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.


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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

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

Michigan General Permit for Diesel Generators Suspended

The Michigan Department of Natural Resources and Environment (MDNRE) General Permit to Install for Diesel Fuel-Fired Engine Generators has been suspended from use due to the new federal National Ambient Air Quality Standard (NAAQS) for nitrogen dioxide (NO2). Any general permits previously issued for diesel-fired generators will remain in effect.

On January 22, 2010, the US EPA promulgated a final rule containing a new NAAQS for NO2 based on a 1-hour averaging time. On April 12, 2010, 188 µg/m3 became effective as the 1-hour NAAQS for NO2 . The applicability criteria and special conditions in the general permit for generators have been reevaluated by MDNRE to determine the impact of this new standard. Dispersion modeling was done for a hypothetical generator to determine the maximum ambient 1-hour N02 concentration. A representative building and various stack parameters were used and the modeling assumed the generator stack to be an isolated facility with no other sources considered in the analysis. All alternative stacks showed a total impact to be above the 1-hour NO2 NAAQS.

Because the current general permit for diesel generators does not limit NO2 emissions to adequately ensure compliance with the new 1-hour NO2 limit the permit is being suspended from use at this time. Until the general permit for diesel-fired generators is revised, a case-by-case permit to install pursuant to Rule 201 is being used for diesel-fired generators.

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

MDEQ Section 404 Wetlands Program - EPA Program Review

In 2008, the U.S. Environmental Protection Agency (EPA) issued a report on its informal review of Michigan’s EPA-approved Clean Water Act (CWA) Section 404 wetlands program. Michigan is one of only two States to have received approval to administer the Section 404 program. Michigan’s Section 404 program is implemented by the Michigan Department of Environmental Quality (MDEQ).

As background, in 1997 EPA conducted a review of Michigan’s approved CWA Section 404 program and identified deficiencies that required corrective action. In its July 31, 2008 Notice, EPA again identified a number of deficiencies in Michigan’s program. MDEQ has agreed to address the deficiencies listed by EPA through a number of means, including seeking legislative amendments to Michigan’s wetlands statute, Part 303 (Wetlands Protection) of the Michigan Natural Resources and Environmental Protection Act (NREPA).

MDEQ committed to initiating the legislative corrective actions in early 2009 and to completing them within 36 months. EPA will review the status of MDEQ’s corrective actions within 36 months after the Notice to determine whether Michigan’s Clean Water Act Section 404 wetlands program approval should be revoked.

EPA took issue with a number of activities that Part 303 exempts from the requirement to obtain a wetlands permit, but that are not exempted from the CWA’s requirements, including exemptions for:

• agricultural activities;


• drain creation and improvement; and


• iron and copper mining tailings basins.

To address these deficiencies, MDEQ has agreed to seek legislative amendments that would limit the agricultural exemptions, delete the agricultural drainage exemptions, delete the exemption for iron and copper mining tailings basins; and to delete the exemption for utility maintenance activities.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation water quality rules, wastewater and stormwater permitting, and preparing cost-effective compliance management programs.

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