Revised Waste Management Rules for Renovation or Demolition Projects

The Minnesota Pollution Control Agency (MPCA) has finalized waste and material removal rules that apply to all renovation or demolition projects. According to the revised Rules, the following items and materials must be removed prior to the commencement of renovation or demolition:

A. items that would normally be disposed of as mixed municipal solid waste, such as furniture, carpeting, bedding, mattresses, clothing, small appliances, food, and food waste;
B. household hazardous waste including;
F. items that may contain elemental mercury:
G. items that may contain polychlorinated biphenyls (PCBs);
H. items that may contain chlorofluorocarbons (CFCs):
I. oils, including used oil, hydraulic oils, and oils located in heating oil tanks, piping, sumps, and traps;
J. lead-containing items, including lead-acid batteries, lead pipes, lead sheeting, lead flashing in roof vents, and lead paint that is not firmly adhered to the substrate; and
K. electronic products containing a cathode ray tube, including televisions and computers;

An exemption from this requirement exists for items or materials that are within components of the structure, such as elevators, vertical lifts, or lighting, that need to remain intact are being used during the course of renovation or demolition, provided that the items or materials are removed after use of the component is no longer required for renovation or demolition work.

If the owner, person authorizing renovation or demolition, or person conducting the renovation or demolition knows or has reason to know that portions of the structure may be contaminated by hazardous substances or petroleum based on past uses of the structure, such as a medical building, laboratory, or manufacturing facility, they must obtain appropriate samples and receive results from laboratory analysis as necessary to ensure the proper management and disposal of contaminated structural elements and any resulting debris generated.

Caltha LLP provides specialized expertise to clients nationwide in the pre-demolition surveys, developing waste handling procedures, and preparing cost-effective waste management programs.

For further information contact Caltha LLP at
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Definition of Waters of US - Proposed Revision

The "Clean Water Restoration Act", has been approved by the US Senate Senate Environment and Public Works Committee. The proposed law would clarify the scope of the Clean Water Act definition of "waters of the United States". Under the bill, waters of the US would be defined as including:

(A) all waters which are subject to the ebb and flow of the tide;
(B) all interstate waters, including interstate wetlands;
(C) all other waters, such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds;
(D) all impoundments of waters of the United States;
(E) tributaries of the aforementioned waters;
(F) the territorial seas; and
(G) wetlands adjacent to the aforementioned waters;

The draft bill specifically excludes groundwaters from the definition of waters subject to the Clean Water Act.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation of environmental, health & safety rules, developing cost effective compliance procedures, and management programs.

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US EPA Extends SPCC Rule Deadline

Facilities subject to Spill Prevention, Control & Countermeasure (SPCC) requirements have more time to amend their programs. On June 11, 2009, EPA again extended the compliance date for compliance with the federal "SPCC Rule". Facilities subject to the SPCC Rule now have until to November 10, 2010 to come into either amend their existing SPCC Plan or prepare an inital Plan, if they are newly subject to the Rule.

Facilities must amend or prepare, and implement SPCC Plans by the compliance date in accordance with revisions to the SPCC rule promulgated since 2002. Farms that are also subject to the Rule must also amend or prepare their SPCC Plans, and implement those Plans by the same date.

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

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