RCRA and Universal Waste Annual Training For Minnesota Waste Generator

Caltha LLP Project Summary

Project: RCRA Hazardous Waste Generator and Universal Waste Generator Training
Client: International Chemical Products Manufacturer
Location(s): Minnesota

Key Elements: RCRA training, Universal waste training

Overview: Caltha prepared and presented training to facility staff and to on-site contractors who were responsible for generation of hazardous wastes and universal wastes at this site located in Minneapolis, Minnesota. Training was conducted to comply with Federal, state and county hazard waste rules, including:
40 CFR Part 260-262 – Hazardous Waste Management
40 CFR Part 273 – Standards for the Management of Universal Wastes
40 CFR Part 279 – Standards for the Management of Used Oil
Minnesota Rules Chapter 7045: Hazardous Waste Rules
Minnesota Rules Chapter 7035: Solid Waste

Training was provided at the facility and included a summary of regulatory requirements, and site-specific procedures for handling wastes generated at the site. Training also including a summary of the site Contingency Plan, spill prevention and related emergency preparedness and response procedures.



For more information on Caltha LLP EH&S training services, go to the Caltha Employer's EH&S Training Center.



Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Regulatory Compliance Audit and Due Diligence For Minnesota and North Dakota Food Manufacturing Plants

Caltha LLP Project Summary

Project: Compliance Audit and Environmental Due Diligence For Minnesota and North Dakota Food Manufacturing Plants
Client: International Food Manufacturing Industry
Location(s): Minnesota and North Dakota

Key Elements: Environmental Compliance Audit, Phase 1 Environmental Site Assessment

Overview: Caltha was retained by this multinational food manufacturer to conduct an environmental regulatory compliance audit and a Phase I ESA at two of its plants located near Minneapolis, Minnesota and near Bismarck, North Dakota. Compliance audits were conducted to assess compliance with EPA, Minnesota Pollution Control Agency (MPCA), and Hennepin County requirements in Minnesota, and EPA and North Dakota Department of Health (NDDH) requirements in North Dakota. Regulatory requirements evaluated included:

• Clean Air Act,
• Clean Water Act,
• RCRA hazardous waste and solid waste requirements,
• Emergency Preparedness and Community Right-to-know Act (EPCRA) requirements,
• Toxic Substance Control Act,
• Above and underground tank requirements,
• OSHA Hazard Communication.

Caltha also completed a Phase I Environmental Site Assessment (ESA) for both sites, in accordance with ASTM E1527-05.



For more information on Caltha LLP services, go to the Caltha Audit Page

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

RCRA and TSCA Compliance Audit For Multiple Facilities To Meet ISO 14001 Requirements

Caltha LLP Project Summary

Project: Combined RCRA and TSCA PCB Management Audit For 26 Facilities
Client: Electric Utility
Location(s): 26 locations

Key Elements: RCRA hazardous waste audit, TSCA PCB management, Used oil management, Universal waste management, ISO 14001

Overview: Caltha was retained to conduct a compliance audit of 26 facilities to assess compliance with:

• EPA hazardous waste rules (40 CFR Part 260-262)
• Minnesota hazardous waste rules (MPCA Chapter 7045)
• North Dakota hazardous waste rules
• Federal and State requirements for used oil management (40 CFR Part 279)
• Federal and State requirements for universal waste management (40 CFR Part 273)
• EPA Toxic Substances Control Act (TSCA) requirements for PBC management (40 CFR Part 261)

Audits were conducted to satisfy ISO 14001 standards for scheduled audits, under ISO 14001 clause 4.5.2.1. Audits were completed with a combination of records review and on-site inspections.



For more information on Caltha LLP auditing services, go to the Caltha Compliance and EMS SMS Audit Page



Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Air Permit Compliance Assessment and Option D Registration Permit Source Review

Caltha LLP Project Summary

Project: Air Permit Compliance Audit and Registration Permit Tracking Review

Client: International Beverage and Food Product Company

Location(s): Minnesota

Key Elements: Air Emission Reporting Review, Air Emission Inventory, Permit Compliance Assessment

Overview: This facility retained Caltha to conduct a review of air permit compliance with the MPCA Option D Registration Permit. The review was prompted by recent staff turn-over at the facility and an impeding multi-media audit being conducted by the corporate group. Facility management wanted to assure that all applicable air emission sources were permitted, emission tracking systems were accurate and complete, and that new staff responsible for on-going permit compliance activities were provided with ”on-the-job” training .

Caltha staff conducted on on-site inspection of the facility to identify all equipment and processes which were subject to air emission permitting. Emission tracking records and calculation spreadsheets were reviewed to confirm that all applicable emission sources were included and that calculations were accurate. Some revisions to spreadsheets were required. Caltha staff then provided training to facility staff on new tracking procedures.

For more information on Caltha LLP services, go to the Caltha Contact Page

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Preparation Of Response To Request For Information From EPA Regarding NESHAP Compliance

Caltha LLP Project Summary

Project: Preparation of Technical Response To EPA Region V Request For Information
Client: Foam manufacturer
Location(s): Wisconsin

Key Elements: Air emission, NESHAP, Subpart OOOOOO

Overview: Caltha was retained by this manufacturer to contact State and EPA air compliance personnel and to prepare a response to a Request For Information sent by US EPA Region V. The issue involved compliance with a specific National Emission Standards for Hazardous Air Pollutants (NESHAP). EPA believed that the facility may have been subject to 40 CFR 63, Subpart OOOOO (6O) - Flexible Polyurethane Foam Production & Fabrication Area Sources. After reviewing site operations, it was determined that the facility was not subject to 6O. Documentation was prepared and submitted to EPA and the State. No further actions were required by the facility.

For more information on Caltha LLP services, go to the Caltha Contact Page
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Environmental Compliance Audit For Iowa Food Ingredient Manufacturer

Caltha LLP Project Summary

Project: EHS Compliance Audit For Iowa Food Ingredient Manufacturer
Client: Food Ingredient Manufacturer
Location(s): Iowa

Key Elements: Multi-media Compliance Audit

Overview:

Caltha was retained by this food ingredient manufacturer to conduct a multi-media compliance audit of its operations located in northwest Iowa. The operations were self certified as being in conformance with the Environmental Management System (EMS) requirements specified under ISO 14001. The audit was being conducted in advance of a planned merger and was required by the prospective business partner.

The scope of the compliance audit included applicable Federal, State and local regulations:

OSHA	Hazard Communication
EPCRA	EPCRA 311-312 EPCRA 313
Hazardous and Solid Waste Management	Federal RCRA rules
	Iowa waste rules
	Universal waste rules
Air	Federal air emission rules
	Federal NESHAP standards
	Iowa air emission permit
	Iowa air emission rules
Clean Water Act	Authorized/Unauthorized Discharges
	Iowa Stormwater Discharge Permit compliance
	SPCC Rule Compliance
	Iowa Spill Notification and Reporting
	Federal Industrial pretreatment rules
	Local Industrial discharger permit compliance
TSCA	Current registration
	Inventory Update Rule IUR Reporting
	Chemical Data Rule CDR Reporting
Tanks	Iowa aboveground tank rules
	Iowa underground tank rules

The audit was completed under attorney client privilege through external legal counsel.



For more information on Caltha LLP services, go to the Caltha Contact Page

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
 For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website