Saturday, September 30, 2017

Metal Plating Operation Required To Have Total Organic Spill Plan

Caltha LLP Project Summary

Project: Total Toxic Organics Management Plan For Metal Finisher
Client: Metal Finishing Company
Location(s): Minnesota

Key Elements: Total Toxic Organics Management Plan, SPCC Plan

Overview: This metal finishing was subject to Categorical Effluent Guidelines. In lieu of monitoring wastewater discharges for the full list of “Total Toxic Organics” the facility opted to prepare and implement a Total Toxic Organic Management Plan (TTOMP) for the site. Caltha was contracted to prepare the TTOMP for the facility. The TTOMP included:
• Inventory and description of TTO compounds used in the electroplating or finishing processes, and degreasing processes;
• Inventory and description of regulated processes where TTO compounds are used;
• Description of disposal methods for materials and wastes that contain TTO compounds;
• Description of controls used to limit or eliminate the discharge of TTO compounds to the sanitary sewer.

The TTOMP was combined with a Facility Spill Plan which included processes and containers not specifically addressed under the Effluent Guidelines. Caltha prepared a spill control plan for the site to minimize and control spills from areas where liquids are stored, transferred and used. The spill plan included:
1. Inventory and description of chemical storage and process tanks;
2. Description of batch discharges to sanitary sewer;
3. Description of controls and procedures to prevent entry of chemicals and other restricted materials and wastes from entering the sanitary sewer;
4. Emergency notification procedures;

Click here for more information on Caltha LLP Spill Prevention and Response Plan Services and SPCC Support Services.

TSCA Compliance Expert Technical Support For NJ Chemical Company

Caltha LLP Project Summary

Project: TSCA Certification Support
Chemical Distributor 
New Jersey

Key Elements: TCSA Import Certification, TSCA reporting, Hazardous Material Storage, Hazardous Material Transportation

Overview: Caltha LLP has provided on-going ad hoc technical support to this chemical importer and distribution company. Services are provided on an "as needed" basis and include review of product SDS, chemical storage requirements, and TSCA import certifications (positive certification, negative certification).

Click here for more information on Caltha LLP TSCA Compliance services.

Monday, September 25, 2017

TCEQ Issues Revised General Operating Permits

The Texas Commission on Environmental Quality (TCEQ) has issued revisions to Oil and Gas General Operating Permits (GOP) 511 and 514. The revisions were needed to address the applicability status of Wise County. Sites in Wise County are now covered under GOP 511 instead of GOP 514. The revised GOPs were proposed on January 27, 2017, and the public comment period closed on February 27, 2017.

Current permit holders are required to submit an application for a new authorization to operate (ATO) no later than October 12, 2017, if any of the emission units, applicability determinations, or the basis for the applicability determinations are affected by the revisions in the renewed GOPs. If the revisions in the GOPs do not affect a site, a new ATO is not required.

For more information on Caltha LLP air permitting services in Texas, go to
Caltha Permitting And Compliance Support

New Jersey General Permit For Emergency Generators Revised

The New Jersey Department of Environmental Protection (NJDEP) Air Quality Permitting Program has revised the Emergency Generator General Permit (GP-005) used by many facilities.

Permit GP-005 was revise to incorporate the requirements of revised New Jersey Administrative Code 7:27-19, Control and Prohibition of Air pollution by Oxides of Nitrogen,  and to  incorporate the United States Environmental Protection Agency proposed New Source Performance (NSPS) requirements for Emergency Generators outlined at 40 CFR 60.4207 Subpart IIII.

The revised general permit will now allow a facility to combine all applicable emergency generators at the facility into one single registration in most situations.

For more information on Caltha LLP services related to air permitting, go to:
Caltha Permitting & Compliance Page