New Categories For Air Permit Exemptions Proposed

Minnesota Pollution Control Agency (MPCA) is proposing to adopt amended air quality rules within “exempt source/conditionally insignificant activities rules” to clarify permit requirements for small sources of air emissions and update rules governing the treatment of small air pollution emitting activities (“insignificant activities” and “conditionally insignificant activities”). Written comments on the proposed rules are being accepted until May 29, 2018.

Permitted Dust Control System

Changes create four new categories of conditionally exempt stationary sources where emissions primarily come from one type of activity; auto-body refinishing facilities, coating facilities, woodworking facilities, and insignificant facilities that meet applicable technical standard would be exempt from obtaining an air emissions permit. Changes to the existing categories of conditionally exempt sources, gasoline service stations and concrete manufacturing, are made to align with the rule structure for the new categories.

Caltha LLP | Your Air Permitting Partner

REACH, ROHS, Prop 65 and Other Chemical Compliance Certifications

Caltha LLP Project Summary

Project: Certification of REACH, ROHS, Prop 65, Conflict Minerals, Biocidal Products Compliance
Client: Component Manufacturer 
Location(s): Minnesota

Key Elements: EU Chemical Regulations, California Proposition 65 Labeling, Conflict Minerals Compliance Certifiaction

Overview: Caltha LLP was retained by this component manufacturer to compile compliance documentation and to prepare Certification of Compliance. Certification of compliance was required by customers who purchased manufactured components and incorporated them into their final products which were exported to the European Union and other areas.

Caltha prepared a certification form and background information to be completed by raw material suppliers that allowed each supplier to provide an informed certification statement regarding presence/absence of regulated chemical substances, and if present, documentation that concentrations are below regulatory thresholds.

Total Toxic Organics Management Plan For Metal Finisher

Caltha LLP Project Summary

Project: Total Toxic Organics Management Plan For Metal Finisher
Client: Metal Finishing Company
Location(s): Minnesota

Key Elements: Total Toxic Organics Management Plan, SPCC Plan

Overview: This metal finishing was subject to Categorical Effluent Guidelines. In lieu of monitoring wastewater discharges for the full list of “Total Toxic Organics” the facility opted to prepare and implement a Total Toxic Organic Management Plan (TTOMP) for the site. Caltha was contracted to prepare the TTOMP for the facility. The TTOMP included:
• Inventory and description of TTO compounds used in the electroplating or finishing processes, and degreasing processes;
• Inventory and description of regulated processes where TTO compounds are used;
• Description of disposal methods for materials and wastes that contain TTO compounds;
• Description of controls used to limit or eliminate the discharge of TTO compounds to the sanitary sewer.



Spilled Corrosive Liquid From Aboveground Tank


The TTOMP was combined with a Facility Spill Plan which included processes and containers not specifically addressed under the Effluent Guidelines. Caltha prepared a spill control plan for the site to minimize and control spills from areas where liquids are stored, transferred and used. The spill plan included:
1. Inventory and description of chemical storage and process tanks;
2. Description of batch discharges to sanitary sewer;
3. Description of controls and procedures to prevent entry of chemicals and other restricted materials and wastes from entering the sanitary sewer;
4. Emergency notification procedures;

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

 

Caltha LLP | Your EH&S Compliance, Auditing 

and EMS/SMS Partner

Environmental Inspections, Phase 2 Investigation and Cleanup In Minnesota

Minnesota Phase 1 Environmental Assessment and Cleanup Consultant from Caltha LLP

Caltha LLP is a trusted environmental consulting and engineering firm serving Minnesota with Phase I and Phase II site assessments and remediation services. Caltha LLP maintains close ties with State and local agencies that oversee waste management and contaminated site cleanup, including Minnesota Pollution Control Agency and Hennepin, Ramsey, Anoka, Carver, Washington, Dakota and Scott County governments.

Leaking bulk fuel tank and fuel pump

discovered during Phase I ESA

Click here to review other example Caltha remediation projects. Click here to review other Caltha projects in Minnesota and MN regulatory updates.

Hazardous Waste Management Training In Minnesota

Minnesota-based Environmental, Health & Safety Trainer

Caltha LLP, a Minnesota headquartered EH&S training and consulting company, provides training to facility employees that is required to meet State and Federal regulations, and needed to ensure sustainability, safety and liability management goals are achieved.

Training is provided in a number of flexible formats, including in-person sessions at your site, web-based "live" training, and preparation of customized training modules used by your employees at their convenience.

We provide a wide range of training programs for facilities across Minnesota, including:

SWPPP training	Annual SPCC training	HazCom training
Safety data sheet training	PPE training	Hazardous waste training -LQG
Hazardous waste training -SQG	Environmental awareness	ISO 14001 Awareness
ISO 18001 Awareness	Universal waste training	AWAIR training
HazMat DOT training	Hazard Communication	Workplace spill training

Improper Storage and Labeling of a Flammable Hazardous Waste 

Identified During Waste Audit 

Providing EH&S Training To Facilities Across Minnesota

Caltha provides training to facilities located in all parts of Minnesota and routinely leads training sessions in:

Minneapolis	St. Paul	Rochester	Duluth	Bloomington
Brooklyn Park	Plymouth	Woodbury	Eagan	Maple Grove
Coon Rapids	Blaine	Eden Prairie	Burnsville	Bemidji
St. Cloud	Marshall	Minnetonka	Edina	St. Louis Park
Moorhead	Mankato	Maplewood	Shakopee	Cottage Grove

Minnesota-based Consultant With MPCA, MnOSHA and Local Agency Knowledge

Caltha LLP maintains close ties with the key State and local agencies that oversee environmental and safety compliance programs,  including the Minnesota Pollution Control Agency, Minnesota OSHA, The Metropolitan Council, who regulates wastewater in the Minneapolis- Saint Paul area, and the seven Metro area Counties (Hennepin, Ramsey, Anoka, Washington, Dakota, Carver, Scott) who regulate hazardous wastes.

Click here for more information or to request a quote on Caltha's EHS training services, including Hazardous Waste and DOT Hazardous Material certification training for hazardous waste generators.

MinnesotaToxic Pollution Prevention Plan Update Due January 1, 2018

The Minnesota Toxic Pollution Prevention Act (TPPA) requires facilities that report toxic chemical releases under EPCRA 313 to prepare a Pollution Prevention Plan (P2 Plan) for chemicals reported on EPA Form R. In addition to submitting their EPA Form R to the Environmental Protection Agency (EPA) and the Minnesota Emergency Planning and Community Right-to-Know Act (EPCRA) Program, TRI reporting sites must prepare a Pollution Prevention Plan and to submit annual Pollution Prevention Progress Reports based on those plans to the Minnesota EPCRA Program.

There are two reoccurring P2 requirements for TRI reporting sites in Minnesota:

• Annual P2 Progress Report - due with TRI report on July 1, and
• Biennial Update to Pollution Prevention  (P2) Plan - due by Jan 1 for each odd-numbered year (update required in 2017 must be completed by January 1, 2018)

The Pollution Prevention Plan and Progress Report do not apply to chemicals that are not required to be reported on EPA Form R, are reported on EPA Form A, or are reported on EPA Form R but have no on-site release or off-site transfer amounts.

Click here for more information and regulatory updates on EPCRA reporting.

Safety And Health Consultant Services In Minnesota

The development of cost effective safety programs to manage risks and to comply with OSHA regulations is a core service provided by Caltha LLP. Caltha also provides expert professional & technical support in developing safety management systems and in OHSAS 18001 registration. Caltha also supports our clients’ liability management programs by providing both systems and compliance auditing services.

Developing safety management programs that are easy to implement, document & track is an important service Caltha provides to our clients. This includes integrating compliance management with other risk management, quality improvement and cost control initiatives that our clients may already have. Caltha will train your staff to successfully implement the safety management programs in the future.

Caltha can also provide "as needed" technical support in preparing and maintaining OSHA compliance records, and to conduct incident investigations to support a root cause analysis. Caltha staff have led multi-disciplinary teams to develop corrective action plans arising from variety of incidence, including injuries, accidents, spills and fires.

Click here for more details on the safety, health and emergency preparedness services Caltha provides.

Click here to review a sampling of our past safety related projects.

Compliance and Sustainability Training For MN and ND Industry

Caltha LLP Project Summary

Project: Environmental Awareness / Sustainability Training Module For Facility Management
Client: Grain Processing & Food Manufacturing Corporation 
Location(s): Minnesota, North Dakota


Key Elements: Regulatory training, Sustainability, Permit compliance, Employee training, Webinar


Overview: Caltha LLP was retained by this grain processing and food manufacturing corporation to prepare and present a training module that provides corporate and facility managers with basic compliance training to assist them in managing EH&S compliance activities at multiple facilities. The training was developed to be specific to the corporation's facilities and products and included:

• Company's commitment to sustainability / Sustainability policy
• Background on environmental regulations and key issues at company's locations
• Overview of company's key procedures

Training was created as a recorded live webinar which can be replayed as needed.


For more information on Caltha LLP EH&S Training services, go to the Caltha LLP EH&S Training 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

Metal Plating Operation Required To Have Total Organic Spill Plan

Caltha LLP Project Summary

Project: Total Toxic Organics Management Plan For Metal Finisher
Client: Metal Finishing Company
Location(s): Minnesota


Key Elements: Total Toxic Organics Management Plan, SPCC Plan


Overview: This metal finishing was subject to Categorical Effluent Guidelines. In lieu of monitoring wastewater discharges for the full list of “Total Toxic Organics” the facility opted to prepare and implement a Total Toxic Organic Management Plan (TTOMP) for the site. Caltha was contracted to prepare the TTOMP for the facility. The TTOMP included:
• Inventory and description of TTO compounds used in the electroplating or finishing processes, and degreasing processes;
• Inventory and description of regulated processes where TTO compounds are used;
• Description of disposal methods for materials and wastes that contain TTO compounds;
• Description of controls used to limit or eliminate the discharge of TTO compounds to the sanitary sewer.


The TTOMP was combined with a Facility Spill Plan which included processes and containers not specifically addressed under the Effluent Guidelines. Caltha prepared a spill control plan for the site to minimize and control spills from areas where liquids are stored, transferred and used. The spill plan included:
1. Inventory and description of chemical storage and process tanks;
2. Description of batch discharges to sanitary sewer;
3. Description of controls and procedures to prevent entry of chemicals and other restricted materials and wastes from entering the sanitary sewer;
4. Emergency notification procedures;


Click here for more information on Caltha LLP Spill Prevention and Response Plan Services and SPCC Support Services.

PPE Assessment and Employee Exposure Review For Minnesota Manufacturer

Caltha LLP Project Summary

Project: PPE Assessment
Client: Chemical Formulating Facility
Location(s): Minnesota

Key Elements: PPE assessment, OSHA hazard communication, employee training, safety data sheet, employee exposure control

Overview: Caltha LLP was retained by this chemical processing facility to conduct a PPE assessment for specific processing areas, including dry mixing, blending, wet mixing, and packaging. Caltha staff reviewed raw material and finished product safety data sheets, as well as specific tasks being conducted in each area. For each area, a standard set of employee PPE was prescribed; specific materials which require additional or other types of PPE were then identified. Employees were provided training, including visual reminders at each work station, to alert them when PPE beyond the standard was required.

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

Hazardous Waste and DOT Hazardous Material Training For Minnesota Facility

Caltha LLP Project Summary

Project: Employee training on Hazardous Waste management, Universal Waste Management, and DOT HazMat training for shipping of regulated hazardous materials
Client: Medical product manufacturer
Location(s): Minnesota

Key Elements: Waste management, Employee training, DOT hazardous material shipping

Overview: Caltha LLP assisted this medical product manufacturer by conducting employee training sessions at the client's facility covering:

• Hazardous waste management, for conditionally exempt small quality generator (CESQG)
• Universal waste management
• DOT HazMat employee training for individuals responsible for preparing and shipping hazardous materials, including wastes

For more information on Caltha LLP training services provided to small and medium sized facilities, go to Employer's Environmental Health and Safety Training Center.

Registration Permit Review For New Facility In Minnesota

Caltha LLP Project Summary

Project: Option D Permit Review For New Process
Client: Food Manufacturing Processing Facility
Location(s): Minnesota

Key Elements: Air permitting, Air permit compliance, Air emission estimates, Control equipment efficiency

Overview: Caltha LLP was retained by this food manufacturing processing facility to conduct an evaluation to determine if a new project planned at the facility would require a modification to the existing air emission permit issued by MPCA or if prior notifications would be required for the project. Caltha staff reviewed project plans to determine added air emissions resulting from the new project. These estimates were added to emission estimates for all other permitted sources at the facility to determine if any permit actions were required. Based on the technical evaluation, it was determined that the project could be constructed with no permit modifications or notifications.

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

Environmental Awareness and Sustainability Training For Food Manufacturer

Caltha LLP Project Summary

Project: Environmental Awareness / Sustainability Training Module For Facility Management
Client: Grain Processing & Food Manufacturing Corporation
Location(s): Minnesota, North Dakota

Key Elements: Regulatory training, Sustainability, Permit compliance, Employee training, Webinar

Overview: Caltha LLP was retained by this grain processing and food manufacturing corporation to prepare and present a training module that provides corporate and facility managers with basic compliance training to assist them in managing EH&S compliance activities at multiple facilities. The training was developed to be specific to the corporation's facilities and products and included:

• Company's commitment to sustainability / Sustainability policy
• Background on environmental regulations and key issues at company's locations
• Overview of company's key procedures

Training was created as a recorded live webinar which can be replayed as needed.

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

SWPPP and SWPP Training For Minnesota Residential Development

Caltha LLP Project Summary

Project: Construction Permitting, SWPPP & Training
Client: National Home Builder
Location(s): Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 49-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.

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

Hazardous Material Storage Review For Minnesota Manufacturer

Caltha LLP Project Summary

Project: Hazardous Material Storage Review
Client: Specialty Plastics Manufacturer
Location(s): Minnesota

Key Elements: Haz Mat regulatory review, Site storage inspection

Overview: Caltha LLP was retained by the specialty plastics manufacturer to conduct a review of Federal, State, County and City requirements related to planned on-site storage of several new hazardous materials. Once complete, Caltha staff conducted a pre-start-up on-site review on storage and handling practices and waste management.


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

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

MPCA Delays Enforcement Action On Handling of Hazardous Aerosols & Cylinders

The Minnesota Pollution Control Agency has extended its compliance deadline for one important change to its policies regarding management of spent aerosol cans and gas cylinders that contain hazardous chemicals. Historically, the MPCA had elected not to take enforcement action against hazardous waste generators who empty aerosol cans and cylinders by releasing pressure into the atmosphere, including those who puncture cans with equipment fitted with carbon or other filtration systems to capture vapors. The agency considers this "abandonment" of hazardous waste, which is prohibited.


The MPCA had planned to change its enforcement policy as of January 1, 2017. which would require generators using such equipment to find an alternate means of handling aerosol cans and cylinders. The agency recently announced that it has extended this change to enforcement policy until January 1, 2018, to allow facilities more time to modify their practices, if needed.


Minnesota is one of only a few States that allows aerosol cans and gas cylinders to be handled as though they were universal wastes, although they are technically not regulated as universal wastes under State and Federal rules. MPCA has established some minimum requirements generators must comply with to take advantage of this policy.


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

MPCA Rules On Puncturing and Venting Spent Aerosol Cans Changes January 1, 2017

In Minnesota, generators can puncture waste aerosols or gas cylinders that have been shown to be empty or that have been evaluated as non-hazardous, as long as any unavoidable liquid residuals are collected and properly managed.


However, hazardous waste aerosols and gas cylinders may no longer be punctured or vented in Minnesota after January 1, 2017, unless all hazardous waste propellant gases, product gases, and liquids are captured and properly disposed. MPCA does not allow charcoal and activated carbon filters to be used to capture hazardous waste propellants or gases for disposal.


The deliberate release of hazardous waste propellant or compressed gas to the atmosphere has been prohibited by the Minnesota Hazardous Waste Rules for many years, but MPCA chose not to enforce this prohibition. This allowed generators and collection sites to puncture hazardous waste aerosols and dispose of ignitable hazardous waste to the atmosphere. This practice is not allowed after 1/1/2017.


UPDATE: The deadline for this policy change has been revised.




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 Rules Allow Handling Aerosol Cans As Universal Waste In Minnesota

A handful of States allow spent aerosol cans to be handled under State Universal Waste rules (email Caltha LLP if you would like to know if your State is included), although this waste stream is not a Federal universal waste under 40 CFR 273. The Minnesota Pollution Control Agency has finalized rules that will allow generators to manage aerosol cans as universal wastes.



Because documenting that an aerosol container or gas cylinder meets “RCRA Empty” standard can be impractical, MPCA allows generators to assume that an aerosol container is empty when both the following conditions are met:
· No liquid is felt or heard when the container is shaken by hand; and
· No gas or liquid is released when the spray/discharge valve is activated and the container rotated through all directions, as long as the valve is not observably or known to be clogged.



Hazardous waste aerosols and gas cylinders that are not empty can be managed under rules equivalent to universal wastes in Minnesota. Generators must accumulate hazardous waste aerosols and gas cylinders in closed containers labeled with one of these phrases:
· Universal Waste Aerosols/Gas Cylinders (whichever is appropriate)
· Waste Aerosols/Gas Cylinders
· Used Aerosols/Gas Cylinders



Accumulated hazardous waste aerosols/gas cylinders can be stored on-site for no more than one year and must be dated to verify how long they have been stored. Generators can ship hazardous waste aerosols/gas cylinders without a hazardous waste manifest to any site that has agreed to accept and properly manage them.





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