Monday, March 30, 2009

MassDEP Limits Mercury in Industial Wastewater Discharges

Massachusetts Department of Environmental Protection (MassDEP) restrictions on mercury discharges to municipal sewer systems go into effect on May 1, 2009. These rules, promulgated under the Massachusetts Mercury Management Act, limit the maximum concentration of mercury in sanitary sewer discharges from industrial users to less than 1 ug/L (1 ppb). By July 2007, all dischargers were to have determined possible sources of mercury in their discharges and have taken reasonable steps to eliminate them.

[What is 1 ug/L (parts per billion) mercury equivalent to?]

Caltha LLP provides specialized expertise to clients nationwide in the evaluation water quality and wastewater requirements, NPDES permitting, and preparing cost-effective wastewater programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
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Thursday, March 26, 2009

Revised NESHAP for Petroluem Refineries

EPA recently released its final amendments to the National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (40 CFR 63, Subpart CC). EPA is required to review the developments in practices, processed, and control technologies every eight years and update national emissions standards to address the "residual risk" after implementation of the original standards.

The updated NESHAP includes new requirements for storage vessels. All Group 1 external floating roof (EFR) storage tanks will be required to install controls for guide poles and other openings, and additional inspection, recordkeeping, and reporting requirements.

Heat exchange systems will be required to conduct monthly sampling and analyses for VOC in the cooling water. The amendments to Refinery MACT will require the repair of leaks in heat exchangers within 45 days of the sampling event in which the leak is detected, unless a delay in repair is allowed.

All Group 1 storage vessels and heat exchange systems at existing refineries must be in compliance within 36 months after the Final Amendments are published in the Federal Register.

EPA opted not to promulgate changes to Refinery MACT that would include performance standards and monitoring requirements for enhanced biological units to treat wastewater streams.

Caltha LLP provides specialized expertise to clients nationwide in the multimedia environmental permitting, regulatory compliance and auditing, and developing cost-effective compliance management programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
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Wednesday, March 25, 2009

North Carolina CAFO General NPDES Permit Renewal

The North Carolina Department of Environment, Health, and Natural Resources – Division of Water Quality has revised its general NPDES discharge permits for confined animal feeding operations (CAFO). The current general permits for waste systems at swine, cattle and dairy and wet poultry operations will expire on Sept. 30, 2009. Operators of swine, cattle and poultry farms who come under the state general permits for wastewater systems need to apply for renewal under the new permit before April 1, 2009.

Animal feeding operations that have more than 250 swine, 100 confined cattle or dairy animals, 75 horses or a wet litter operation for more than 30,000 chickens are required to apply for a permit from the state.

General permits set requirements for waste management activities common to facilities of a particular type, and are issued as a class every five years. General permits for animal operations are issued along with certificates of coverage that address specific requirements for each facility.

The new general permits differ from the current permits in some operational, monitoring and reporting requirements. The most substantive change to the current permit is that application of waste must stop within 4 hours of a National Weather Service (NWS) issuing a warning of a hurricane, tropical storm or flood watch for the county in which the CAFO is located.

Looking for other water quality-related topics?, go to:
Water Quality Standards Aquatic Toxicology NPDES Permit Limits

Caltha LLP provides specialized expertise to clients nationwide in the NPDES permitting, State and Federal water quality regualtions, and preparing cost-effective compliance management programs.

For further information contact Caltha LLP at
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Tuesday, March 24, 2009

Proposed Reciprocating Internal Combustion Engine RICE Rules

Update:  January 2013 - EPA Released Final RICE NESHAP

On March 5, 2009, EPA published new proposed 40 CFR Part 63 rules for reciprocating internal combustion engines (RICE). The rules would affect:
  • Engines at facilities classified as "Area Sources" with hazardous air pollutant (HAP) emissions less than 10/25 TPY.
  • Engines with horsepower rating less than 500 at major source facilities and constructed/reconstructed before June 12. 2006.
  • Engines with horsepower rating greater than 500 at major source facilities and constructed/reconstructed before December 12, 2002.

EPA expects that the new emissions limits would be met by installing "after-treatment" controls such as:
  • Existing rich-burn engines would install non-selective catalytic reduction (NSCR).
  • Existing diesel engines would install oxidation catalysts and/or catalyzed diesel particulate filters (CDFP).
  • Non-emergency engines with greater than 300 horsepower would burn ultra-low sulfur fuel.
Caltha LLP provides specialized expertise to clients nationwide in the air emission permitting, regulatory compliance support, and preparing cost-effective regulatory compliance programs.
For further information contact Caltha LLP atinfo@calthacompany.com
orCaltha LLP Website




Monday, March 23, 2009

Changes to 2009 Toxic Release Inventory Report Requirements

Toxics Release Inventory (TRI) reporting requirements were changed on March 11, 2009 as part of the Omnibus Appropriations Act of 2009. These changes affect TRI reports due July 1, 2009. The 2009 Omnibus Appropriations Act returned TRI reporting requirements back to the rules in effect prior to December 22, 2006.

The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals be submitted on "Form R,", which is the more detailed form. For all other chemicals the shorter form, “Form A” may be used only if the annual reporting amount is 500 pounds or less and that the chemical was manufactured, processed or otherwise used in an amount not exceeding 1 million pounds during the reporting year. EPA will issue a rule shortly revising the regulatory text in the Code of Federal Regulations to reflect these changes. TRI-ME software and other reporting assistance materials are also being revised.

As background, in December 2006 U.S. EPA revised the reporting requirements for releases of listed chemicals (commonly known as 313 chemicals) required under Section 313 of the Emergency Planning & Community Right-to-Know Act (EPCRA). The revisions made by EPA in 2006 related to the Forms used to report 313 chemical releases. Form R is typically used to report releases, and data submitted on Form R is released to the public. Form A is a streamlined reporting process, used for 313 chemicals released in smaller quantities. Data submitted on Form A is not released to the public. The revision made by U.S. EPA changed the thresholds for when Form A could be used. Form R could always be used to report data, even for small quantities.

The 2006 revision allowed some facilities to use a streamlined reporting process; chemicals reported using the streamlined process would not be included in facility TRI reports released to the public. In response, twelve States filed a law suit against U.S. EPA in November 2007. The suit claims that the revision prevented citizens and communities from having access to the critical information required under EPCRA.

The 2009 changes to TRI reporting only affects how TRI data are reported; it does not change the thresholds used to determine if a TRI report is required. This change only applies to TRI reporters with total releases less than 5,000 lbs/year. No revisions were made by U.S. EPA for reporting 313 chemicals that have releases greater than 5,000 lbs/year.


[Read more about recent changes to TRI reporting for auxiliary facilities]
[Read more about 2008 legislation in Minnesota that reversed 2006 EPA TRI changes for Minnesota TRI sites]

Caltha LLP provides specialized expertise to clients nationwide in the EPCRA and TRI reporting, developing hazardous material tracking procedures, and preparing cost-effective regulatory compliance programs.

For further information contact Caltha LLP at
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Tuesday, March 17, 2009

Regulatory Updates - Environmental Management and Compliance

In addition to this ENVIRONMENTAL REGULATORY COMPLIANCE page, Caltha LLP maintains several websites to provide regulatory updates and discussion of current environmental, health and safety topics, as listed below. Interested parties can register to receive automatic notification when a new topic is posted.

SWPPP - Stormwater Pollution Prevention Plans - Stormwater Permits - Stormwater Training
Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits, Stormwater Pollution Prevention Plans, monitoring, training, spill prevention and control, SPCC compliance.

Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits
Discussion of a variety of topics related to State and Federal water quality standards, ambient water quality criteria, sediment criteria, NPDES & site-specific discharge standards, water quality management, aquatic toxicology, aquatic community impacts, and water quality assessment.

Environmental Sustainability - Sustainable Environmental Management Systems
Discussion of sustainability topics, including pollution prevention, waste reduction, material reuse, environmental management systems, product stewardship, and international environmental standards.

Environmental Due Diligence - Site Assessments - Phase I ESA - Environmental Liability
Discussions and comments regarding environmental due diligence, environmental liabilities, CERCLA liabilities, Phase I environmental site assessments, corporate liabilities, environmental compliance liabilities, quantitative environmental liability assessment.

Regulatory Briefings
Regulatory Briefings are published periodically by Caltha to highlight new or proposed regulations on a wide range of environmental, health & safety topics. These briefings are generally 2- to 4-pages in length and provide an overview of the regulations and discuss potential impacts on the regulated community. Participants must sign up to receive an email link to new Regulatory Briefings as they are posted.


Caltha LLP provides specialized expertise to clients nationwide in the environmental permitting & compliance, environmental management systems, and preparing cost-effective EHS compliance programs.

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South Coast AQMD Rules for Thinners and Solvents

The South Coast Air Quality Management District (SCAQMD) has recently adopted rules that restrict the VOC content of a wide range of paint thinners and solvents commonly used as consumer products and in commercial and industrial settings. The purpose of the rule (Rule 1143) is to reduce emissions of volatile organic compounds (VOCs) from the use, storage and disposal of consumer paint thinners and multi-purpose solvents commonly used in thinning of coating materials, cleaning of coating application equipment, and other solvent cleaning operations.

The rule applies to anyone who supplies, sells, offers for sale, or manufactures consumer paint thinners and multi-purpose solvents for sale in the SCAQMD, as well as anyone who uses or solicits the use of any consumer paint thinner and multi-purpose solvent within the SCAQMD.

The rule, adopted March 6, 2009, restricts the VOC content of consumer paint thinners and multi-purpose solvent to:

2.5 Lbs VOC/gal (effective 1/1/2010)
0.21 Lbs VOC/gal (effective 1/1/2011)

Some exemptions are included for certain materials and uses.

Caltha LLP provides specialized expertise to clients nationwide in the environmental permitting, developing pollution prevention procedures, and preparing cost-effective environmental compliance programs.

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Wednesday, March 11, 2009

Illinois Clean Air Mercury Rule CAMR Revision

Illinois' Clean Air Mercury Rule (CAMR) provides for the control of mercury from coal-fired electric generating units. Despite the fact that the federal CAMR rule has been vacated, IEPA regards the majority of the rule as in effect. However, because a number of monitoring, recordkeeping, and reporting provisions simply incorporated the federal CAMR rule by reference, and so are no longer valid, the Illinois rule must be amended.

The proposed rule no longer requires a CEMS, but allows periodic emissions testing as an alternative. Additionally, under the proposed rule, units complying with the Multi-Pollutant Standard or the Combined-Pollutant Standard can elect to comply with these monitoring requirements or with semi-annual emissions testing requirements

Under current rules, emissions monitoring must have commenced by January 1, 2009. However, in the proposed rule, this deadline is extended until July 1, 2009. The proposed rule also amends reporting requirements.

Caltha LLP provides specialized expertise to clients nationwide in the air emission and NPDES permitting, environmental management systems develpment, and preparing cost-effective regulatory compliance programs.


For further information contact Caltha LLP at
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Tuesday, March 10, 2009

NDEQ Proposed Area Source NESHAP Rule

The Nebraska Department of Environmental Quality (NDEQ) is proposing that seven area source NESHAPS be adopted and implemented as issued by the EPA. For two EPA standards, however, the NDEQ is proposing additional rules which will allow sources to limit monthly throughputs below the facility’s maximum design capacity in order to avoid the more stringent and costly controls required for facilities with greater monthly throughputs. Sources taking these limits must document their adherence to the agreed upon lower throughputs. The two industry categories for which this option will be offered are bulk gasoline terminals and gasoline dispensing facilities.


  • Hospital Ethylene Oxide Sterilizers (Subpart WWWWW)
  • Electric Arc Furnace Steelmaking Facilities (Subpart YYYYY)
  • Iron and Steel Foundries Area Sources (Subpart ZZZZZ)
  • Paint Stripping and Miscellaneous Surface Coating Operations (Subpart HHHHHH)
  • Clay Ceramics Manufacturing (Subpart RRRRRR)
  • Glass Manufacturing Area Sources (Subpart SSSSSS)
  • Secondary Nonferrous Metals Processing (Subpart TTTTTT)

Caltha LLP provides specialized expertise to clients nationwide in the environmental permitting, environmental management systems, and preparing cost-effective compliance programs.


For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website




Pesticide NPDES Permit - NDEQ Proposed Permit By Rule

The Nebraska Department of Environmental Quality (NDEQ) is proposing a Permit-By-Rule related to the application of pesticides in and near waters of the State.

As background, the Permit-by-Rule is being proposed to address a gap in permit coverage left after a decision by the 6th Circuit Court of Appeals in January 2009, which vacated the U.S. Environmental Protection Agency (EPA)’s pesticide rule.

[Read more about vacatur of EPA pesticide rule]

The NDEQ rule establishes a Permit-by-Rule for the application of pesticides to, over, or near, waters of the state provided that the pesticide applicator:

(1) complies with FIFRA requirements relating to water quality, compliance with all label application directions, buffer zones, application locations, intended targets, protecting threatened or endangered species, times of day, temperature or other application requirements, and proper disposal of pesticide residues; and
(2) retains certain information relating to name of the pesticide, targeted pests or weeds, pesticide label, and details of the application.

The Permit-by-Rule applies to chemical pesticides only; no biological pesticides are allowed under the Permit-by-Rule. NDEQ also requires the applicator to report any adverse impacts to non-targeted species or the environment to the Department within 24 hours.




Caltha LLP provides specialized expertise to clients nationwide in the wastewater permitting, water quality assessments, and preparing cost-effective compliance management programs.


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SPCC Rule - 40 CFR 112 - Redefining "Navigable Waters"

In November 2008, the Environmental Protection Agency (EPA) promulgated a final rule to amend a Clean Water Act (CWA) Section 311 regulation to change the definition of the term “navigable waters''. This amendment affects compliance with the SPCC Rule, 40 CFR 112.

As background, the SPCC rule was originally promulgated on December 11, 1973. The 1973 SPCC rule defined “navigable waters'' (see below). In 2002, EPA amended the SPCC rule including a revision to the regulatory definition of “navigable waters”.

In 2008, a US District Court ruled that the Agency's promulgation of the revised definition of "navigable waters'' in the July 2002 SPCC rule violated the Administrative Procedure Act. The court vacated the 2002 definition and specifically restored the 1973 SPCC regulatory definition:

Navigable waters of the United States means "navigable waters'' as defined in section 502(7) of the FWPCA, and includes:
(1) All navigable waters of the United States, as defined in judicial decisions prior to passage of the 1972 Amendments to the FWPCA (Pub. L. 92-500), and tributaries of such waters;
(2) Interstate waters;
(3) Intrastate lakes, rivers, and streams which are utilized by interstate travelers for recreational or other purposes; and
(4) Intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in interstate commerce.


[Read more about recent changes to SPCC Rules]

[Request information on State-specific SPCC Plans and Template Plans]

Caltha LLP provides specialized expertise to clients nationwide in the evaluation regulatory requirements & rules, obtaining environmental permits, and preparing cost-effective compliance programs.


For further information contact Caltha LLP at
info@calthacompany.com
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Monday, March 9, 2009

MDEQ Section 404 Wetlands Program - EPA Program Review

In 2008, the U.S. Environmental Protection Agency (EPA) issued a report on its informal review of Michigan’s EPA-approved Clean Water Act (CWA) Section 404 wetlands program. Michigan is one of only two States to have received approval to administer the Section 404 program. Michigan’s Section 404 program is implemented by the Michigan Department of Environmental Quality (MDEQ).

As background, in 1997 EPA conducted a review of Michigan’s approved CWA Section 404 program and identified deficiencies that required corrective action. In its July 31, 2008 Notice, EPA again identified a number of deficiencies in Michigan’s program. MDEQ has agreed to address the deficiencies listed by EPA through a number of means, including seeking legislative amendments to Michigan’s wetlands statute, Part 303 (Wetlands Protection) of the Michigan Natural Resources and Environmental Protection Act (NREPA).


MDEQ committed to initiating the legislative corrective actions in early 2009 and to completing them within 36 months. EPA will review the status of MDEQ’s corrective actions within 36 months after the Notice to determine whether Michigan’s Clean Water Act Section 404 wetlands program approval should be revoked.

EPA took issue with a number of activities that Part 303 exempts from the requirement to obtain a wetlands permit, but that are not exempted from the CWA’s requirements, including exemptions for:



  • agricultural activities;

  • drain creation and improvement; and

  • iron and copper mining tailings basins.

To address these deficiencies, MDEQ has agreed to seek legislative amendments that would limit the agricultural exemptions, delete the agricultural drainage exemptions, delete the exemption for iron and copper mining tailings basins; and to delete the exemption for utility maintenance activities.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation water quality rules, wastewater and stormwater permitting, and preparing cost-effective compliance management programs.


For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website




IEMA EPCRA Tier 2 Reports - Extension of Due Date

Owners or operators of facilities that have hazardous substances on hand in quantities above threshold levels must submit Emergency Preparedness and Community Right-to-know Act (EPCRA) Tier 2 forms by March 1 each year. The Tier 2 report covers the previous calendar year.

The Illinois Emergency Management Agency (IEMA) has extended the reporting deadline for Illinois facilities until March 16, 2009.

The Illinois Emergency Management Agency (IEMA) now requires all regulated facilities to submit Tier 2 information electronically by using Tier 2 Manager, IEMA's Tier 2 on-line filing system. Each facility's username is unique to its physical address. IEMA also requires all EPCRA Section 302 (EHS) and EPCRA Section 311 (MSDS) submissions be made by using Tier 2 Manager. Hard-copy submissions are no longer accepted.

For Reporting Year 2008, there are two new required fields in Tier 2 Manager's Facility Section: 1) drop-down box to select a facility's jurisdictional fire department and 2) addition of a North American Industry Classification System (NAICS) number. NAICS is replacing the SIC Code.

Facilities that reported in 2007, but are not subject to reporting in 2008, should make the facility inactive on the Tier 2 Manager Facility Home Page. Facilities that didn't file in 2007, but are reporting for 2008, must contact IEMA for a state-issued User ID and Password.

[Read more about recent changes to EPA EPCRA 311-312 reporting requirements]
[Read more about recent changes to EPA EPCRA 313 – TRI reporting requirements]

Caltha LLP provides specialized expertise to clients nationwide in the regulatory reporting requirements, EPCRA compliance, and preparing cost-effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website




Saturday, March 7, 2009

All Appropriate Inquiry - Phase I ESA for Forest and Rural Properties

In December 2008, the U.S. Environmental Protection Agency (“EPA”) issued a final rule amending the standards and practices for “All Appropriate Inquiries” under the CERCLA. The changes now to allow the limited use of ASTM E2247-08 “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property.” The rule applies to conducting a site characterization or assessment on a large forested or rural property with a brownfields grant and will become effective on March 23, 2009. However, EPA also published a separate proposed rule proposing the same change to the All Appropriate Inquiries regulations.

Conducting environmental site assessments for large tracts of forested or rural lands presents a challenge to strict adherence to the ASTM Standard Method for Phase I environmental site assessments (ASTM E 1527-05). The final rule and the proposed change to the All Appropriate Inquiry requirements will benefit organizations purchasing large tracts of forested lands or large rural properties that may want to claim landowner liability protections as innocent landowners, bona fide prospective purchasers, or contiguous property owners.

[Read more about Landowner Liability Protections – LLPs]
[Read more about All Appropriate Inquiry under CERCLA]

Caltha LLP provides specialized expertise to clients nationwide in the environmental due diligence, environmental site assessment, and environmental liability evaluations.

For further information contact Caltha LLP at
info@calthacompany.com
or
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Aggregation Under New Source Review - Extension of Compliance Date

On January 12, 2009, EPA issued a final rule that revises the agency’s policy on “aggregation” as it relates to New Source Review (NSR) under the Clean Air Act. For the purpose of determining whether NSR applies, this rule directs facilities and permitting authorities to combine, or aggregate, emissions from plant modifications when those projects are related. Therefore, total emissions for the related projects must be considered when permitting authorities determine whether NSR applies.

NSR is a pre-construction permitting program to ensure air quality is maintained when factories, industrial boilers and power plants are built or modified. The program ensures that appropriate emission control technology is installed at new plants or existing plants that are undergoing a major modification. Aggregation refers to the grouping of multiple, related physical or operational changes into a single project for evaluating requirements under the New Source Review program.

On February 9, 2009, EPA extended the effective date of the rule final rule modifying the NSR air permitting program’s “aggregation” policy, to allow for further review. This action is in response to the White House’s January 20, 2009, and the Office of Management and Budget’s January 21, 2009, memoranda regarding regulatory review. EPA also will reconsider one or more of the aspects of this final rule raised by the Natural Resources Defense Council in a petition for reconsideration. To allow time for the review and the reconsideration, EPA will stay the effective date of this rule for 90 days, until May 18, 2009.


Caltha LLP provides specialized expertise to clients nationwide in the air emission review, air emission permitting, and preparing cost-effective air compliance management programs.

For further information contact Caltha LLP at
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Pharmaceuticals in Universal Waste Rule - Comment Period Extended

EPA announced that it has added an extra 30 days for the public and stakeholders to comment on the agency's proposal to add hazardous pharmaceutical wastes to the federal universal waste program. (Amendment to the Universal Waste Rule: Addition of Pharmaceuticals). The public comment period will now close on March 9, 2009.

The EPA Office of Resource Conservation and Recovery, formerly known as Office of Solid Waste made the extension in response to requests for more time to submit comments on the proposed rule from several stakeholders, including the Northeast Waste Management Officials' Association, Waste Management, PharmEcology Associates LLC, Healthcare Distribution Management Association, Clean Harbors Environmental Services, and the Environmental Technology Council.

[Read more about proposed amendments to the Universal Waste Rule]

Caltha LLP provides specialized expertise to clients nationwide in the evaluation solid waste and hazardous waste rules, developing waste handling procedures, and preparing cost-effective waste management programs.

For further information contact Caltha LLP at
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or
Caltha LLP Website




NPDES General Permit for Vessels - Potential EPA Review

The Environmental Protection Agency has indicated that the agency plans to reconsider rules to control discharges from vessels which were finalized in December 2008 and made effective February 6, 2009. Environmental groups also sued EPA in February 2009, saying the permit did not meet requirements of the Clean Water Act.

In December, the EPA released a general permit for cargo vessels entering the Great Lakes or other US waters from overseas that includes rules for 26 types of discharges, such as ballast, oily bilge water and "gray water", deck runoff and engine cooling water. Beginning on February 6, 2009, vessels ranging from large cruise ships to barges, tankers and many recreational vessels have to obtain permit coverage and meet certain requirements under the terms of the Vessel General Permit (VGP). These new requirements include best management practices and standards that differ depending on the type of discharge and the type of vessel. Recordkeeping requirements, self reporting, training and other obligations are also required for vessel owners and operators.

One of the key goals of the permit program is to control the spread of invasive species. Ballast water is a leading pathway for the spread of zebra mussels and other non-native aquatic species, which can displace native species and result in significant damage. The agency now believes that the VGP may do too little to prevent cargo ships from spreading invasive species. Similar measures have already had been required by Canada and the U.S. Coast Guard, and evidence suggests that they have been ineffective at controlling the spread of invasive species.

On the Great Lakes System, Minnesota and Michigan set up their own discharge permit programs before the EPA completed its VGP. The other Great Lakes states, except Wisconsin, added their own specifications to the EPA rules. Wisconsin state water officials adopted the VGP without amendments.

Caltha LLP assists wastewater dischargers to obtain NPDES permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
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Wednesday, March 4, 2009

RIDEM Air Emission Caps - Proposed Amendments

The Rhode Island Department of Environmental Management (DEM) recently proposed to amend Air Pollution Control Regulation No. 29, which regulates the requirements to obtain "Operating Permits".

APC Regulation No. 29 requires that all major sources subject to the regulation obtain an operating permit. However, the regulation does contain certain provisions to allow sources to apply for an emissions cap if they meet certain criteria. An emissions cap must be federally enforceable and include some combination of production and/or operational limitations to ensure that emissions are limited by quantifiable and enforceable means. An emissions cap relieves the stationary source from having to obtain an operating permit.

The current regulation states that emission caps are issued for a term not to exceed 5 years. DEM proposes to amend these conditions so that emission caps will no longer expire and that sources will not be required to renew their emission cap. Emission caps would remain in effect unless they were terminated by DEM. Sources with emission caps will continue to pay an annual compliance/assurance fee.

The public comment period for these amendments ends March 23, 2009.

For further information contact Caltha LLP at
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WIsconsin Runoff Performance Standards - Proposed NR 151

The Wisconsin Department of Natural Resources (WDNR) is currently in the process of making revisions to Wisconsin Rule NR 151. NR 151establishes runoff pollution performance standards for non−agricultural facilities and transportation facilities and performance standards and prohibitions for agricultural facilities and practices designed to achieve water quality standards.

[Read on proposed changes to WDNR amendments to stormwater runoff rules]


For further information contact Caltha LLP at
info@calthacompany.com
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Tuesday, March 3, 2009

Minnesota Water Quality Rules - Amendments To 7050 and 7052

The Minnesota Pollution Control Agency (MPCA) is requesting comments on its planned amendments to rules governing state water quality standards found in Minnesota Rules Chapters. 7050 and 7052.

Chapter 7050 includes provisions to protect Minnesota’s waters from pollution – including classification system for both surface and ground waters, listing of specifically classified water bodies, water quality standards, nondegradation (antidegradation) provisions, and methods for the determination of site-specific criteria.

Chapter 7052 provides standards specific to surface waters of the state in the Lake Superior Basin - establishes aquatic life, human health, and wildlife water quality standards and criteria for Great Lakes Initiative pollutants, nondegradation standards, and implementation procedures for deriving effluent limitations from these standards and criteria.


The Federal Clean Water Act (CWA) requires States to review their water quality standards every three years (“Triennial Review”) and to amend and update them if necessary. The MPCA initiated this triennial review by seeking comments in a Request for Comments published in the July 28, 2008, State Register.

[Read more about proposed MPCA amendments to Water Quality Standards in Minnesota]

For further information contact Caltha LLP at
info@calthacompany.com
or

Caltha LLP Website



Sunday, March 1, 2009

CHMM Overview Course - Environmental Health and Safety Overview - Minneapolis, MN

CHMM Overview Course for the Institute of Hazardous Material Managers (IHMM) Examination
April 22 – April 24, 2009
Bloomington, Minnesota

The North Star Chapter of the Academy of Certified Hazardous Materials Managers presents this CHMM Overview Workshop. The Regulatory / CHMM Overview Workshop provides a comprehensive overview of the major environmental, health & safety topics. The course is intended to prepare students to take the IHMM Exam, although it also provides a valuable overview of EHS topics for individuals who do not intend to become Certified Hazardous Material Managers (CHMM).

Course topics include:
  • Federal Environmental Statutes Overview
  • Environmental Liability and Compliance Overview
  • Clean Water Act (CWA)
  • Clean Air Act (CAA)
  • Toxic Substances Control Act (TSCA)
  • Comprehensive Environmental,Response, Compensation and Liability Act (CERCLA)
  • Emergency Preparedness and Community Right-to-Know Act (SARA Title III - EPCRA)
  • Chemistry of Hazardous Materials
  • Toxicology Overview
  • Geology Overview
  • Radiation Principles for Hazardous Materials Managers
  • Asbestos Overview
  • Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
  • Hazardous Materials Transportation
  • OSHA Regulatory Overview
  • Incident/Accident Response Overview
  • Environmental Management Systems
  • Environmental Considerations in Real Estate/ Due Diligence Assessments
  • Underground Storage Tanks
  • Resource Conservation & Recovery Act (RCRA)
  • Waste Analysis Overview
  • Hazardous Waste Treatment Technologies
  • Waste Reduction/Minimization and Pollution Prevention
  • Environmental Compliance Audits and Auditing
  • Motivation of Employees with Respect to Environmental Matters
The full brochure for this workshop is available in .pdf format. Registration is also available online at the ACHMM-NSC web site: http://www.achmm-nsc.org/course.htm


Caltha LLP is pleased to support the North Star Chapter in presenting this valuable training course by providing volunteer instructors.

For further information contact Caltha LLP at
info@calthacompany.com
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Caltha LLP Website