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

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

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

NDEQ Environmental Permits Now Require Proof of Legal Status

The Nebraska Department of Environmental Quality (NDEQ) now requires that applicants for environmental permits (air emissions, wastewater, stormwater, etc) provide an attestation form certifying that they are in the U.S. legally.

On April 8, 2009, the Governor signed into law Legislative Bill 403 (LB 403). This law (effective October 1, 2009) requires state agencies to verify the lawful presence in the United States of any person who has applied for public benefits that are administered by that agency. For the purposes of the law, public benefits are defined to mean “any grant, contract, loan, professional license, commercial license . . . or any other similar benefit” provided by a governmental agency. This includes the professional certifications, permits, and approvals issued by the NDEQ.

Applications for State issued permits must include the Attestation Form. Failure to complete and submit the Attestation Form will delay processing of the application.

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

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

NDEQ Proposed Area Source NESHAP Rule

The Nebraska Department of Environmental Quality (NDEQ) is proposing that seven area source NESHAPS be adopted and implemented as issued by the EPA. For two EPA standards, however, the NDEQ is proposing additional rules which will allow sources to limit monthly throughputs below the facility’s maximum design capacity in order to avoid the more stringent and costly controls required for facilities with greater monthly throughputs. Sources taking these limits must document their adherence to the agreed upon lower throughputs. The two industry categories for which this option will be offered are bulk gasoline terminals and gasoline dispensing facilities.

• Hospital Ethylene Oxide Sterilizers (Subpart WWWWW)
• Electric Arc Furnace Steelmaking Facilities (Subpart YYYYY)
• Iron and Steel Foundries Area Sources (Subpart ZZZZZ)
• Paint Stripping and Miscellaneous Surface Coating Operations (Subpart HHHHHH)
• Clay Ceramics Manufacturing (Subpart RRRRRR)
• Glass Manufacturing Area Sources (Subpart SSSSSS)
• Secondary Nonferrous Metals Processing (Subpart TTTTTT)

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

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

Pesticide NPDES Permit - NDEQ Proposed Permit By Rule

The Nebraska Department of Environmental Quality (NDEQ) is proposing a Permit-By-Rule related to the application of pesticides in and near waters of the State.

As background, the Permit-by-Rule is being proposed to address a gap in permit coverage left after a decision by the 6th Circuit Court of Appeals in January 2009, which vacated the U.S. Environmental Protection Agency (EPA)’s pesticide rule.

[Read more about vacatur of EPA pesticide rule]

The NDEQ rule establishes a Permit-by-Rule for the application of pesticides to, over, or near, waters of the state provided that the pesticide applicator:

(1) complies with FIFRA requirements relating to water quality, compliance with all label application directions, buffer zones, application locations, intended targets, protecting threatened or endangered species, times of day, temperature or other application requirements, and proper disposal of pesticide residues; and
(2) retains certain information relating to name of the pesticide, targeted pests or weeds, pesticide label, and details of the application.

The Permit-by-Rule applies to chemical pesticides only; no biological pesticides are allowed under the Permit-by-Rule. NDEQ also requires the applicator to report any adverse impacts to non-targeted species or the environment to the Department within 24 hours.

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

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