USA -  May 5 Deadline for feed facilities to Report Notification of Chromium, Manganese Levels

On Jan. 5, 2010, the Environmental Protection Agency issued a national emission standard for control of hazardous air pollutants, or HAP, for manufacturing of prepared feeds. Facilities that are covered are required to provide initial notification to EPA by May 5, 2010 that they handle chromium and manganese at levels equal to or exceeding threshold levels. Existing facilities then are required to submit a notification of compliance status to EPA on or before May 4, 2012; newly constructed facilities subject to the regulations are to submit such notification within 120 days of initial startup, or by May 4, 2012, whichever is later.

Subsequently, every March 1 thereafter, covered facilities are required to submit to EPA annual compliance certification reports for the previous calendar year. Covered facilities are to maintain required records, notifications and reports for at least five years.

When the final rule was published, the form to use to notify the EPA if a facility was covered under the rule was not yet available. The EPA has posted an example of the form that shows the required data that must be submitted to the agency.

EPA states that there is no specific template required for the initial notification. In the initial notification, the owner/operator simply needs to provide the information specified in the rule to their EPA Regional Office. States where the rule has been delegated, the initial notification needs to go to the EPA Regional Office and the delegated state or delegated local permitting authority.

You also may submit the required information in another format. It is highly recommended by AFIA that you talk with your permitting authority before using any of these examples as potential templates.

Download the example initial form. [Source: Keith Epperson, AFIA vice president of manufacturing and training].