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wildfire smoke philadelphia

Wildfire Smoke & Air Quality Action Days: A Small Business Operational Guide

Written by Jeremy on . Posted in Breaking News. No Comments on Wildfire Smoke & Air Quality Action Days: A Small Business Operational Guide

When wildfire smoke or elevated fine particulate matter (PM2.5) triggers official Air Quality Action Days across Pennsylvania, residents are advised to limit outdoor activity. For small business owners, however, these alerts also raise practical operational questions: How do you protect outdoor crews, maintain healthy indoor environments, and help prevent further local air pollution during a smoke event?

Understanding air quality starts with data and monitoring science. Behind every public forecast is a continuous stream of environmental measurement and atmospheric transport modeling. The Pennsylvania Department of Environmental Protection (DEP) Bureau of Air Quality operates a sophisticated statewide Ambient Air Monitoring Network — including the Commonwealth of Pennsylvania Air Monitoring System (COPAMS) — with dozens of automated monitoring stations strategically located throughout Pennsylvania’s air basins and communities.

Equipped with high-precision sensors, these stations continuously track weather patterns and measure airborne pollutants like ozone and fine particulate matter down to parts-per-billion levels. When wildfire smoke drifts across the Commonwealth, this sensor network, coupled with advanced air dispersion modeling, allows state regulators and atmospheric scientists to track smoke plumes in real time and issue timely Air Quality Action Days.

As regional or statewide Code Orange, Red, or Purple air quality alerts are declared, small businesses can use this real-time data to make informed operational decisions.

1. Track Real-Time Local Conditions with AirNow

Before scheduling high-exertion outdoor work or adjusting facility operations, consult localized air quality tools fed directly by state and federal monitoring sensors:

  • AirNow.gov: Jointly operated by the EPA and state air monitoring divisions (including PA DEP), AirNow provides color-coded Air Quality Index (AQI) forecasts based on continuous sensor data for ground-level ozone and fine particulates (PM2.5).

  • AirNow Fire and Smoke Map: For hyper-local smoke tracking, this interactive tool overlays official PA DEP monitoring sensors with satellite data and low-cost local air sensors to display real-time smoke plumes and ground-level pollution movement.

2. Protect Outdoor and On-Site Workers

During Code Orange (unhealthy for sensitive groups) or Code Red/Purple (unhealthy for all) alerts, physical exertion outdoors increases exposure to inhaled particulate matter. Small businesses with outdoor operations — such as landscaping, construction, logistics, and roofing — should consider:

  • Task Adjustments: Postpone heavy physical labor or shift demanding tasks to days with lower predicted particulate levels.

  • Frequent Rest Breaks: Provide shaded or indoor break areas with filtered air and encourage regular hydration.

  • Respiratory Protection: Supply voluntary-use N95 respirators for employees who must perform essential work outdoors during severe smoke events.

3. Maintain Indoor Air Quality (IAQ)

Indoor workplaces are not automatically immune to outdoor smoke. Fine particles can easily enter facilities through building ventilation intakes, loading docks, and doorways.

  • Upgrade Filtration: Inspect facility HVAC systems and upgrade to MERV 13 filters (or the highest rating compatible with your system) to effectively capture microscopic smoke particles.

  • Adjust Air Intakes: Temporarily set HVAC units to recirculate indoor air during peak smoke hours rather than drawing in unfiltered outdoor air.

4. Voluntary Steps to Reduce Local Emissions

During official Air Quality Action Days, the PA DEP encourages small businesses to voluntarily minimize operations that generate additional fine particulates or ozone precursors, helping prevent localized air stagnation:

  • Limit Fuel-Burning Machinery: Postpone non-essential use of gas-powered lawn and garden equipment, heavy diesel machinery, or open burning operations.

  • Optimize Fleet Travel: Consolidate delivery routes and enforce strict anti-idling policies for company vehicles.

  • Reschedule High-Emission Tasks: Where schedules permit, pause non-essential incineration, dust-generating manufacturing, or high-VOC solvent usage until air quality returns to Code Yellow or Green.

Need Environmental Compliance Support?

Whether you need help evaluating facility emissions, navigating DEP air permitting requirements, or understanding air monitoring standards, you don’t have to figure it out alone. EMAP provides Pennsylvania small businesses with free, confidential technical assistance.

Conventional oil and natural gas well

What Conventional Oil & Gas Operators Need to Know About PA’s VOC Reporting Rules

Written by Jeremy on . Posted in Breaking News, Regulatory Updates. No Comments on What Conventional Oil & Gas Operators Need to Know About PA’s VOC Reporting Rules

Pennsylvania’s Department of Environmental Protection (DEP) has released updated guidance to help conventional oil and natural gas operators comply with new Volatile Organic Compound (VOC) reporting requirements under 25 Pa. Code §§ 129.131–129.140.

These rules apply to owners and operators of conventional well sites, gathering and boosting stations, and natural gas processing plants that include certain pieces of VOC-emitting equipment.

While many small businesses may already know that annual VOC reports are due each year by June 1, it is important for operators to understand what equipment triggers reporting and how to submit reports correctly.

What Equipment Triggers Reporting?

According to DEP, reporting applies if your operation includes any of the following:

  • Storage vessels

  • Natural gas-driven continuous bleed pneumatic controllers

  • Natural gas-driven diaphragm pumps

  • Reciprocating and centrifugal compressors

  • Fugitive emission components (valves, flanges, connectors, etc.)

If your site operates any of this equipment, you may need to submit a report so DEP can determine whether your source is subject to the requirements or qualifies for an exemption.

How to Submit Reports

All initial and annual reports must be submitted using the DEP Public Upload System (Greenport).

  • No login or account is required

  • Reports must be uploaded as an Excel or spreadsheet file

  • DEP provides a reporting template, step-by-step guide, and a walkthrough video to help you complete the form accurately

If you are past due for your 2023 or 2024 submission, DEP recommends submitting as soon as possible.

Resources for Oil & Gas Operators

DEP has published a new flyer titled “Conventional Oil and Natural Gas VOC Sources – What You Need to Know for Reporting.” It includes:

  • A clear summary of what equipment is subject to reporting

  • Instructions for how, when, and where to file

  • Links to DEP’s upload portal, reporting templates, and guides

  • Contact information for DEP Air Quality staff

Free Help for Pennsylvania Small Businesses

Pennsylvania small businesses (generally 100 or fewer employees) can contact the Environmental Management Assistance Program (EMAP) for free and confidential assistance with:

  • Determining whether your site has reportable equipment

  • Completing the correct reporting template

  • Understanding the initial report requirement

  • Uploading reports through Greenport

  • Avoiding common errors that lead to rejected submissions

Call (877) ASK-EMAP or visit Contact EMAP for help. Additional resources are available on EMAP’s Oil & Gas Compliance Assistance page.

Why This Matters

Pennsylvania’s VOC reporting requirements apply to all owners and operators of conventional oil and natural gas wells, not just commercial oil and gas businesses. This means that individual homeowners, family farms, churches, or other organizations that own a conventional well may still have reporting obligations under 25 Pa. Code §§ 129.131–129.140.

EMAP can assist eligible small businesses with this process and help ensure compliance.

Note: this post was edited on December 10, 2025.

2026 Dry Cleaner Compliance Calendar Now Available

Written by Jeremy on . Posted in Breaking News, Regulatory Updates. No Comments on 2026 Dry Cleaner Compliance Calendar Now Available

The 2026 Dry Cleaner Compliance Calendar is now available for Pennsylvania dry cleaners. You can access a digital copy here or by visiting EMAP’s Dry Cleaner Resources page.

These environmental compliance calendars are designed to assist Pennsylvania dry cleaners in meeting state and federal environmental regulations. Each calendar includes important record-keeping elements that, when properly completed, serve as an annual record of compliance. Dry cleaners should retain completed calendars for a period of five (5) years.

Important Update on Hard Copies

Due to the ongoing Pennsylvania state budget impasse, hard copy versions of the 2026 calendar are not yet available. If and when possible, EMAP can provide printed copies once the budget situation is resolved and printing resources are restored. We appreciate your patience and encourage dry cleaners to use the digital version in the meantime.

If you have questions or need assistance with using the calendar, please contact EMAP directly by calling our toll-free hotline at (877) ASK-EMAP or emailing questions@askemap.org.

DEP Issues Updated General Permit (GP-14) for Human and Animal Crematory Incinerators

Written by Jeremy on . Posted in Breaking News, Regulatory Updates. No Comments on DEP Issues Updated General Permit (GP-14) for Human and Animal Crematory Incinerators

Pennsylvania DEP has finalized updates to General Permit GP-14, which regulates human and animal crematory incinerators. The revised permit became effective on August 16, 2025, and replaces the prior version.

Why This Matters

The GP-14 provides a streamlined and cost-effective alternative to obtaining an individual State-Only Operating Permit. The updated permit reflects new legislative changes, public feedback, and DEP’s ongoing efforts to balance environmental compliance with the practical needs of small businesses.

The updates to the new general permit are meant to improve air quality, operational safety, and administrative clarity. Previous versions of the GP-14 were often deemed too restrictive by crematory owners and operators, and thus were not an option to be covered by a DEP air quality permit. This often forced owners/operators to go the plan approval application route, which resulted in an individualized  State Only-Operating Permit specific to one’s operation and equipment.

Key Updates in the New GP-14

The following are some key updates to be aware of:

  • Cold Start Requirements: For units charged when cold, the secondary chamber must reach 1600°F and hold before the primary burner can fire. Interlock systems must be configured accordingly.

  • Prohibited Materials Clarified: Cremation of remains in plastic containers is prohibited, except for medical body bags. Pacemakers and electronic devices must be removed, and hazardous remedial devices (such as radioactive implants) must be removed “where feasible.”

  • Fee Structure: Application, renewal, and annual maintenance fees remain lower than individual permits, but crematories should plan for:

    • Application fee: $1,600

    • Renewal fee: $750 (every 5 years)

    • Annual maintenance fee: $500

  • Recordkeeping Adjustments: Crematories must continue to maintain records such as fuel usage, chamber temperatures, operator training, and device removal for five years. DEP decided against its earlier proposal for expanded annual reporting, so records must only be submitted upon request.

  • Fuel Sulfur Content: Only fuel oil requires sulfur content certification. Natural gas, LP gas, and propane are no longer included.

  • Source Testing: Newly constructed or modified crematory units must provide a recent stack test report from a similar model or conduct a new test within 180 days of startup.

  • Training Requirements: Operators must receive formal training that includes combustion principles, safety procedures, recordkeeping, and maintenance.

Additional Important Details from DEP’s Announcement

In addition to the key updates within the permit itself, the Pennsylvania Bulletin announcement provided some important reminders about how crematories must apply and operate under GP-14. These details help clarify how the permit is administered and what steps facilities need to take before beginning construction, modification, or operation.

  • Written DEP authorization is required before constructing, modifying, or operating under GP-14.

  • Electronic submissions are strongly encouraged through DEP’s Public Upload with Electronic Payment system.

  • The revised permit, technical support document, and comment-and-response summary are available in DEP’s eLibrary.

What This Means for Crematory Operators and Your Small Business

The new GP-14 still requires certain operating procedures, recordkeeping, and reporting to ensure the operation remains in compliance with environmental standards.  These include:

  • Expect tighter controls on cold starts and documentation of operating temperatures.

  • Maintain required records but no need for new annual uploads.

  • Factor updated fees into long-term operating budgets.

  • Update operator training and facility procedures to align with new standards.

Resources

For compliance assistance, contact EMAP for free, confidential support.  EMAP offers Pennsylvania small businesses technical assistance with understanding permitting and compliance obligations.

PA DEP Seeks Public Comment on Proposed Methane Emissions Plan for Existing Oil and Gas Facilities

Written by Jeremy on . Posted in Breaking News, Public Comment, Regulatory Updates. No Comments on PA DEP Seeks Public Comment on Proposed Methane Emissions Plan for Existing Oil and Gas Facilities

The Pennsylvania Department of Environmental Protection (DEP) is inviting public comment on a proposed State Plan to reduce methane emissions from existing crude oil and natural gas facilities across the state. The proposal is in response to a federal rule from the U.S. Environmental Protection Agency (EPA) under 40 CFR Part 60, Subpart OOOOc—also known as the Emissions Guidelines (EG) for Greenhouse Gas Emissions from Existing Oil and Natural Gas Operations.

This federal rule, part of the EPA’s broader climate review for the oil and natural gas sector, sets national “presumptive standards” to limit methane—a potent greenhouse gas—from facilities that were in operation on or before December 6, 2022. These standards are designed to improve air quality and reduce emissions through updated monitoring, leak detection and repair (LDAR), and equipment upgrades.

Under Section 111(d) of the Clean Air Act, states like Pennsylvania must create and submit plans to the EPA to implement and enforce these federal guidelines at the state level. DEP’s proposed State Plan outlines how Pennsylvania will meet these federal requirements, including timelines for industry compliance.

What This Means for Small Oil and Gas Operators:

If your business owns or operates existing crude oil and natural gas facilities, this rule may impact your operations. The proposal may require new compliance measures such as enhanced leak detection, emissions controls, and recordkeeping. The proposed plan includes specific compliance schedules, giving operators time to prepare and adjust.

Public Comment Period Open Until July 30, 2025

DEP is accepting public comments on the proposed plan through July 30, 2025. You can view the full proposal and its appendices online at https://www.ahs.dep.pa.gov/eComment/.

In addition, a series of public hearings has been scheduled from June 30 through July 16, 2025 at various locations throughout the Commonwealth.  Advanced registration is needed at least 1 week in advance to provide public testimony.

How to Submit Comments:

  • Online: Use DEP’s eComment system: https://www.ahs.dep.pa.gov/eComment/

  • Email: Send to ecomment@pa.gov (include your name and address)

  • Mail:
    Policy Office
    Department of Environmental Protection
    Rachel Carson State Office Building
    P.O. Box 2063
    Harrisburg, PA 17105-2063

If providing comments, please include “Proposed OOOOc State Plan” in the subject line of your written comment. Comments sent by fax will not be accepted.

In addition, for questions or to request copies of the proposed plan, contact Panna Chibber at (717) 772-3993 or pchibber@pa.gov.

power plant

EPA Proposes Repeal of Clean Power Plan Rules – Public Comments Open Until August 7, 2025

Written by Jeremy on . Posted in Breaking News, Public Comment, Regulatory Updates. No Comments on EPA Proposes Repeal of Clean Power Plan Rules – Public Comments Open Until August 7, 2025

The U.S. Environmental Protection Agency (EPA) is proposing to repeal parts of the Clean Power Plan, a set of federal rules that were designed to limit carbon pollution from power plants—especially those that burn fossil fuels like coal and natural gas.

This repeal would affect how states set rules for existing power plants, and also remove federal requirements for newly built or modified plants. EPA says this change is meant to reduce unnecessary regulatory burdens.

What This Means for Small Businesses

According to EPA, this repeal will not cause financial harm to small businesses. In fact, it’s expected to remove future compliance costs that some small companies might have faced if the rules stayed in place.

Here are a few key takeaways for small businesses based upon EPA’s analysis of potential significant economic impact on small entities:

  • These federal rules did not directly apply to most small businesses, but in some cases could have led to higher costs for power generators.

  • EPA reviewed the potential impact on small businesses that own certain types of natural gas power units and found that a few could have faced increased costs if the rules stayed in effect.

  • By repealing these rules, EPA believes small businesses will avoid those extra costs altogether.

Small Businesses Can Share Your Thoughts

EPA is giving the public, including small entities and small business owners, the chance to comment on this proposed repeal. If you have an opinion or concern, you can submit comments until August 7, 2025.

To read more about the proposal and how to send in your comments, visit:

If you have questions about how this proposal may impact your Pennsylvania small business, EMAP is here to help.

Annual VOC Reports for Oil & Natural Gas Sources Due June 1, 2025

Written by Jeremy on . Posted in Breaking News, Regulatory Updates. No Comments on Annual VOC Reports for Oil & Natural Gas Sources Due June 1, 2025

If your small business owns or operates equipment related to oil and natural gas development in Pennsylvania, it’s time to prepare and submit your annual VOC emissions report. These reports are required under Pennsylvania’s VOC (Volatile Organic Compound) regulations for both unconventional and conventional oil and natural gas sources (25 Pa. Code §§ 129.121–129.130 and §§ 129.131–129.140).

What Do I Need to Do?

Each year, owners and operators must report specific compliance information related to equipment that is subject to the regulations. The Pennsylvania Department of Environmental Protection (DEP) developed Excel templates to help you meet these requirements—one for Unconventional O&G sources and one for Conventional O&G sources. Each tab in the spreadsheet corresponds to a different reporting requirement.

  • Using the DEP template is optional—but your report must still be submitted in spreadsheet format (Excel preferred).

When is the Report Due?

The next annual VOC report is due June 1, 2025 and will cover calendar year 2024.

This deadline applies to all covered sources and is not subject to any extensions or enforcement suspensions.

How to Submit Your Report

Reports must be submitted through DEP’s Public Upload System:

  • Submission Type: Air Quality Report or Miscellaneous Submission (No Payment)

  • Request Type: Other

  • Submission Notes: Include “129.130 Annual Report” or “129.140 Annual Report”

  • Be sure to include: County and Municipality for each site listed in the report

Do you need help with the submission process? DEP provides a step-by-step Public Upload Guide to walk you through the process.

Why Reporting Matters

Timely and accurate reporting helps ensure your business stays in compliance with environmental regulations, while contributing to Pennsylvania’s efforts to reduce harmful emissions. Staying on top of these requirements can also help your business avoid potential enforcement actions.

EMAP consultants are available to speak with you and ready to answer any questions your small business might have about the annual VOC reporting requirements. Contact us at (877) ASK-EMAP or email us at questions@askemap.org.

Public Comment Period Open for General Permit (GP-14) for Crematories

Written by Jeremy on . Posted in Breaking News, Public Comment. No Comments on Public Comment Period Open for General Permit (GP-14) for Crematories

The Pennsylvania Department of Environmental Protection (DEP) has proposed revisions to General Permit GP-14, which regulates human and animal crematory incinerators. A public comment period is open until March 24, 2025, giving crematory owners and operators a chance to voice their opinions on the proposed changes before they take effect.

Why This Matters to Crematory Operations

General Permit GP-14 is intended to provide a streamlined and cost-effective alternative to obtaining an individual State-Only Operating Permit for crematory operations. The proposed February 2025 updates introduce new requirements and clarifications that could impact compliance procedures, operating costs, and reporting obligations.

Key Changes from the August 2024 GP-14 to the Proposed February 2025 Version

  1. New Compliance Requirements for Units Charged When Cold

    • If a crematory incinerator is charged before reaching 1600°F, the secondary chamber must now reach and hold 1600°F before the primary burner is fired and throughout the cremation cycle.
    • Interlock systems must be configured to prevent primary chamber firing until the secondary chamber is at 1600°F.

  2. New Sulfur Content Recordkeeping for All Fuels

    • Previously, only fuel oil sulfur content records were required. The new version expands this requirement to include natural gas, LP gas, and propane.

  3. Earlier Annual Reporting Deadline

    • The deadline for submitting reports to DEP moves from March 1st to February 1st each year.

  4. Updated Electronic Submission Process

  5. Clarifications on Prohibited Materials

    • Crematory operators must remove hazardous remedial devices (e.g., radioactive implants) “where feasible”, adding flexibility compared to the previous blanket prohibition.

How These Changes Could Affect Your Small Business

  • More detailed compliance requirements for cold-start cremations may affect operating procedures.
  • Additional fuel sulfur content tracking could create minor administrative issues or burdens.
  • The earlier reporting deadline means adjusting compliance workflows to meet the new due date.
  • Navigating DEP’s new electronic submission system may require familiarization with the updated process.

How to Submit Public Comments

Small crematory operations should review the proposed changes to the General Permit (GP-14) and provide feedback if deemed appropriate. Your input is important to ensuring that the GP-14 remains a practical and cost-effective option for small businesses while maintaining environmental compliance.

If you have questions or need assistance in understanding the proposed changes, please contact EMAP.

Annual NESHAP Reporting Reminder

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As we move into the New Year in 2025, it is an ideal time for small businesses subject to air quality regulations, such as National Emission Standards for Hazardous Air Pollutants (NESHAPs), to assess their compliance and prepare for upcoming recordkeeping and reporting requirements. Ensuring your facility’s adherence to these regulations helps maintain environmental standards and avoid potential penalties.

Steps to Ensure Compliance

  1. Review Your Air Quality Permits
    • Begin by examining your facility’s air permits. Take note of all recordkeeping and reporting obligations, including due dates for submissions. If you cannot locate your permits, Pennsylvania DEP has a public records portal on their website where you can locate copies of existing air permits.

  2. Understand Your Reporting Requirements
    • Facilities subject to NESHAPs such as the 6X and RICE rule are reminded that annual compliance reports must be submitted by January 31, 2025. These reports often include certifications of compliance as well as documentation of any deviations and corrective actions taken. Remember, regulatory agencies such as DEP and EPA often understand that occasional deviations can occur; the key is to promptly identify issues and address them accordingly.

  3. Check for Additional Reporting Obligations
    • Not all NESHAPs require annual compliance reports, and due dates may vary for those that do. Make sure to verify the specific requirements applicable to your facility.

Common NESHAPs with January Reporting Deadlines

Several area source National Emission Standards for Hazardous Air Pollutants (NESHAPs) have annual compliance reporting deadlines at the end of January. Notable examples include:

Need Assistance? If you have questions about your compliance responsibilities or need help navigating air-quality regulations, Pennsylvania’s Environmental Management Assistance Program (EMAP) is here to help. Contact us for guidance tailored to your small business needs.

By staying proactive and informed, you can ensure a successful start to the new year and continued compliance with environmental standards

pump jack oil & gas

DEP Suspends Enforcement of Initial Annual Reports for Oil and Gas Operators in PA

Written by Jeremy on . Posted in Breaking News, Regulatory Updates. No Comments on DEP Suspends Enforcement of Initial Annual Reports for Oil and Gas Operators in PA

In a recent announcement in the Pennsylvania Bulletin posted on January 27, 2024, the Pennsylvania Department of Environmental Protection (DEP) declared the suspension of enforcement for the initial annual reports under 25 Pa. Code §§ 129.130(k)(1) and 129.140(k)(1), which pertain to recordkeeping and reporting for conventional and unconventional oil and natural gas sources.

The initial annual report submissions for owners and operators of conventional oil and natural gas sources, due on December 2, 2023, covered the time period from December 2, 2022, through December 31, 2022. Similarly, for owners and operators of unconventional oil and natural gas sources, the deadline was December 10, 2023, addressing the time period from December 10, 2022, through December 31, 2022.

DEP has decided to suspend enforcement of the initial annual report submissions until June 1, 2024, the deadline for the second report, which will encompass the entire 2023 calendar year.

It is crucial for oil and gas operators in Pennsylvania to note that while the Department is exercising enforcement discretion, this does not exempt them from the potential of legal challenges by third parties under 25 Pa. Code §§ 129.130(k)(1) and 129.140(k)(1). DEP aims to provide flexibility to operators during this period, but compliance with regulations remains important.

This notice is intended to be a helpful outreach to small oil and gas operators in Pennsylvania, facilitating awareness and understanding of the adjusted reporting timelines. Operators are encouraged to stay informed and prepared for the upcoming reporting obligations and are advised to check DEP’s official resources or EMAP’s Oil & Gas page for any further updates or changes.

EPA

EPA Proposes Ban on TCE: How it May Affect Small Businesses

Written by Jeremy on . Posted in Breaking News, Public Comment, Regulatory Updates. No Comments on EPA Proposes Ban on TCE: How it May Affect Small Businesses

In a significant move aimed at safeguarding public health and the environment, the U.S. Environmental Protection Agency (EPA) has proposed a ban on the use of trichloroethylene (TCE), a chemical solvent with known serious health risks, under the Toxic Substances Control Act (TSCA). While this proposal has wide-reaching implications, it particularly resonates with the small business community, given the various industries that use TCE in their operations.

Where TCE is Often Used:

Small businesses may use TCE in cleaning and degreasing (including spot cleaning, vapor degreasing, cold cleaning, and aerosol degreasing) substances, and if they manufacture refrigerants or use refrigerants. TCE is also used in paint and coat manufacturing, plastics material manufacturing, wood window and door manufacturing, pharmaceutical preparation, and printing machinery. Additionally, TCE is also found in consumer products such as typewriter correction fluids, paint removers, paint strippers, adhesives, spot removers, cleaning fluids for rugs, and metal cleaners.

The proposed ban on trichloroethylene (TCE), while primarily aimed at protecting public health and the environment, will have several potential effects on small businesses.

Transition to Safer Alternatives:

Small businesses that currently use TCE in their products or processes will need to transition to safer alternatives. While this transition may involve some initial costs, it is likely to lead to long-term benefits, as safer alternatives are generally associated with lower health and environmental risks. Small businesses should consider exploring these alternatives and assess their feasibility in their operations.

Compliance Costs:

Small businesses will need to ensure compliance with the proposed rule, which may require changes in their manufacturing processes, product formulations, or supply chains. These adjustments may come with associated costs, including investing in new equipment or materials, revising safety protocols, and retraining employees.

Worker Protections:

The proposed rule includes stringent worker protections for limited remaining commercial and industrial uses of TCE. Small businesses will need to invest in safety measures to protect their employees from potential TCE exposure. This may involve additional training, personal protective equipment, and equipment upgrades.

Phased Transition for Some Uses:

The proposal acknowledges that for certain limited uses of TCE, there will be a longer transition period. Thus, small businesses may have more time to adapt to alternative chemicals or processes. However, they will still need to comply with the worker protections outlined in the proposal.

Reduced Legal and Financial Risks:

By proactively adopting the ban and transitioning to safer alternatives, small businesses can reduce the risk of legal and financial liabilities associated with TCE exposure. This can protect them from potential lawsuits, fines, and reputational damage.

Environmental and Health Benefits:

The proposed ban aims to reduce the adverse health effects and environmental contamination caused by TCE. Small businesses located in areas with historical TCE contamination can benefit from a cleaner and healthier environment, potentially improving the quality of life for their employees and the surrounding community.

Awareness of Health Risks:

The proposed ban raises awareness about the health risks associated with TCE, which can benefit small businesses by encouraging them to prioritize the safety of their employees and customers. Implementing safer practices can enhance the reputation of a business and improve relationships with stakeholders and the local community.

Public Comments and Engagement:

Small businesses have the opportunity to provide feedback during the public comment period, enabling them to express concerns or suggest adjustments to the proposed rule. This engagement can help shape the final regulations and ensure that the unique challenges faced by small businesses are considered.

Topics of interest to small businesses, in which EPA is requesting comments on as noted in the federal register notice, are the following:

  • EPA requests public comment on reasonable compliance timeframes for small businesses, specifically on whether and how to provide longer compliance timeframes for transitioning to alternatives for uses requiring reformulation and cleaning processes for cleaning parts for national defense or cleaning medical devices.
  • EPA requests public comment on differing compliance or reporting requirements or timetables that account for the resources available to small entities.
  • EPA requests public comment on the feasibility of use of alternatives to TCE and their availability for conditions of use that drive the unreasonable risk.
  • EPA requests public comment on how the rulemaking should consider TCE alternatives in light of ongoing regulatory scrutiny.
For those small businesses interested in voicing their opinions on this proposal, the EPA will accept public comments on or before November 30, 2023.

Update on Control of VOC Emissions from Gasoline Dispensing Facilities (Stage I & Stage II)

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UPDATE: Effective on August 20, 2022, Pennsylvania DEP is suspending the enforcement of a specific monitoring requirement – the inspection of the gasoline storage tank automatic tank gauge (ATG) cap.  The reason for the suspension is that after a review of the rule’s requirements it was determined that the likelihood of the ATG being compromised is very low and the verification of the ATG status after every gasoline truck delivery can be problematic and difficult to access.  Please note that the suspension of this specific monitoring requirement does not affect owners or operators of gasoline dispensing facilities relief from other Stage I & Stage II requirements.  Additional information can found in the August 20, 2022 issue of the Pennsylvania Bulletin which can be found here.

About the Stage I & Stage II Rulemaking

The Pennsylvania Environmental Quality Board finalized a final-form rulemaking that amends air quality regulations related to the control of VOC emissions at gasoline dispensing facilities. The rulemaking went into effect on March 26th, 2022 and targets Volatile Organic Compound (VOC) emissions during the following situations:
  • Loading of underground gasoline storage tanks (or Stage I vapor recovery)
  • Filling of motor vehicles at the pump (or Stage II vapor recovery)
  • During and after decommissioning of Stage II vapor recovery equipment from gasoline dispensing pumps.
The final-form rulemaking also adds and amends definitions related to Stage I and Stage II vapor recovery systems. A copy of the final preamble and regulation can be accessed here.

What is Stage I Vapor Recovery Systems?

“Stage I” refers to a vapor recovery system that controls the emission of gasoline vapors into the atmosphere during the transfer of gas from a gasoline tank truck to a gasoline storage tank at a Gasoline Dispensing Facility (GDF). A properly operating Stage I vapor recovery system returns vapors to the gasoline tank truck.  The equipment and controls of a Stage I system also control the emission of gasoline vapors during the storage of gasoline vapors at a GDF.

What is Stage II Vapor Recovery Systems?

“Stage II” refers to the vapor recovery system that controls the emission of vapors during the transfer of gasoline from a gasoline storage tank at a GDF to a motor vehicle fuel tank.  A Stage II vapor recovery system also controls emissions into the the atmosphere of vapors during the storage of gasoline at a GDF. Stage II vapor recovery technology uses special refueling nozzles, dispensing hoses and a system that draws refueling vapors in the Underground Storage Tank (UST).  A properly operating Stage II system moves the gasoline vapors from the motor vehicle fuel tank druing the refueling of the vehicle into the UST at the GDF.

Who is Affected by This Rulemaking?

The Pennsylvania Department of Environmental Protection (DEP) has finalized regulatory requirements for GDF owners and operators to decommission their Stage II vapor recovery system in 12 counties in the Philadelphia and Pittsburgh areas.  The compliance date for the decommissioning of Stage II systems is December 31, 2022.
  • The 12 Pennsylvania counties include: Allegheny, Armstrong, Beaver, Bucks, Butler, Chester, Delaware, Fayette, Montgomery, Philadelphia, Washington, and Westmoreland.
  • Owners and operators are those with gasoline throughputs that exceed at anytime >10,000 gallons per month (or 120,000 gallons per year) and independent small business marketers of gasoline that have a monthly throughput >50,000 gallons per month (or 600,000 gallons per year) in the above mentioned 12 Pennsylvania counties.
  • Persons performing decommissioning procedures, leak testing, and repairs at gasoline dispensing facilities.

What Happens After Decommissioning Takes Place?

For those entities that need to decommission their Stage II vapor recovery system by December 31, 2022, a notification form needs to be completed and submitted to the appropriate DEP regional office, Allegheny County Health Department, or Philadelphia Air Management Services.

Where Can I Learn More about this Rulemaking?

Pennsylvania DEP has put together a Frequently Asked Questions on their website for Decommissioning Stage II Vapor Recovery Systems at Gasoline Dispensing Facilities. In addition, Pennsylvania small businesses can always contact EMAP for further information and assistance if this rulemaking may affect your small business operation.  Simply call EMAP’s toll-free environmental hotline at (877) ASK-EMAP or email us at questions@askemap.org.

1-BP Added to Hazardous Air Pollutants List

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EPA has now added 1-BP to the Clean Air Act List of Hazardous Air Pollutants.  EPA Administrator Michael Regan signed the final rule on December 22, 2021 and this action was published in the Federal Register on January 5, 2022. The effective date of this final rule is February 4, 2022.
EMAP previously wrote about this topic which can be found here.
1-bromopropane (1-BP), also commonly known as nPB, is a chemical solvent often used in surface coating operations, dry cleaning, and in electronics and metal cleaning. 1-BP is also used an adhesive and is sometimes used in the manufacturing process in pharmaceutical and agricultural industries.

What does this rule mean for Pennsylvania small businesses?

If you are a Pennsylvania small business and use 1-BP as part of your operations, you will now need to take into account the use of 1-BP as a regulated Hazardous Air Pollutant (HAP). In Pennsylvania, an air quality permit is required if the actual emissions of a single HAP is greater than 1.0 ton per year or if emissions from multiple HAPs are greater than 2.5 tons per year. If you are an existing Pennsylvania small business that already uses 1-BP then you will now need to take into account the use of 1-BP in facility wide air quality permit limits, requirements, and reporting standards.

Are there any new special requirements that apply due to the 1-BP listing as a HAP?

Simply answered, no, there are no new requirements that will apply to a facility for simply using 1-BP in normal small business operations. The more complex narrative is that the use of 1-BP may affect a facility’s classification as an area source or air quality emissions into a major source, or Title V facility, due to the use of 1-BP and taking into account the facility’s Potential To Emit (PTE).  To help better explain this, EPA has put together a Question and Answers document on the Listing of 1-BP as a Clean Air Act Hazardous Air Pollutant.

Small Business Assistance with 1-BP

If any of this confuses you as a Pennsylvania small business owner or operator, EMAP’s highly skilled team of environmental assistance providers is available to talk one-on-one.  Simply call our toll-free environmental hotline at (877) ASK-EMAP or send us an email at questions@askemap.org.

Jeremy Hancher

Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC.  He holds over 15 years of experience in environmental compliance, environmental policy, and program management.  He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.