General Permits For Wastewater Proposed By IDNR

The Iowa Department of Natural Resources (DNR) has proposed two general discharge permits to cover two types of common and generally low risk discharges.

DNR plans to issue two new National Pollutant Discharge Elimination System (NPDES) general permits known as General Permit #8 (GP8) and General Permit #9 (GP9). GP8 allows for discharges of hydrostatic test water (water used to test the integrity of a pipe or tank), underground storage tank ballast water (water used to weight a tank to facilitate underground installation), and water associated with installation, repair, and replacement of potable water lines. GP9 allows for discharges from dewatering associated with construction and small residential geothermal heating and cooling systems.

IDNR is proposing to include eligibility criteria and Best Management Practices. These will ensure that discharges will comply with water quality standards. Most permittees will be automatically authorized to discharge. Only a few higher-risk dischargers will need to submit a Notice of Intent. There is no fee for either permit.

DNR is seeking public comment on proposed rules that will create two new general permits. DNR will hold three public hearings across the state in March:

• Wednesday, Mar. 7, 4 p.m. at the Coralville, IA Public Library
• Thursday, Mar. 8, 4 p.m. at the Harlan, IA Public Library
• Wednesday, Mar. 14, 4 p.m. at the Urbandale, IA Public Library

Caltha LLP | Your Air Permit, Wastewater Permit, 

Storm Water Permit Partner

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

Environmental Compliance Training, Waste Management Training, SPCC Training

Caltha LLP provides a wide range of training programs to industrial and government sector clients to meet the requirements of State and EPA rules, permits and related spill and emergency preparedness rules. Training can be provided to large or small groups and is provided either in person at your location, or through a live webinar format. For further information and to request a quote, go to Employer's Environmental Health and Safety Training Center.


The training sessions commonly requested include:

• Hazardous waste management training
• SPCC annual training
• Spill response training
• DOT hazardous material (HazMat) triennial recertification and initial training
• Facility compliance training overview (covering a wide range of typical facility environmental compliance topics)
• Internal compliance auditor training
• Industrial and construction site stormwater discharge permit training
• Stormwater monitoring training
• Training for site inspections

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

EPA Hazardous Waste Generator Improvements Rule - What States Are Affected?

The Hazardous Waste Generator Improvements Rule is now signed and  published in the Federal Register on November 28, 2016. This leaves hazardous waste generators to sort out how this will affect them, and when.


Immediate Affect of the Hazardous Waste Generator Improvements Rule
The Generator Improvements Rule modified the Federal rules under RCRA and therefore has direct affect on hazardous waste generators located in States that have not been delegated RCRA authority (Iowa and Alaska) and some other areas, including Tribal lands. However, many States have incorporated portions of the RCRA rules by reference into their authorized programs – therefore, in these States revisions to Federal RCRA rules can have an immediate affect on State rules. This can significantly increase the population of hazardous waste generators that will be affected by the Hazardous Waste Generator Improvements Rule s ix months after publication in the FR - on May 30, 2017.

For generators located in States that have not incorporated generator requirements by reference, the impact of the rule revision will be uncertain. Rule changes will only become effective when States modify their own hazardous waste generator requires. To add to the uncertainty, States will only be required to modify their rules to incorporate portions of the Hazardous Waste Generator Improvements Rule that are MORE stringent than current rules. Other portions of the new EPA rules that add flexibility, are less stringent, or are incorporate clarifications to the rule would not need to be addressed by States to maintain their authorized programs under RCRA.

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 

New Iowa Air Permitting Option - Collection of Air Permits (CAP)

The Iowa DNR is proposing to create a new air quality construction permit option called a Collection of Air Permits (CAP). Current construction permit practice is to issue one permit per emission point. The new CAP permit option will still assign a permit number to each emission point but will consolidate requirements in one permit document.


Several changes have been proposed to the CAP based on comments received during the first CAP comment period in January 2016. Additionally, the CAP was modified to be consistent with the recently updated standard permit format.


For more information on the Iowa CAP air permit program, click here.


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 
 

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

IDNR Schedules Public Meetings On Revised Compliance and Enforcement Procedures

The Iowa Department of Natural Resources (DNR) has scheduled three additional public hearings for proposed new Chapter 17, Compliance and Enforcement Procedures. The DNR is also providing more information on how the DNR plans to implement Chapter 17.

The DNR is holding the additional hearings to allow the public further opportunity to provide input. The DNR held its first public hearing on Monday, April 23.

The three hearings will be held in July and August as follows:

•  Wednesday, July 18, 2012 in Iowa City;
• Tuesday, July 31, 2012 in Mason City; and
• Tuesday, August 7, 2012 in Carroll.

Further, in response to public comments already received, the DNR is providing more information about how the DNR plans to implement Chapter 17. The DNR did not make any changes to the proposed rule language for Chapter 17.

The DNR is also requesting additional public comments. Written comments or suggestions are due no later than 4:30 p.m. on Thursday, August 16, 2012.


Caltha LLP provides specialized expertise to clients in Iowa 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

Schedule For Action On State Regional Haze Plans

The U.S. Environmental Protection Agency (EPA) has announced a court ordered schedule to review and act on more than 40 state regional haze reduction plans, designed to improve visibility in national parks and wilderness areas. The EPA action by itself does not establish control requirements; EPA will work with the states to approve their plans by the court ordered deadline in the agreement. Under the terms of the consent decree, if a state plan cannot be approved, EPA will determine an appropriate federal plan.

The dates for promulgation of final rules (either accepting or rejecting State plans) begin December 13, 2011 and run through November 15, 2011. States are grouped within this timeframe.

EPA initially issued a rule in 1999 requiring states to submit regional haze plans. These plans were due in December 2007, but no action was taken by the agency in response to the submittals. National Parks Conservation Association and other environmental groups sued the agency in August 2011 to take action on these plans, and the consent decree resolves this litigation. EPA will accept public comment on this agreement for 30 days following publication of a notice in the Federal Register.

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

RMP Compliance Grant for Iowa Ammonia Facilities

EPA has awarded the Iowa Department of Agriculture and Land Stewardship (IDALS) a grant for $70,000 to assist with outreach, education and implementation of the Clean Air Act’s Risk Management Program (RMP) at anhydrous ammonia facilities. All fertilizer facilities that handle, process or store more than 10,000 pounds of anhydrous ammonia are subject to EPA’s chemical safety requirements. IDALS plans to use funding to conduct on-site audits, workshops and follow-up safety assessments at agricultural retail anhydrous ammonia facilities in Iowa.

EPA Region 7 receives more accidental release reports for ammonia than for any other chemical. In addition to releases caused by transportation accidents, human error and equipment failure, a number of releases have been caused by anhydrous ammonia thefts. Anhydrous ammonia is a key ingredient in the illegal production of methamphetamine. When stolen, the toxic gas can be unintentionally released, causing injuries to emergency responders, law enforcement personnel, and the public.

Retailers were first required to be in compliance with the Risk Management Program in 1999. EPA then started facility inspections and enforcement of the program, which includes five components: hazard assessment system, management, accident prevention, emergency response and submittal of a risk management plan.

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

IDNR Antidegradation Rules - Extension of Comment Period on Proposed Revision

The Iowa Department of Natural Resources (DNR) has extended the public comment period on the proposed antidegradation rules to March 4. The antidegradation policy, required by Iowa law, would set minimum requirements for the conservation, maintenance and protection of water quality and existing uses of surface waters.

Antidegradation policy is one of the three components of water quality standards - 1) designated uses, 2) water quality criteria to protect those uses, and 3) antidegradation policy). The DNR is proposing a four-tiered approach, including creating a guidance document that establishes procedures for implementing the antidegradation policy.

The changes being proposed include the following:

1. Incorporate by reference the document entitled “Iowa Antidegradation Implementation Procedure,” which proposes an approach to be followed in assessing and minimizing degradation of Iowa’s surface waters


2. Update antidegradation policy language with four tier approach, and


3. Remove High Quality (Class HQ) and High Quality Resource (Class HQR) designated uses and add several waters to the newly proposed Outstanding Iowa Water (OIW) category.
   
   

Caltha LLP provides specialized expertise to clients nationwide in the evaluation and use of ambient water quality criteria, site-specific water quality standards, and permit limits. Caltha staff have prepared national Ambient Water Quality Criteria for US EPA and provide expert resources for permittees and/or their technical consultants as they address State and Federal water quality standards.

[Click here to request further information on water quality standards technical support.]

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

Iowa DNR Antidegradation Policy – IDNR Accepting Comments on Draft Policy

The Iowa Department of Natural Resources (IDNR) is proposing changes to its “Antidegradation Policy”. The changes can impact any wastewater discharger in Iowa, but especially new permittees or existing permittees that may wish to increase their discharge in the future. The changes being proposed include:

• Incorporate by reference the document entitled “Iowa Antidegradation Implementation
  Procedure,” which proposes an approach to assessing and minimizing degradation of Iowa’s surface waters,
• Update antidegradation policy language with four tier approach,
• Remove High Quality (Class HQ) and High Quality Resource (Class HQR) designated uses and add several waters to the newly proposed Outstanding Iowa Water (OIW) category.
  

The purpose of the antidegradation policy is to set minimum requirements to conserve, maintain, and protect existing uses and water quality for water bodies that currently meet their water quality standards. The department is required by Clean Water Act to develop and adopt a statewide antidegradation policy and to identify procedures for implementing the policy. Comments on the draft policy are being accepted through January 29, 2009.

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