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

TCEQ Issues Revised General Operating Permits

The Texas Commission on Environmental Quality (TCEQ) has issued revisions to Oil and Gas General Operating Permits (GOP) 511 and 514. The revisions were needed to address the applicability status of Wise County. Sites in Wise County are now covered under GOP 511 instead of GOP 514. The revised GOPs were proposed on January 27, 2017, and the public comment period closed on February 27, 2017.

Current permit holders are required to submit an application for a new authorization to operate (ATO) no later than October 12, 2017, if any of the emission units, applicability determinations, or the basis for the applicability determinations are affected by the revisions in the renewed GOPs. If the revisions in the GOPs do not affect a site, a new ATO is not required.

For more information on Caltha LLP air permitting services in Texas, go to
Caltha Permitting And Compliance Support

Approval For Texas New Source Review Program

On October 11, EPA approved revisions to the Texas permitting program for major air pollution sources under the Clean Air Act's New Source Review (NSR) program. According to EPA, changes submitted by the Texas Commission on Environmental Quality (TCEQ), increase regulatory certainty and efficiency while ensuring public health and the environment are protected. The revised plan provides industry with operating flexibility by establishing site-wide emission caps known as "Plant-wide Applicability Limits," or PALS, for existing sources. These PALS require continuous monitoring for each of the units included in the cap.

According to EPA, this final approval of the state's revised plan enhances the clarity and enforceability of state issued permits and also provides industry with flexibility to meet Clean Air Act requirements, while ensuring environmental protection. The adopted rules are fully consistent with federal requirements and consistent with NSR reform rules approved by EPA for other states in the country.

Congress established NSR permitting program as part of the 1977 Clean Air Act Amendments. NSR is a preconstruction permitting program that protects air quality while allowing for industrial growth. In Texas, NSR permits are legal documents issued by the TCEQ that facility owners/operators must abide by. The permit specifies what construction is allowed, what emission limits must be met, and often how the emissions source must be operated.
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

Texas New Source Review NSR Program Approval

U.S. Environmental Protection Agency (EPA) announced its proposal to approve revisions submitted by the Texas Commission on Environmental Quality to the state’s permitting program for major air pollution sources under the Clean Air Act’s New Source Review (NSR) program. These changes to the State’s clean air plan meet federal clean air goals by establishing state rules for existing major facilities that are consistent with federal permitting requirements.

The revised plan provides operating flexibility by establishing site-wide emission caps known as “Plant-wide Applicability Limits,” or PALS, for existing sources. These PALS require continuous monitoring for each of the units included in the cap. PALS are a useful because they provide flexibility in the daily operations at a facility. Today’s proposal is the result of many months of work by Texas Commission on Environmental Quality and EPA to develop a PALS program for the state.

After publication in the Federal Register, the EPA will seek public comment on this proposed approval of the state’s revised plan for 30 days. Comments will be considered as the agency completes the final decision process.

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

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

Texas Audit Program Option For Flexible Permit Holders

U.S. Environmental Protection Agency (EPA) has released its voluntary Audit Program to help companies in Texas with Flexible Permits obtain air quality permits that meet state and federal requirements and the protections of the Clean Air Act (CAA). The TCEQ's Flexible Permits program was never approved by EPA into the state implementation plan (SIP).

The Audit Program will offer a covenant from civil enforcement by the federal government, for instances where companies with Flexible Permits operated outside of federal requirements provided that companies agree to and complete the proposed audit program. In addition, companies who enter the audit will no longer be subject to EPA's use of Title V tools for permits issued that do not contain all CAA requirements.

The Audit Program is available for 90 days after publication in the Federal Register. Participants who sign up in the first 45 days can take advantage of a reduced penalty incentive for potential violations.

Under the program, a third-party auditor will conduct an independent review of operations, modifications, and permitting activities that occurred since the issuance of the flexible permit, so that the federally-applicable requirements can be identified for a new permit. These independent findings would be directly transmitted to the company and EPA and used to establish new limits in state-issued permits. EPA anticipates the audit process to take about one year.

The Audit Program requires participants to obtain federally-approved state permits from the TCEQ. A company would enter into a Consent Agreement and Final Order with EPA based on the findings of the third-party audit. This audit program and CAFO would resolve any New Source Review non-compliance issues that occurred while operating with the Flexible Permit provided that the companies complete the audit program.

The federal audit program is one of two paths available for companies to transition their flexible permits to a permit that meets federal and state requirements. EPA is also inviting companies to contact the EPA Region 6 Compliance Assurance and Enforcement Division if they are interested in more direct negotiations with EPA that would result in federally-enforceable permits and resolution of non-compliance and Title V uncertainty.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and EH&S compliance auditing programs.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website

TCEQ New Source Review Program Rejected By EPA

U.S. Environmental Protection Agency (EPA) has issued formal disapproval of aspects of the Texas Commission on Environmental Quality’s (TCEQ) air emission permitting program that do not meet federal Clean Air Act requirements. EPA sought public comment on its proposed disapproval of New Source Review (NSR) program which was published in the Federal Register in September 2009 and considered comments in reaching its final decision.

EPA determined the revisions proposed by TCEQ’s New Source Review program did not meet federal Clean Air Act requirements. One example is the Pollution Control Project Standard Permit revision offered by TCEQ. The permit is designed to streamline permitting of changes within a plant but according to EPA lacked adequate review of impacts on total air pollution levels should the changes be approved.

In July 2009, the EPA and the Business Coalition for Clean Air (BCCA) Appeal Group, the Texas Association of Business, and the Texas Oil and Gas Association reached an agreement regarding the timing of federal review of regulatory changes to Texas’ air permitting program. EPA’s action is the latest in a series of actions under that agreement.

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