Corporate HSE Department Needed Site Remediation Oversight Support

Caltha LLP Project Summary

Project: Corporate HSE Staffing-Site Remediation Oversight
Client: Multi-national Chemical Company
Location(s): California, Illinois, Indiana, Minnesota, North Carolina, Ontario, Canada, Michigan, Kentucky, Arizona


Key Elements: Environmental Health & Safety Staffing, Site remediation


Overview: This chemical company contracted with Caltha to provide temporary staffing in its corporate HSE Department for the position that oversaw numerous site remediation projects being conducted across the US and Canada. Due to staff turnover the position needed to be filled quickly to assure that process on projects continued, on-site contractors had questions and issues addressed, and that required agency submittals were reviewed, approved and submitted on time. Caltha provided a highly experienced HSE professional to fill the position until the corporation could hire a permanent replacement. Caltha staff were then able to provide transitional support.


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

Certified Environmental Health and Safety Audit Services

Caltha LLP provides IAA-BEAC certified auditors to perform internal EH&S audits to support ISO 14001 registered organizations or to support routine internal audit programs implemented as part of an overall governance system. Caltha can provide:

• Single auditors to support audit teams as a media or regulatory expert,
• Audit teams to address multiple program areas, or
• Due diligence auditors / audit teams.

Caltha auditors can act as adjunct auditors to augment your existing internal audit team, or can act as an independent third party auditor.


Caltha auditors have conducted assessments in all 50 US States, Canada, Mexico, South America, Europe and Asia.


Click here for more information on Caltha Compliance Audit, Management System Audit and Due Diligence Assessment services

Chicago Multimedia Compliance Audit For Manufacturing Plant

Caltha LLP Project Summary

Project: HSE Compliance Audit
Client: High Tech Manufacturer
Location(s): Chicago, Illinois

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, PPE assessment, hazard communication


Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this manufacturing facility located in Cook County. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management
• Current IEPA Air Permit
• Cook County Air Emission Ordinance
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

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

Initial Liquid Special Waste Report Due To Cook County

The first Liquid Special Waste Report under the new Cook County Liquid Hazardous Waste Ordinance is due September 1, 2016 which covers the first half of calendar year 2016.


The Cook County Liquid Hazardous Waste Ordinance requires facilities in suburban Cook County to report their annual liquid hazardous waste generation and submit the corresponding fee to the Cook County Department of Environmental Control. 


Facilities will need to report:
(1)  For waste generated from January 1 – June 30, 2016, the computation form and fee is due September 1, 2016.
(2)  For waste generated from July 1 – December 31, 2016, the computation form and fee is due March 1, 2017.
(3)  For waste generated each year after 2016, the reporting period is January – December and the computation form and fee is due 90 days following the end of the reporting period (March 1).


Click here for more information on the Cook County Liquid Special Waste Reporting rule


Contact Caltha for technical assistance in determine if any wastes being generated are classified as “special wastes” under Illinois rules and if any reports are needed. Caltha can also provide assistance in preparation an submittal of Special Waste reports to Cook County

Small Container Excemption For Some Painting Operations Approved In Illinois

EPA has approved a revision to the Illinois State Implementation plan (SIP) submitted by the Illinois Environmental Protection Agency (Illinois EPA) on November 14, 2011. The revision amended Illinois Administrative Code by adding a "small container exemption" for pleasure craft surface coating operations in the Chicago and Metro-East St. Louis 8-hour ozone nonattainment areas. EPA concluded that these exemptions were consistent with EPA volatile organic compound (VOC) reasonably available control technology (RACT) policy.

As background, in 2010 and 2011 Illinois promulgated rules on VOC RACT emission limitations for coating operations. During that rulemaking, the American Coatings Association (ACA) commented to Illinois EPA that many VOC coating regulations include a small container exemption not to exceed a liter or a quart. The ACA stated that the basis for these exemptions is to allow for small repairs and touch ups to existing coatings at the end of the painting line to avoid having to completely recoat the product, thus resulting in lower VOC emissions overall from pleasure craft coating operations.

EPA found the exemption was consistent with Illinois RACT rules for similar coating operations, including can, coil, vinyl, metal furniture, and magnet wire coatings. EPA agreed with Illinois EPA and ACA that the exemption may reduce VOC emissions by encouraging repairs and touch ups, as opposed to performing complete re-coats.

Caltha LLP provides specialized expertise to clients in Illinois and 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 

EPA Proposes Review of SIPs For SSM Requirements

The EPA is proposing to take action on a petition for rulemaking filed by the Sierra Club in 2011 concerning the treatment of excess emissions in state rules by sources during periods of startup, shutdown, or malfunction (SSM). EPA is proposing to grant in part and to deny in part the request to rescind its policy interpreting the Clean Air Act (CAA) to allow states to have appropriately drawn state implementation plan (SIP) provisions that provide affirmative defenses to monetary penalties for violations during periods of SSM. The EPA is also proposing either to grant or to deny the Petition regarding existing SIP provisions related to SSM in each of 39 states identified in the petition.

For each of those states where EPA proposes to grant the petition concerning specific provisions, EPA also is proposing to find that the existing SIP provision is substantially inadequate to meet CAA requirements and proposes a "SIP call." For those affected states EPA will require the states to submit a corrective SIP revision. Comments on the proposed actions must be received on or before March 25, 2013.

Through this rulemaking, EPA intends to clarify its interpretation of the CAA regarding excess emissions during SSM events. EPA may find specific SIP provisions to be substantially inadequate to meet CAA requirements; if a state's existing SIP provision allows an automatic exemption for excess emissions during periods of startup, shutdown, or malfunction, then the EPA may determine that the SIP provision is substantially inadequate because the provision is inconsistent with requirements of the CAA.
The affected States include:

Alabama
Alaska
Arizona
Arkansas
Colorado
Delaware
District of Columbia
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
New Hampshire
New Jersey
New Mexico
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Rhode Island
South Carolina
South Dakota
Tennessee
Virginia
Washington
West Virginia
Wyoming

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

Illinois Increases Enforcement and Penalties For Illegal Dumping of Solid Wastes

On August 10, 2011, the State of Illinois passed a law that increased enforcement and fines associated with illegal dumping. The new law provides for increased penalties for dumping more than 250 cubic feet of waste or 50 waste tires, and makes it a Class 4 felony. It also increases the felony penalty for open dumping from $5,000 to $25,000.

Previously, the penalty for a first violation of the open dumping prohibition was a Class A misdemeanor, regardless of the quantity of waste dumped.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

EPA Declines Review of Greenhouse Gas Requirements in IEPA Permit

U.S. EPA's Environmental Appeals Board recently issued a decision concerning greenhouse gas requirements of air permits in Illinois. This case involved a petition for review filed by the Sierra Club challenging certain conditions of a prevention of significant deterioration (“PSD”) permit issued by the Illinois Environmental Protection Agency for construction of a synthetic natural gas manufacturing plant.

The Sierra Club raised several issues, including that the permit failed to regulate greenhouse gases. According to Sierra Club, greenhouse gases constitute "contaminants" causing or contributing to "air pollution" under IEPA rules. However, the Illinois EPA disagreed and made its case that IEPA does not interpret State rules as requiring regulation of greenhouse gas emissions.

The Board deferred to Illinois EPA's interpretation and rejected Sierra Club's argument. Because the IEPA had interpreted the disputed provision of its state SIP as inapplicable to greenhouse gases, and because this interpretation did not appear unreasonable, the Appeals Board declined to substitute its judgment for that of the IEPA and denied review of this issue.

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

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website

State Environmental Compliance Resources

Caltha maintains a number of blog resources dedicated to State regulatory programs, including:

Wisconsin Environmental Consultant
Iowa Environmental Consultant
North Dakota Environmental Consultant
Minnesota Environmental Consultant
Texas Stormwater Consultant
Nebraska Stormwater Consultant
California Stormwater Consultant
Illinois Stormwater Consultant
Ohio Stormwater Consultant
Michigan Stormwater Consultant
South Dakota Environmental Consultant

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

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website

Illinois Electronic Products Recycling and Reuse Act

Illinois Environmental Protection Agency has notified computer, television and printer manufacturing companies doing business in Illinois of statewide collection and recycling requirements as they implement recycling programs for excess electronic waste (e-waste). The Illinois Electronic Products Recycling and Reuse Act requires electronic manufacturers and retailers to properly manage discarded and unwanted electronic products, if they sell their products in the state. They must establish a system for recycling and/or reusing computers, monitors, televisions and printers discarded from residences. Beginning January 1, 2012, computers, monitors, televisions and printers will be banned from landfill disposal.

Each year, the Illinois EPA sets a statewide goal for the amount of e-waste that must be recycled and then allocates that goal among electronics manufacturers based on various formulas included in the Act. The statewide recycling goal for 2010 is 31 million pounds of e-waste. Manufacturers are required to pay for e-waste recycling and/or refurbishment up to the amount of their annual goal.

The law does not specify methods for manufacturers to meet these obligations, allowing a free market approach to determine over time the most cost-effective means of annual goal achievement.

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

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

Illinois Clean Air Mercury Rule CAMR Revision

Illinois' Clean Air Mercury Rule (CAMR) provides for the control of mercury from coal-fired electric generating units. Despite the fact that the federal CAMR rule has been vacated, IEPA regards the majority of the rule as in effect. However, because a number of monitoring, recordkeeping, and reporting provisions simply incorporated the federal CAMR rule by reference, and so are no longer valid, the Illinois rule must be amended.

The proposed rule no longer requires a CEMS, but allows periodic emissions testing as an alternative. Additionally, under the proposed rule, units complying with the Multi-Pollutant Standard or the Combined-Pollutant Standard can elect to comply with these monitoring requirements or with semi-annual emissions testing requirements

Under current rules, emissions monitoring must have commenced by January 1, 2009. However, in the proposed rule, this deadline is extended until July 1, 2009. The proposed rule also amends reporting requirements.

Caltha LLP provides specialized expertise to clients nationwide in the air emission and NPDES permitting, environmental management systems develpment, and preparing cost-effective regulatory compliance programs.

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

IEMA EPCRA Tier 2 Reports - Extension of Due Date

Owners or operators of facilities that have hazardous substances on hand in quantities above threshold levels must submit Emergency Preparedness and Community Right-to-know Act (EPCRA) Tier 2 forms by March 1 each year. The Tier 2 report covers the previous calendar year.

The Illinois Emergency Management Agency (IEMA) has extended the reporting deadline for Illinois facilities until March 16, 2009.

The Illinois Emergency Management Agency (IEMA) now requires all regulated facilities to submit Tier 2 information electronically by using Tier 2 Manager, IEMA's Tier 2 on-line filing system. Each facility's username is unique to its physical address. IEMA also requires all EPCRA Section 302 (EHS) and EPCRA Section 311 (MSDS) submissions be made by using Tier 2 Manager. Hard-copy submissions are no longer accepted.

For Reporting Year 2008, there are two new required fields in Tier 2 Manager's Facility Section: 1) drop-down box to select a facility's jurisdictional fire department and 2) addition of a North American Industry Classification System (NAICS) number. NAICS is replacing the SIC Code.

Facilities that reported in 2007, but are not subject to reporting in 2008, should make the facility inactive on the Tier 2 Manager Facility Home Page. Facilities that didn't file in 2007, but are reporting for 2008, must contact IEMA for a state-issued User ID and Password.

[Read more about recent changes to EPA EPCRA 311-312 reporting requirements]
[Read more about recent changes to EPA EPCRA 313 – TRI reporting requirements]

Caltha LLP provides specialized expertise to clients nationwide in the regulatory reporting requirements, EPCRA compliance, and preparing cost-effective compliance programs.

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