Wednesday, January 31, 2018

Who Is Responsible For Leaking Transformer?

Electric transformers are found at almost every larger commercial, institutional and industrial facility. Sometimes this equipment is owned by the facility owner and sometimes by the power company. For some facilities, it is not always clearly understood who owns and is responsible for transformers.

Can Electric Transformers Leak Oil?

Yes, electric transformers can leak oil, but only if they actually contain oil.

How Can I Tell If Electric Transformer Contains Oil?

For newer transformers, the quantity of oil in the unit is usually found on the label. For older equipment, this information may not be on the label, or the label may have been removed or is illegible. In this case, a visual inspection of the equipment by a knowledgeable person can usually determine if it contains oil or not.     Not sure?   Send Caltha a photo and we may be able to determine this - send to

Who Is Responsible To Clean Up Leaks From Transformers?

This will depend on State laws. In general, the Owner of the equipment is responsible. However, for a property owner whose property has been impacted by a leaking transformer, the issue could affect the value of the property and they may voluntarily elect to clean up leaks.

What Are The Environmental Risks For Electric Transformers?

A risk for oil spills exists for any oil-filled transformer. Older transformers commonly contained PCB oils. Use of PCB oils has been phased out and newer equipment is often labeled "No PBC"; however older electric transformers could still contain PCBs which makes clean up more involved.

Leaks can occur over long periods and accumulate slowly. The other risk is an emergency spill caused by a fire or the transformer being damaged by vehicles, etc. These risks are minimized by ensuring equipment is included in pollution prevention plans and spill plans (such as SWPPP, SPCC Plan or other spill plans) and is regularly inspected and maintained.

Typical Leaking Electric Transformer

Tuesday, January 30, 2018

Once In Always In Policy Withdrawn By US EPA

On January 25, 2018, EPA announced it is withdrawing the “Once In, Always In” (OIAI) policy under the Clean Air Act. New EPA guidance allows stationary sources of hazardous air pollutants (HAPs) that are classified as “major sources” to limit their HAP emissions to below major source thresholds and thereby be reclassified as “area” sources at any time. In the past, major sources of HAPs remained subject to major source requirements, even if they took steps to reduce their potential to emit, or PTE, below major source thresholds.

 Area sources are subject to less onerous emission requirements than are major sources. The withdrawal of the OIAI Policy is effective immediately.


Click here to review EPA memo on Once In Always In policy

Sunday, January 28, 2018

Who Needs An EPA ID Number?

Federal regulations require large and small quantity generators of hazardous waste to obtain an EPA Identification (EPA ID) number using EPA Form 8700-12 and to submit the completed form to the authorized state agency or EPA regional office if the state is not authorized to implement the Resource Conservation and Recovery Act Subtitle C program. The Site Identification Form (EPA Form 8700-12) includes information such as:
  • Facility’s name and address,
  • Contact information,
  • A description of hazardous waste activities conducted at the site, and
  • Projected generator status, SQG or LQG.
Very small quantity generators of hazardous waste are not required by federal EPA to obtain an EPA ID number or submit a notification form, but may be subject to state-specific reporting requirements. In addition, in some areas local governments, such as Counties or Cities, may have licencing or permitting requirements.

Onsite Waste Disposal Observed During 
Phase 1 Environmental Assessment

Caltha LLP assists hazardous waste generators in applying for hazardous waste generator licence, developing hazardous waste management programs, providing employee hazardous waste training and waste reduction / waste minimization consulting.

Saturday, January 27, 2018

Who Needs A WDNR Solid Waste or Hazardous Waste Licence?

In Wisconsin, the Wisconsin Department of Natural Resources requires certain businesses that handle solid wastes, hazardous wastes, recyclable materials and other special wastes to have a licence issued by WDNR. This licence is in addition to any requirements to obtain an EPA facility ID, notify WDNR of hazardous waste activities, or to obtain a RCRA permit, if needed. Licences are required for 1) transporters and waste haulers, and 2) certain facilities.

Unlicensed Solid Waste Dump Identified 
During A Site Inspection

Waste Transporters/Haulers Licence

Businesses would need a waste transportation license if they:
  • transport more than 20 tons of solid waste during a year;
  • transport hazardous waste from businesses or institutions (non-households); or
  • transporting more than 50 pounds of infectious waste within any one calendar month.
Special requirements have been published for haulers of solid waste or recyclables, waste tire haulers, used oil transporters/handlers. Not all businesses need a state license to transport solid waste, recyclables, hazardous waste or infectious waste; solid waste/recyclable transportation license  and infectious waste transportation license exemptions are listed in DNR rules.

Facility Licence

A DNR license is required for a solid waste landfill. In most cases, a DNR license is required for a compost facility, processing facility, storage facility, woodburning facility, incinerator or transfer station. Facilities that treat, store or dispose of hazardous waste must be licensed by the DNR, unless the activity is specifically exempt from the licensing requirement.

Caltha LLP assists waste generators and handlers in Wisconsin in applying for hazardous waste generator licence, developing hazardous waste management programs, providing employee hazardous waste training and waste reduction / waste minimization consulting.

Thursday, January 25, 2018

Court Ruling On EPA Lead Paint Lead Dust Rules

On December 27, 2017, the US Court of Appeals ruled the Environmental Protection Agency must issue a proposed rule within 90 days to update lead-based paint and lead-dust hazard standards. The court also ruled that the EPA must promulgate the final rule within one year after the announcement of the proposed update.

Complaints were filed in August 2009 by multiple groups, including the Sierra Club and United Parents Against Lead National, urging the EPA to use its rule-making authority in order to more adequately protect children. Court filings requested lead-dust hazard levels to be lowered to 10 µg/ft2 for floors and 100 µg/ft2 for window sills and the standard for lead-based paint be lowered to 0.06% lead by weight. The EPA responded in October 2009 and agreed, however, since that date EPA has not provided specifics on the rule nor a date when the proposed rules would come into effect.

Sunday, January 21, 2018

Environmental Inspections, Phase 2 Investigation and Cleanup In Minnesota

Caltha LLP is a trusted environmental consulting and engineering firm serving Minnesota with Phase I and Phase II site assessments and remediation services. Caltha LLP maintains close ties with State and local agencies that oversee waste management and contaminated site cleanup, including Minnesota Pollution Control Agency and Hennepin, Ramsey, Anoka, Carver, Washington, Dakota and Scott County governments.

Leaking bulk fuel tank and fuel pump
discovered during Phase I ESA

Click here to review other example Caltha remediation projects. Click here to review other Caltha projects in Minnesota and MN regulatory updates.

Hazardous Waste Management Training In Minnesota

Minnesota-based Environmental, Health & Safety Trainer

Caltha LLP, a Minnesota headquartered EH&S training and consulting company, provides training to facility employees that is required to meet State and Federal regulations, and needed to ensure sustainability, safety and liability management goals are achieved.

Training is provided in a number of flexible formats, including in-person sessions at your site, web-based "live" training, and preparation of customized training modules used by your employees at their convenience.

We provide a wide range of training programs for facilities across Minnesota, including:
SWPPP training Annual SPCC training HazCom training
Safety data sheet training PPE training Hazardous waste training -LQG
Hazardous waste training -SQG Environmental awareness ISO 14001 Awareness
 ISO 18001 Awareness Universal waste training AWAIR training
HazMat DOT training Hazard Communication Workplace spill training

Improper Storage and Labeling of a Flammable Hazardous Waste 
Identified During Waste Audit 

Providing EH&S Training To Facilities Across Minnesota

Caltha provides training to facilities located in all parts of Minnesota and routinely leads training sessions in:
Minneapolis St. Paul Rochester Duluth Bloomington
Brooklyn Park Plymouth Woodbury Eagan Maple Grove
Coon Rapids Blaine Eden Prairie Burnsville Bemidji
St. Cloud Marshall Minnetonka Edina St. Louis Park
Moorhead Mankato Maplewood Shakopee Cottage Grove

Minnesota-based Consultant With MPCA, MnOSHA and Local Agency Knowledge

Caltha LLP maintains close ties with the key State and local agencies that oversee environmental and safety compliance programs,  including the Minnesota Pollution Control Agency, Minnesota OSHA, The Metropolitan Council, who regulates wastewater in the Minneapolis- Saint Paul area, and the seven Metro area Counties (Hennepin, Ramsey, Anoka, Washington, Dakota, Carver, Scott) who regulate hazardous wastes.

Click here for more information or to request a quote on Caltha's EHS training services, including Hazardous Waste and DOT Hazardous Material certification training for hazardous waste generators.

Saturday, January 20, 2018

EHS Compliance Audit In Manchester, NH

Caltha LLP Project Summary

Project: Environmental - Safety Compliance Audit
National Industrial Corporation
Manchester, New Hampshire

Key Elements: EH&S audit, LQG, hazardous waste treatment permit, air permit, hazardous material storage, wastewater permit, hazard communication, SPCC

Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this industrial facility located in New Hampshire. The scope of the audit included:
  • EPCRA hazardous chemical storage reporting
  • Hazardous waste management - Large Quantity Generator
  • Hazardous waste treatment permit
  • Current air pollution control permit
  • Current industrial wastewater discharge permit
  • TSCA
  • Tanks
  • Hazard communication
  • DOT Hazardous material transportation
  • Groundwater remediation permit
The audit was led by a IIA-certified professional auditor.

Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in New Hampshire and NH regulatory updates.

Thursday, January 11, 2018

Fees For Electronic And Paper Manifests

EPA finalized the e-Manifest User Fee Final Rule on December 20, 2017 and it was published in the Federal Register (FR) on January 3, 2018.

The final rule establishes the methodology that EPA will use in setting and revising user fees in order to recover the full costs of the electronic manifest system. This includes costs incurred in developing, operating, maintaining, and upgrading a national e-Manifest system, as well as any costs incurred in collecting and processing data from any paper manifest submitted to the e-Manifest system after the date on which the system begins to operate on June 30, 2018. The per-manifest fees for each manifest submission type are:

Manifest submission type Year 1 fee
Mailed Paper ............................................................................ $20.00
Image Uploads ........................................................................... 13.00
Data File Uploads ....................................................................... 7.00

Electronic ............................................................................... 4.00

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 or Caltha LLP Website