Environmental Management Assistance Program
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EMAP Receives 2022 National Small Business Environmental Assistance Program Excellence Award

The National Steering Committee (NSC) of Small Business Environmental Assistance Programs (SBEAPs) & Small Business Ombudsmen (SBO) have selected the Environmental Management Assistance Program (EMAP) of Widener University with the 2022 Small Business Environmental Assistance Program Excellence Award. This award category recognizes exemplary performance of a state SBEAP in the areas of compliance assistance, sustainability, advocacy, and collaboration at the national level. The SBEAP Excellence Award emphasizes program leadership where they have created resources and work products, promoted policy advancements, developed program innovations, and established new partnerships to build a strong network of small business assistance.

Since 1997, EMAP has provided free and confidential environmental technical assistance to the small business community in the Commonwealth of Pennsylvania. Headquartered at Widener University in the School of Business Administration on Widener’s main campus located in Chester, Pennsylvania, EMAP services are available throughout the entire network of the Pennsylvania Small Business Development Centers (SBDC) to any Pennsylvania small business seeking assistance with issues of air quality and environmental compliance.

 

The EMAP team, which includes Lee Ann Briggs, Jeremy Hancher, Charles Haney, and Carrie Wintersteen, was chosen by the SBEAP/SBO for their involvement and leadership with the National Steering Committee, the Technical and Annual Training Subcommittees, and the Environmental Justice Workgroup.  In addition, EMAP was recognized for performing small business analyses on several Pennsylvania air quality rulemakings, for collaborating with the SBDCs and the Pennsylvania DEP Small Business Ombudsman to conduct in-person workshops and virtual webinars on environmental resources, and in partnering with other Pennsylvania stakeholder organizations and trade associations.

 

Since 2018, EMAP Program Manager Jeremy Hancher has served as an appointee from Pennsylvania Governor Tom Wolf on the Pennsylvania Department of Environmental Protection’s (DEP) Small Business Compliance Advisory Committee (SBCAC).  This committee provides timely feedback on Pennsylvania air quality regulations and proposed rulemakings, environmental policies and programs, and represents the perspectives and challenges faced by Pennsylvania small businesses.

 

Dale Kaplan, owner of Kaplan’s Careful Cleaners and long-time Chair of the SBCAC, commented on EMAP services and having received the award by saying, “I have been with the DEP Small Business Compliance Advisory Committee for 26 years and EMAP has stepped up to the plate, the whole team, along with the 16 SBDC universities across the state and have served small businesses in a way that is really phenomenal.  You deserve what you are getting, thank you.”

 

Several EMAP small business clients have received National SBEAP small business awards of their own including Pennsylvania small businesses Abilene Boot Company in 2022, Dent Design Hardware in 2021, Gate 7 LLC in 2020, and Pik Rite, Inc. in 2017.  During the COVID-19 pandemic, EMAP continued to be a reliable and steady presence to Pennsylvania small businesses needing environmental assistance and support.  EMAP even pivoted during the early stages of COVID to utilize its connections within the Pennsylvania SBDC to provide firsthand knowledge of economic opportunities so that small businesses could access small business grants and low-interest loans related to COVID related shutdown orders.

 

Always looking to better assist Pennsylvania small businesses in any way they can, the EMAP team recently surveyed their small business clients that received technical assistance in 2021.  One small business noted the following in the survey:

“I’ve worked with EMAP for many years. The services they provide to small businesses are exceptional. I have and will continue to work with and support EMAP and continue to recommend and refer them to others as well.”
 

1-BP Added to Hazardous Air Pollutants List

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.

Proposed Rulemaking for Dry Cleaning Facilities

EPA has proposed amendments to the National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities. This proposal would add provisions which would require all dry-to-dry machines at new and existing facilities to have both refrigerated condensers and carbon adsorbers as secondary controls.
The request for comment period is currently open.  EPA seeks comments and information regarding the number of third generation and earlier model dry cleaning machines that potentially could still be in operation.  In addition, EPA seeks information on dry cleaning practices, processes, and control technologies that could reduce emissions from hazardous air pollutions, or HAPs, for fourth generation (or better) dry cleaning machines.
A copy of the rule summary, the new proposed rule, and fact sheets can be found here.
General speaking, most dry cleaning facilities and operations are small businesses.  Estimates from EPA report that there are approximately 10,000 to 15,000 perchloroethylene dry cleaning facilities in the United States.  Unfortunately, due to the COVID-19 pandemic it is estimated that 10-15% of perc dry cleaners have closed.

Environmental Reports due March 1st 2022

March 1st is an important deadline for some small businesses that may be subject to Air Quality Emissions Inventory or Hazardous Waste Biennial Reporting. The Annual Emission Statement (AES) report is required by the Pennsylvania DEP Bureau of Air Quality to report on point sources meeting certain thresholds for large emitters of air pollution.  Facilities inventoried for emission statement purposes may include Non-Title V facilities, or smaller “area sources” of air emissions. Regional DEP air quality staff will often determine and notify which facilities are required to report on their air emissions. More often than not, this requirement will be listed in a facility’s State-Only Operating Permit. There are some emission reporting exemptions for small stationary sources. If you are a small business and question whether or not you are subject to air quality emissions reporting, please contact one of our EMAP environmental consultants for further assistance.
The Hazardous Waste Biennial Report is due March 1, 2022 and is required of any Pennsylvania hazardous waste Large Quantity Generator (LQG) for the calendar year ending December 31, 2021.  A small business is considered a LQG of hazardous waste if your operation generates more than 2,200 lbs of hazardous waste or more than 2.2 lbs of acute hazardous waste per calendar month.
Small businesses with an obligation to report hazardous waste acitivities should use EPA’s RCRAInfo system for the electronic submission process.
Additional information on hazardous waste reporting requirements can be found on the Pennsylvania DEP’s website found here.
If you are a Pennsylvania small business that needs further assistance with air quality emissions reporting or the hazardous waste biennial report, contact EMAP by calling our toll-free environmental hotline at (877) ASK-EMAP or email us at questions@askemap.org.

The Circular Merchant: Pennsylvania’s New Materials Exchange

A new online platform to exchange materials is now available to Pennsylvania small businesses and organizations.  The Circular Merchant, hosted by the Pennsylvania Recycling Markets Center, allows facilities and operations a way to get rid of unneeded materials by posting items on the new website or via a smartphone app.
Items that may be exchanged include examples such as electronic scrap, glass, organics & composting, paper & cardboard, plastics, metals, textiles, and yard sale items.  Users can browse for materials on the Circular Merchant website or create a listing to get rid of excess materials as a means of sustainably recycling or reusing materials.
The benefits are obvious for small businesses and users.  Less waste goes to landfills, businesses can become better stewards of the environment, and a little money can be made (if desired).
The Circular Merchant takes the place of the retired Pennsyvania Material Trader website.  The PA Material Trader was originally established in 2004 by EMAP and the Pennsylvania Small Business Development Centers (SBDC). Operating under the premise that what may be “trash” to one small business may be a “treasure” to another, the PA Material Trader had seen its glory days behind it.  Thus, EMAP’s friends and partners over at the Recycling Markets Center took in and embraced the premise of hosting Pennsylvania’s material exchange platform.

2022 Dry Cleaner Compliance Calendars available

Pennsylvania dry cleaners can now request copies of the 2022 Dry Cleaner Compliance Calendar. These calendars are an important small business environmental compliance tool to help fulfill recordkeeping requirements per state and federal regulations. EMAP has a select amount of print copies of the 2022 calendar available that we will be happy to mail out to any Pennsylvania dry cleaners in need. Simply contact us at our toll-free environmental hotline at (877) ASK-EMAP or email us at questions@askemap.org. Electronic versions are also available online at EMAP’s Industry Sector Resources for Dry Cleaners. Also important to note is that the use of perc machines at dry cleaning facilities located in buildings in which people reside such as houses, apartments, condos, and co-ops (co-residential) was prohibited after December 21, 2020. See here for more information about this upcoming residential perc phase-out.

Updated General Information Form Now Available for DEP Permit Applications

Pennsylvania DEP has updated its General Information Form (GIF) which is a form used to facilitate coordination between different types of permit or authorization applications for the same project.  The updated GIF form can be accessed in DEP’s eLibrary found here.
Small business permit applicants should begin using the updated forms immediately as older versions of the GIF form will only be accepted through September 30, 2020.
The GIF form is typically used in situations when a small business submits a permit application to Pennsylvania DEP for the very first time for a particular project. This could be if a business decides to start a new type of operation in Pennsylvania and it is determined that an environmental permit application will be needed.  The form is thus used to determine whether additional environmental permit applications will be required for the project.
As an example, if a small business is required to submit an air quality permit application for a project, and the business has never submitted an environmental permit application to DEP in the past, then the GIF form is a tool used by DEP to determine if additional permit applications (e.g. waste, stormwater, etc.) will also be required.
If a small business is considering starting a new project in Pennsylvania, or is expanding or relocating an existing operation, then it is suggested to first use Pennsylvania DEP’s Permit Application Consultation Tool.
Small businesses in Pennsylvania can also reach out to EMAP staff to discuss your project and see if any environmental permit applications may be required by DEP.  All EMAP services are strictly confidential and are offered at no cost.

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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.
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