New Hazardous Waste Rule Effective In North Carolina

The Hazardous Waste Generator Improvement Rule amended the Federal RCRA rules and enacted several important changes in how hazardous waste is managed. The Federal Rule was finalized in November 26, 2016 and became effective in a few States (Iowa, Alaska) on May 30, 2017. For all other States where implementation of RCRA had been delegated to State agencies, the Hazardous Waste Generator Improvement Rule did not become effective until States formally amended State rules to include these new provisions. Because some elements of the Hazardous Waste Generator Improvement Rule were less stringent that the existing RCRA rules, States had the option to include or exclude those portions when adopting their own State laws. For those portions of the Hazardous Waste Generator Improvement Rule that were more stringent than the existing RCRA rules, States were required to accept Federal rules in order to maintain an approved RCRA program.

Click here for a summary of the Hazardous Waste Generator Improvement Rule.



Leaking Waste Solvent Hazardous Waste Tank



In 2017, The North Carolina  Department of Environmental Quality put a hold on all State rulemaking in order to go through a formal rulemaking process to incorporate the Hazardous Waste Generator Improvement Rule. That process was concluded in 2017. The State of North Carolina has finalized the updated hazardous waste rules which become effective on March 1, 2018.

Click here for more North Carolina regulatory updates and Caltha project examples from North Carolina.

 

Caltha LLP | Your EH&S Compliance, Auditing 

and EMS/SMS Partner

Certified Environmental and Safety Audit in Raleigh

Caltha LLP Project Summary

Project: Multimedia EH&S Compliance Audit
Client: National Corporation
Location(s): Raleigh-Durham Region, North Carolina

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, hazard communication

Overview: Caltha staff conducted a multimedia environmental, health and safety audit of this industrial facility located in Raleigh-Durham Region. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management- 15A NCAC 13B
• Current NC Air Permit
• NC Air Pollution Control Rule – NCAC 15A-2D
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.


Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in North Carolina and NC regulatory updates.

Charlotte Facility Needed Audit For Compliance Improvement

Caltha LLP Project Summary

Project: Compliance Audit
Client: National Industrial Corporation
Location(s): Charlotte, North Carolina

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, hazard communication

Overview: Caltha staff conducted a multimedia environmental, health and safety audit of this industrial facility located in Charlotte, NC. The scope of the audit included:

• EPCRA
• Hazardous waste rules as applicable to RCRA Conditionally Exempt Small Quantity Generator (CESQG), and Solid Waste Management rules including Mecklenburg County Mandatory Source Separation Ordinance (SSO) and 15A NCAC 13B
• Current NC Air Permit
• Current Charlotte-Mecklenburg Utility Department industrial wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in North Carolina and NC regulatory updates.

DEQ Plans Hazardous Waste Generator Rule Update

The North Carolina Department of Environmental Quality (DEQ) has proposed a schedule to adopt the federal hazardous waste generator improvement rule into State hazardous waste regulations. This state rule also freezes the existing hazardous waste generator rules from May 29,2017 in place until North Carolina adopts the Hazardous Waste Generator Improvements Rule on March 1, 2018.

The EPA Hazardous Waste Generator Improvement Rule was finalized in 2016 and became effective in a few States in May 2017. However, the majority of States need to adopt the rule into their own State regulations in order for generators in their State to take advantage of the rule.

The EPA revision to RCRA rules is especially significant to Small Quantity generators (SQG) and Conditionally Exempt Small Quantity Generators (CESQG). Click here for more information on the key changes under the Hazardous Waste Generator Improvement Rule.

Click here for examples of Caltha projects related to hazardous waste management, and for project examples for clients located North Carolina.

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.


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

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

North Carolina CAFO General NPDES Permit Renewal

The North Carolina Department of Environment, Health, and Natural Resources – Division of Water Quality has revised its general NPDES discharge permits for confined animal feeding operations (CAFO). The current general permits for waste systems at swine, cattle and dairy and wet poultry operations will expire on Sept. 30, 2009. Operators of swine, cattle and poultry farms who come under the state general permits for wastewater systems need to apply for renewal under the new permit before April 1, 2009.

Animal feeding operations that have more than 250 swine, 100 confined cattle or dairy animals, 75 horses or a wet litter operation for more than 30,000 chickens are required to apply for a permit from the state.

General permits set requirements for waste management activities common to facilities of a particular type, and are issued as a class every five years. General permits for animal operations are issued along with certificates of coverage that address specific requirements for each facility.

The new general permits differ from the current permits in some operational, monitoring and reporting requirements. The most substantive change to the current permit is that application of waste must stop within 4 hours of a National Weather Service (NWS) issuing a warning of a hurricane, tropical storm or flood watch for the county in which the CAFO is located.

Looking for other water quality-related topics?, go to:
Water Quality Standards Aquatic Toxicology NPDES Permit Limits

Caltha LLP provides specialized expertise to clients nationwide in the NPDES permitting, State and Federal water quality regualtions, and preparing cost-effective compliance management programs.

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