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

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

Greenhouse Gas Permiting in AZ, AR, ID, KS, OR, WY & TX

U.S. Environmental Protection Agency (EPA) has proposed the final series of actions that will ensure that the largest industrial facilities can get Clean Air Act permits that cover greenhouse gas (GHG) emissions beginning in January 2011. The first set of actions will give EPA authority to permit GHGs in seven states (Arizona, Arkansas, Florida, Idaho, Kansas, Oregon, and Wyoming) until the state or local agencies can revise their permitting regulations to cover these emissions. EPA is taking additional steps to disapprove part of Texas' Clean Air Act permitting program and the agency will also issue GHG permits to facilities in the state. These actions will ensure that large industrial facilities will be able to receive permits for greenhouse gas emissions regardless of where they are located.

In the second set of actions, EPA has issued final rules that will ensure that there are no federal laws in place that require any state to issue a permit for GHG emissions below levels outlined in the tailoring rule.

Beginning in January 2011, industries that are large emitters of GHGs, and are planning to build new facilities or make major modifications to existing ones, must obtain air permits and implement energy efficiency measures or, where available, cost-effective technology to reduce their GHGs emissions. EPA will propose standards for power plants in July 2011 and for refineries in December 2011 and will issue final standards in May 2012 and November 2012, respectively.

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

States Identified For Greenhouse Gas Permitting Program Updates

Working with the states, the U.S. Environmental Protection Agency (EPA) is moving forward with its plan to require certain states to update their Clean Air Act implementation plans to cover greenhouse gas (GHG) emissions. These updates are required to ensure that beginning in January 2011 the largest industrial GHG emissions sources can receive permits. This action is part of EPA’s “Tailoring Rule”.

EPA has identified 13 states that need to make changes to their plans, allowing them to issue permits that include GHG emissions. These states include:
Arizona, Arkansas., California, Connecticut, Florida., Idaho, Kansas, Kentucky, Nebraska, Nevada, Oregon, Texas, and Wyoming.

The Clean Air Act requires states to develop EPA-approved implementation plans that include requirements for issuing air permits. When federal permitting requirements change, as they did after EPA finalized the GHG tailoring rule, states may need to modify these plans.

In January 2011, industries that are large emitters of GHGs, and are planning to build new facilities or make major modifications to existing ones, will work with permitting authorities to identify and implement the most efficient control technologies to minimize their GHGs. This includes the largest GHG emitters, such as power plants, refineries and cement production facilities. Emissions from small sources are not covered by these GHG permitting requirements.

Related links:
GHG Tailoring Rule

Greenhouse Gas (GHG) permitting information

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

Kansas Greenhouse Gas, GHG, Tailoring Rule

The Kansas Department of Health and Environment has proposed new air quality regulation K.A.R. 28-19-200a, regarding general provisions and definitions to implement the federal greenhouse gas (GHG) tailoring rule, and proposed amended air quality regulation K.A.R. 28-19-350, regarding prevention of significant deterioration (PSD) of air quality.

The proposed new regulation K.A.R. 28-19-200a and amendment to K.A.R. 28-19-350 will align State air quality regulations with the revised federal regulations for the Title V and PSD programs to implement the federal Title V GHG Tailoring Rule. The proposed regulatory actions incorporate the modified definition of ‘‘major source’’ and the new definition for ‘‘subject to regulation’’ in K.A.R. 28-19-200a to update the Title V program and update the adoption by reference of 40 C.F.R. 52.21 in K.A.R. 28-19-350 to align the state PSD program with the federal program.

These proposed regulatory actions are needed for the state of Kansas to retain the primary authority to implement the PSD and Title V programs and retain the ability to issue permits for both programs.

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