that are involved in shipping off-site, transporting, and receiving approximately 5.9 million tons of RCRA hazardous wastes annually (non-wastewaters and wastewaters). These entities currently use between 4.6 and 5.6 million EPA Uniform Hazardous Waste Manifests (EPA Form 8700-22 and continuation sheets EPA Form 8700-22A) to track hazardous waste shipments from the site of generation to sites of treatment, storage, or disposal.
The next milestone for the EPA is to develop an e-Manifest Information Technology (IT) system, to be up and running by October 5, 2015. At this time, the technical capabilities of the e-Manifest are not fully defined; however, the EPA does have some vision which may be viewed in the Q&A at the EPA website.
Biofuels and Ethanol
Many facilities are switching to biofuels and ethanol, which has spurred an increase in the number of facilities storing such fuels. Both ethanol and biodiesel have unique characteristics different than petroleum; therefore, special precaution should be taken when deciding on the storage of these fuels.
The majority of ethanol-blended fuel sold is E10, a mixture of approximately 10 percent ethanol and 90 percent gasoline by volume. E85 fuel is a mixture of approximately 85 percent ethanol and 15 percent gasoline by volume. Biodiesel can be used in its pure form (B100), or as a fuel additive. B20 is of approximately 20 percent biodiesel and 80 percent petroleum diesel by volume.
The guidance discusses how owners and operators of USTs regulated under 40 CFR part 280 can demonstrate compliance with EPA’s compatibility requirement (40 CFR 280.32) when storing gasoline containing greater than 10 percent ethanol or diesel containing greater than 20 percent biodiesel.
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