Overview of Management Systems Used By EHS Professionals

Overview of Management Systems For EHS Professionals

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Wastewater Permit And Compliance Overview

Overview of Clean Water Act 



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Overview of the Clean Water Act and underlying programs. Clean Water Act; CWA; wastewater; NPDES; pretreatment permit; water quality standards; permit limits; effluent guidelines; effluent standards; waters of the US, water quality criteria, SPCC rule

Air Permit Engineer For Wisconsin Printing Business

Caltha LLP Project Summary

Project: Update To Air Permit Emission Tracking And Reporting
Client: Printing Operation
Location(s): Wisconsin

Key Elements: WDNR air permit, annual air emission inventory, VOC emission calculation

Overview: Caltha LLP has assisted this Wisconsin printing company with annual air emission inventory used for compliance reporting under the facility air emission permit issued by the Wisconsin Department of Natural Resources. This has included preparation of a site specific product usage and emission tracking workbook used by plant personnel to record monthly solvent usage and the resulting VOC emissions.

Caltha provides ad hoc training and technical support to plant staff on emission tracking and permit compliance.


Spray Booth Included In Facility
Wide Air Emission Permit

 

Caltha LLP | Your Air Permit, Wastewater Permit, 

Storm Water Permit Partner

Is Hazardous Waste Allowed In City Sewer?

FAQ: Is It Legal To Discharge Hazardous Waste Into Sewer?

Possibly, if certain conditions are met.

The Clean Water Act (CWA) Pretreatment Program regulations require that Industrial Users (IUs) report any substance discharged to the Publicly Owned Treatment Works (POTW) which, if otherwise disposed of, would be considered a Resource Conservation and Recovery Act (RCRA) hazardous waste. Under RCRA’s Domestic Sewage Exclusion (DSE), any mixture of domestic sewage and other wastes that passes through a sewer system to a POTW is not considered a hazardous waste for the purposes of RCRA.

However, reporting of such discharges are regulated under the CWA as follows:

• 40 CFR 403.12(p) requires a one-time report for each substance discharged to a POTW that, if otherwise disposed of, would be considered RCRA hazardous waste.
• 40 CFR 403.12(j) requires a report in advance of any substantial change in volume or character of any IU discharge.

Who Must Submit Notification of Hazardous Waste Discharge?

All IUs that discharge a substance that, if otherwise disposed of, would be characteristic or listed wastes under 40 CFR Part 261 and meet the following criteria:

• Total waste discharged is greater than or equal to 15 kg/month; or
• Waste discharged is acute hazardous waste.

Where Does Notification Need To Be Sent?

If notification of hazardous waste discharge is required, it needs to be submitted to:

1. Local Sewerage Authority(i.e., POTW)
2. EPA Regional Waste Management Director, and
3. State Hazardous Waste Authority

What Does Notification Need To Include?

The notification must contain:

For hazardous wastes ≥ 15 kg/month or any quantity of acute, the one-time notification from an IU to a POTW must contain:

1. Name of the hazardous waste as set forth in 40 CFR Part 261.
2. EPA hazardous waste number (code).
3. Type of discharge to the sewer (continuous, batch, or other).
4. A certification that the IU has a program in place to reduce the volume and toxicity of hazardous wastes generated to the degree it has determined to be economically practical.

If the IU discharges more than 100 kg of acute or non-acute hazardous waste per calendar month to the POTW, the notification must also contain the following items of information, to the extent such information is known and available:

• An identification of the hazardous constituents contained in the hazardous wastes.
• An estimation of the mass and concentration of such constituents in the waste stream discharged during the calendar month in which the one-time report is made.
• An estimation of the mass of constituents in the wastestream expected to be discharged during the 12 months following the notification.

Common Questions Regarding Notification Of Hazardous Waste Discharge To City Sewer

 

Caltha LLP | Your Air Permit, Wastewater Permit, 

Storm Water Permit Partner

Can I Throw Empty Pesticide Spray Cans In Trash?

How Are Spent Aerosols Containing Pesticides Regulated?

Hazardous waste aerosol cans that contain pesticides are also subject to the requirements of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), including compliance with the instructions on the label. In general, the statement on aerosol pesticide product FIFRA labels prohibits the puncturing of the cans. However, in April 2004, EPA issued a determination that puncturing aerosol pesticide containers is consistent with the purposes of FIFRA and is therefore lawful pursuant to FIFRA section 2(ee)(6) provided that the following conditions are met:

• The puncturing of the container is performed by a person who, as a general part of his or her profession, performs recycling and/or disposal activities;
• The puncturing is conducted using a device specifically designed to safely puncture aerosol cans and effectively contain the residual contents and any emissions thereof; and
• The puncturing, waste collection, and disposal, are conducted in compliance with all applicable federal, state and local waste (solid and hazardous waste) and occupational safety and health laws and regulations.

EPA anticipates that this 2004 FIFRA determination would not be affected by the proposed addition of hazardous waste aerosol cans to the universal waste rules.

Used Aerosol Cans Could Be Universal Waste Under Proposed Rule

EPA is proposing to add hazardous waste aerosol cans to those “universal wastes” regulated under title 40 of the Code of Federal Regulations (CFR), part 273. This change in the Resource Conservation and Recovery Act (RCRA) regulations, once finalized, will reduce regulatory costs of a wide variety of establishments generating and managing aerosol cans, including the retail sector, by providing a clear, practical system for handling discarded aerosol cans.

How Is Aerosol Can Disposal Currently Regulated?

Aerosol cans frequently contain flammable propellants such as propane or butane which can cause the aerosol can to demonstrate the hazardous characteristic for ignitability. In addition, the aerosol can may also be a hazardous waste if they contain materials that exhibit hazardous characteristics. Similarly, a discarded aerosol can may also be a P or U-listed hazardous waste if it contains a commercial chemical product. Therefore, fir several reasons, spent aerosol cans could be a regulated hazardous waste.



Waste Audit Finds Improper Flammable Waste Storage And Labeling

How Are Spent Aerosols Containing Pesticides Regulated?

Hazardous waste aerosol cans that contain pesticides are also subject to the requirements of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), including compliance with the instructions on the label. In general, the statement on aerosol pesticide product FIFRA labels prohibits the puncturing of the cans. However, in April 2004, EPA issued a determination that puncturing aerosol pesticide containers is consistent with the purposes of FIFRA and is therefore lawful pursuant to FIFRA section 2(ee)(6) provided that the following conditions are met:

• The puncturing of the container is performed by a person who, as a general part of his or her profession, performs recycling and/or disposal activities;
• The puncturing is conducted using a device specifically designed to safely puncture aerosol cans and effectively contain the residual contents and any emissions thereof; and
• The puncturing, waste collection, and disposal, are conducted in compliance with all applicable federal, state and local waste (solid and hazardous waste) and occupational safety and health laws and regulations.

EPA anticipates that this 2004 FIFRA determination would not be affected by the proposed addition of hazardous waste aerosol cans to the universal waste rules.

Does The Proposed Rule On Aerosol Can Disposal Affect State Rules?

If approved, States with approved RCRA programs would need to made revisions to State rules.

Four states, California, Colorado, Utah and New Mexico, already have universal waste aerosol can programs in place, and two more states, Ohio and Minnesota, have proposed to add aerosol cans to their universal waste regulations.



Spent Aerosol Cans Being Handled As Universal Waste

Are Any Containers Excluded From the Proposed Rule?

EPA intends the rule to be limited to sealed containers whose intended use is to dispense a material by means of a propellant or compressed gas.  Other types of containers, including compressed gas canisters and propane cylinders, present a greater risk than aerosol cans and would not be included.

EPA specifically excludes aerosol cans that have been emptied of their contents (both propellant and product). Once the contents of a universal waste aerosol can have been removed, the emptied can is considered a new point of generation and is subject to a hazardous waste determination.. An aerosol can that meets the definition of empty container is not subject to hazardous waste regulation, and may be recycled as scrap metal.

The proposed rule also excludes aerosol cans that show evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. Through this exclusion, EPA intends that hazardous waste aerosol cans that are not intact continue to be subject to the full hazardous waste standards.


Aerosol Cans Being Stored For Disposal or Recycling

What Handling Requirements Are Proposed?

Under this proposed rule, the existing universal waste requirements currently applicable to small quantity handlers of universal waste (SQHUWs) and large quantity handlers of universal waste (LQHUWs) would also be applicable to handlers of discarded aerosol cans. For both SQHUWs and LQHUWs, these requirements include:

• waste management standards,
• labeling and marking,
• accumulation time limits,
• employee training,
• response to releases,
• requirements related to off-site shipments, and
• export requirements.

For the labeling requirement, EPA is proposing that either each aerosol can, or a container in which the aerosol cans are contained, must be labeled or marked clearly with any of the following phrases: “Universal Waste—Aerosol Can(s),” “Waste Aerosol Can(s)”, or “Used Aerosol Can(s)”.

In addition, EPA is proposing that small and large quantity universal waste handlers must follow certain specific management standards while handling their aerosol cans. Under this proposal, all handlers must manage their universal waste aerosol cans in a manner designed to prevent releases to the environment. This includes accumulating universal waste aerosol cans in containers that are structurally sound and compatible with the contents of the can, and show no evidence of leaks, spills, or damage that could cause leaks under reasonably foreseeable conditions. Handlers may sort aerosol cans by type and consolidate intact aerosol cans in larger containers, remove actuators to reduce the risk of accidental release, and under certain conditions, may puncture and drain aerosol cans that are being recycled..

Future of Aerosol Can Puncturing Under Proposed EPA Rule

 

Caltha LLP | Your EH&S Compliance, Auditing and EMS/SMS Partner

Information Collection Request For Recycled Hazardous Secondary Materials

EPA has proposed an extension of an “information collection request,” or ICR, regarding recordkeeping related to the recycling of hazardous secondary materials. The specific requirements affected by the ICR request include shipping records and receipts, financial assurance requirements, personnel training, labeling storage containers, and emergency preparedness and response conditions. These information requests were set to expire in April of this year. The information requirements proposed for extension impact generators, verified recyclers, contractors, and others involved in shipping, transporting, and recycling hazardous secondary materials under the exclusions added in the 2015 Final Rule. These exclusions are found at 40 CFR 261.4(a)(23), (24), and (27), and the revised speculative accumulation requirement at 40 CFR 261.1(c)(8).

EPA is soliciting comments and information  to:

• Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency;
• evaluate the accuracy of the Agency's estimate of the burden of the proposed collection of information;
• enhance the quality, utility, and clarity of the information to be collected; and
• minimize the burden of the collection of information on those who are to respond.

EPA will consider comments received and amend the ICR as appropriate, and final ICR package will then be submitted to OMB for review and approval. At that time, the EPA will issue another Federal Register notice to announce the submission of the ICR to OMB and the opportunity to submit additional comments to OMB.The comment period would end April, 27, 2018.

This action would extend paperwork requirements that originate from a January 2015 Final Rule that revised EPA’s Definition of Solid Waste to exclude certain hazardous secondary materials from regulation under RCRA. In addition to new exclusions, the Final Rule added recordkeeping rules EPA says ensure regulated entities meet their responsibilities and help inspectors verify compliance.



Flammable Hazardous Waste Storage

Background On Definition Of Solid Waste Rule

In 2015 the EPA published final revisions to the definition of solid waste that exclude certain hazardous secondary materials from regulation (80 FR 1694, January 13, 2015). The information requirements help ensure that (1) entities operating under the regulatory exclusions are held accountable to the applicable requirements; (2) state inspectors can verify compliance with the restrictions and conditions of the exclusions when needed; and (3) hazardous secondary materials exported for recycling are actually handled as commodities abroad.

Paperwork requirements finalized in that rule include:

• Under the generator-controlled exclusion at 40 CFR 261.4(a)(23), the tolling contractor has to maintain at its facility for no less than three years records of hazardous secondary materials received pursuant to its written contract with the tolling manufacturer, and the tolling manufacturer must maintain at its facility for no less than three years records of hazardous secondary materials shipped pursuant to its written contract with the tolling contractor. In addition, facilities performing the recycling of hazardous secondary materials under the generator-controlled exclusions at 40 CFR 261.4(a)(23) to maintain documentation of their legitimacy determination onsite.
• Under the verified recycler exclusion at 40 CFR 261.4(a)(24), a verified hazardous secondary materials recycler or an intermediate facility who has obtained a solid waste variance must meet the following conditions: Having financial assurance in place, having trained personnel, and meeting emergency preparedness and response conditions.
  Under the remanufacturing exclusion at 40 CFR 261.4(a)(27), both the hazardous secondary material generator and the remanufacturer must maintain records of shipments and confirmations of receipts for a period of three years from the dates of the shipments.
• Under the revised speculative accumulation requirement in 261.1(c)(8), all persons subject to the speculative accumulation requirements must label the storage unit by indicating the first date that the material began to be accumulated.

 

Caltha LLP | Your EH&S Compliance, 

Auditing and EMS/SMS Partner

Is A Gap Analysis Required Under ISO?

For many organizations considering developing a formal Environmental Management System (EMS) or Safety Management System (SMS) or becoming registered under ISO 14001 or now ISO 45001, two questions asked early on are:

1. What will it cost? and,
2. How long will it take?

To answer these questions, many organizations will conduct a quick assessment of their current status, called a Gap Analysis. The Gap Analysis is a low cost assessment which can usually be completed in one to two days. The Gap Analysis produces an inventory of existing programs which could be used in developing the EMS/SMS. The Gap Analysis evaluates these programs to determine if changes will need to be made, and to what extent, in order to conform to the ISO 14001 or ISO 45001 standard.



Flammable Liquid and Ignitable Hazardous Waste Storage Room



The Gap Analysis is typically formatted as a checklist of questions addressing the various elements of the ISO 14001 / 45001 standard. Based on the results of the Gap Analysis, the organization will understand the areas where improvement will need to be made, and can then do basic resource planning to determine the optimum strategy to move forward, including cost and schedule.


Hazardous Waste Storage Drum In Flammable Cabinet



Caltha LLP provides expert technical support to organizations wanting to improve their EMS or SMS or to become registered under ISO 14001 or ISO 45001. One of Caltha’s key services is help organizations conduct their Gap Analysis and resource planning. For more information go to ISO 14001 and Environmental and Safety Management Systems Services page.

 

Caltha LLP | Your EH&S Compliance, 

Auditing and EMS/SMS Partner

Maintenance of Legal And Other Requirements List For Pennsylvania Facility

Caltha LLP Project Summary

Project: Update and Maintenance of Legal and Other Requirements Listing
Client: International Steel Manufacturer
Location(s): Pennsylvania

Key Elements: Review of regulatory requirements, preparation of ISO 14001 documentation of legal and other requirements

Overview:  Caltha was contracted by the client to provide technical support to maintain their listing of "Legal and Other Requirements" which was prepared to conform to ISO 14001 Clause 4.3.2. An environmental management system that conforms to ISO 14001 must include a procedure to identify legal and other requirements that the organization believes are applicable to its operations. The organization also needs to have a system to be able to access the current version of these requirements.

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Hazardous Waste Storage Drum In
Flammable Cabinet


The list of requirements is also essential for complying with other Clauses of the standard. This list becomes the scope of scheduled compliance audits the organization must perform. Caltha provided a technical update to the organization's existing listing of requirements, which included several new regulations that had been recently promulgated on both the Federal and State level.

The most recent update included important changes to the hazardous waste management requirements and Pennsylvania stormwater permit requirements, included in:

• Hazardous Waste Generators Improvement Rule,
• Solvent Contaminated Wipe Management Rule,
• 2016 Revised PDEP Industrial Stormwater Requirements.

Flammable Liquid and Ignitable Hazardous Waste
Storage Room



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

 

Caltha LLP | Your EH&S Compliance, 

Auditing and EMS/SMS Partner