Carbon Emissions from Agriculture – Data Gathering to Begin Soon

What is your carbon footprint?  How can you best sequester carbon?  The answer to these questions may soon be available.

Consistent with Section 2709 of the Food, Conservation, and Energy Act of 2008, the USDA has published a notice in the Friday, February 18, 2011, Federal Register seeking public comment on a new effort to provide methods that will help farmers, ranchers, and forest land owners to assess their greenhouse gas (GHG) footprint.

According to the notice in the Federal Register, “…the methods will be used by farmers and by USDA to improve management practices and to identify actions to reduce greenhouse gas emissions and increase carbon sequestration.”

The guidelines that will be developed are not intended to replace any other Federal GHG reporting systems or requirements.  So what will the use of the end product (methods to measure GHG emission) be? According to the notice, “…aiding (1) USDA in assessing GHG and carbon sequestration increases and decreases resulting from current and future conservation programs and practices; (2) USDA and others in evaluating and improving national and regional GHG inventory efforts; and (3) landowners, NGOs, and other groups assessing increases and decreases in GHG emissions and carbon sequestration associated with changes in land management.”

USDA estimates that this project will take approximately three years to complete.

This announcement is yet another indication that agriculture is facing many of the same overall “environmental management pressures” once thought only to apply to the world of manufacturing. 

Here is a link to the announcement in the Federal Register http://www.gpo.gov/fdsys/pkg/FR-2011-02-18/html/2011-3731.htm.

Milk – still not exempt under SPCC

The long sought after clarification/exemption of milk as a regulated oil under the Spill Prevention Control and Countermeasure (SPCC) Plan rules is remaining elusive.  If the exemption is not granted, the number of dairy farms that will require an SPCC will likely grow exponentially. 

According to a recent article in The Watertown Daily Times, “The U.S. Environmental Protection Agency has not completely backed away from a proposal that could treat milk spilled on farms as if it were oil — although officials say they are working on a way to avoid such a rule” http://www.watertowndailytimes.com/article/20110212/NEWS02/302129960.

The current deadline to develop and implement an SPCC (for those facilities in operation after August 16, 2002) is November 2011.  See our previous blog entries regarding SPCCs, including our October 15, 2010 entry.

Reporting Changes to EPCRA – Common Sense

It’s not often that you can use “environmental regulation” and “common sense” in the same breath. But the recent action by the Environmental Protection Agency (EPA) really is common sense and should provide reporting relief, especially for those who handle large volumes of steel.

The intent of the Emergency Planning and Community Right to Know Act (EPCRA) is to provide information to emergency responders regarding the storage and use of chemicals at facilities. Obviously, this information allows responders to make better decisions in the event of an emergency.  However as with any regulation, interpretations can lead to some questionable results.

Under section 311(e)(2) of EPCRA it states, ‘‘any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use’’ it is exempt from the definition of hazardous chemical and therefore need not be reported under sections 311 and 312.  This makes sense; a 10,000 pound roll of steel does not pose a health hazard to an emergency responder.

But EPA’s interpretation of this basically said that if any part of the solid was altered and led to an exposure (for example welding) then all of the metal should be counted for reporting purposes.  Going back to the 10,000 pound roll of steel, if I weld and create an “emission” then ALL of the steel is now counted for reporting purposes.  This meant anyone with large volumes steel, such as metal stamping facilities, were required to report under  section 311/312 of EPCRA – this didn’t make any sense and it certainly didn’t help emergency responders.

Under the new interpretation, facilities need only consider the “fume or dust” that is emitted to determine EPCRA applicability.  So, for example, if you weld, you need only consider the resulting fumes, not the total amount of steel used at your facility.  Keep in mind this is a federal rule, so your individual state has latitude to enforce a more strict interpretation.  But in general, it appears this will be a positive change for those handling large volumes of steel and for those agencies that likely had no use for data regarding the use and storage of steel and other metals

 For more information go to the Federal Register notice http://www.gpo.gov/fdsys/pkg/FR-2010-07-13/pdf/2010-17031.pdf

If you have questions about environmental regulations, environmental audits, or any other environmental compliance issue, contact Matthew Schroeder, P.E. (mschroeder@dragun.com) at 248.932.0228.

Chromium 6: Real Issue or Hype?

Is Chromium 6 the next target? Following a report from The Environmental Working Group (EWG) that hexavalent chromium was detected in 25 of 35 drinking water supplies, some are speculating that we will see more focus on monitoring for chromium. According to Environmental Compliance Alert, “The report is expected to prompt EPA to speed up development of a much tighter national drinking water standard for hexavalent chromium.” The current standard is 100 ppb.

What’s not widely reported is EWG used the California standard for chromium in drinking water; 0.06 ppb not the 100 ppb federal standard.

American Council on Science and Health (ACSH) advisor Dr. Robert Baratz, an expert on metal exposure and professor at the Boston University and Tufts University Schools of Medicine was not impressed with EWGs report on the threat of hexavalent chromium in drinking water. According to the ACSH website, “In an NPR article, he (Dr. Baratz) explained that it’s difficult to draw scientifically valid conclusions from the single samples EWG took from water taps in various cities. In addition, he questioned EWG’s decision to use a limit on chromium proposed for California as a benchmark for what would be an acceptable level of chromium-6 nationwide.”  http://www.acsh.org/factsfears/newsid.2190/news_detail.asp

The According to ACSH, “Our research found exactly one member of the EWG board has scientific credentials.”

As always, it’s good advice to look past the headlines.