Recently, the EPA denied New York State’s , regarding air emission source impacts from upwind states. This denial follows  denials for Northeastern states, including Connecticut, Delaware and Maryland.

In addition, the EPA reported the  of 14 National Priorities List (NPL) sites so far in 2019, indicating that resources will continue to be applied to maintain this increased pace.

We have highlighted some additional topics of interest this month from Brown and Caldwell’s BLR source regarding drinking water, air, and toxic substances:

Proposed Lead Service Line replacement requirements

The EPA’s  to the federal Lead and Copper Rule (LCR) would require that public water systems (PWSs) conduct full lead service lines replacements (LSLRs) when lead in the service line exceeds the lead action level (AL). The PWS would be obligated to replace LSLs exceeding the AL at the rate of 3% a year.

The proposal also contemplates goal-based LSL replacements that occur mainly when homeowners act independently to replace their portion of the LSL. Overall, the EPA estimates that the proposed provisions will result in about 214,000 to 350,000 LSLRs during the next 35 years.

OLD subject to new proposed CAA amendments

Under an EPA , the Organic Liquids Distribution (OLD) source category would be subject to new Clean Air Act (CAA) amendments pertaining to storage tanks, transfer operations, equipment leaks and flares. Other amendments would eliminate an exemption from the National Emission Standards for Hazardous Air Pollutants (NESHAP) during periods of startup, shutdown and malfunction, and would impose a new electronic reporting requirement.

In lieu of the proposed amendments, the agency is also proposing that owners and operators of OLD operations may implement a fenceline monitoring program. Compliance with the amendments would be required no more than 3 years after the effective date of a final rule.

EPA looking for methylene chloride risk evaluation feedback

The EPA recently released a , as part of the 2016 amendments to the Toxic Substances Control Act (TSCA), indicating unreasonable risk associated with a majority of the 70 uses of methylene chloride.

The draft risk evaluation will be peer reviewed by independent scientific experts as well as open to at least one round of public comment. The agency says it will use feedback received from the peer review and public comment period to inform the final risk evaluation and will provide updates on this process.

The EPA will accept comments on the methylene chloride draft risk evaluation until Dec. 30.

About the experts

Meghan Krishnayya, Indianapolis, is the Compliance & Permitting Service Line Director for Brown and Caldwell, with expertise in environmental regulatory program strategy development and implementation.

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