Air Permit Engineer For Wisconsin Printing Business

Caltha LLP Project Summary

Project: Update To Air Permit Emission Tracking And Reporting
Client: Printing Operation
Location(s): Wisconsin

Key Elements: WDNR air permit, annual air emission inventory, VOC emission calculation

Overview: Caltha LLP has assisted this Wisconsin printing company with annual air emission inventory used for compliance reporting under the facility air emission permit issued by the Wisconsin Department of Natural Resources. This has included preparation of a site specific product usage and emission tracking workbook used by plant personnel to record monthly solvent usage and the resulting VOC emissions.

Caltha provides ad hoc training and technical support to plant staff on emission tracking and permit compliance.


Spray Booth Included In Facility
Wide Air Emission Permit

 

Caltha LLP | Your Air Permit, Wastewater Permit, 

Storm Water Permit Partner

Who Needs A WDNR Solid Waste or Hazardous Waste Licence?

In Wisconsin, the Wisconsin Department of Natural Resources requires certain businesses that handle solid wastes, hazardous wastes, recyclable materials and other special wastes to have a licence issued by WDNR. This licence is in addition to any requirements to obtain an EPA facility ID, notify WDNR of hazardous waste activities, or to obtain a RCRA permit, if needed. Licences are required for 1) transporters and waste haulers, and 2) certain facilities.

Unlicensed Solid Waste Dump Identified 

During A Site Inspection

Waste Transporters/Haulers Licence

Businesses would need a waste transportation license if they:

• transport more than 20 tons of solid waste during a year;
• transport hazardous waste from businesses or institutions (non-households); or
• transporting more than 50 pounds of infectious waste within any one calendar month.

Special requirements have been published for haulers of solid waste or recyclables, waste tire haulers, used oil transporters/handlers. Not all businesses need a state license to transport solid waste, recyclables, hazardous waste or infectious waste; solid waste/recyclable transportation license  and infectious waste transportation license exemptions are listed in DNR rules.

Facility Licence

A DNR license is required for a solid waste landfill. In most cases, a DNR license is required for a compost facility, processing facility, storage facility, woodburning facility, incinerator or transfer station. Facilities that treat, store or dispose of hazardous waste must be licensed by the DNR, unless the activity is specifically exempt from the licensing requirement.

Caltha LLP assists waste generators and handlers in Wisconsin in applying for hazardous waste generator licence, developing hazardous waste management programs, providing employee hazardous waste training and waste reduction / waste minimization consulting.

WI Rules Protecting CHMM, CSP, CIH Credentials

Wisconsin Senate Bill 132 was signed prohibiting the unauthorized use of certain professional credentials, including Certified Hazardous Material Manager, or CHMM. Unless a person is certified by the Institute of Hazardous Materials Management (IHMM), the law prohibits that person from using the title of Certified Dangerous Goods Professional (CDGP), Certified Hazardous Materials Manager (CHMM), or Certified Hazardous Materials Practitioner (CHMP). The new Wisconsin law also provides protections for those certified by the American Board of Health Physics, the American Board of Industrial Hygiene, the Board of Certified Safety Professionals, and the National Registry of Radiation Protection Technologists.

The new law also prohibits a business from representing that services provided are furnished by one of these certified professionals unless those services are provided by a certified person. A person is also prohibited from misleading or deceiving another person by the unauthorized use of a certification mark awarded by the U.S. Patent and Trademark Office.

The Wisconsin law considers a violation of these prohibitions an unfair method of competition in business or an unfair trade practice, and allows a person who suffers a monetary loss because of a violation to sue for twice the amount of the monetary loss and reasonable attorney fees. The law allows the Department of Agriculture, Trade and Consumer Protection to bring a court action for an injunction to restrain a violation of these prohibitions.

Caltha LLP provides services performed by Certified Hazardous Material Manager certified by the Institute of Hazardous Materials Management.


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

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

SPCC Plan Review | Five Year SPCC Plan Amendment

Caltha LLP Project Summary

Project: SPCC Plan 5-Year Review, Plan Update & Management Compliance Training
Client: Transportation Terminal
Location: Wisconsin

Key Elements: Regulatory compliance training, SPCC Plan

Overview: Caltha LLP was retained by this multimodal transportation terminal to conduct the five-year review of its Spill Prevention, Control & Countermeasure (SPCC) Plan. Under 40 CFR 112, SPCC Rule regulated facilities are required to conduct and document a review of their SPCC Plan at least every five years, independent of the requirement to keep the facility SPCC Plan updated to reflect changes at the facility. In conjunction with this review, Caltha staff provided ad hoc compliance training to selected facility staff on SPCC Rule requirements. Finally, Caltha prepared an updated facility SPCC Plan to reflect administrative changes at the facility.

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

Wisconsin Air Emission Reporting For Printing Operation

Caltha LLP Project Summary

Project: Air Emission Inventory Reporting Technical Support
Client: Printing Facility
Location(s): Wisconsin

Key Elements: Air emission inventory, Air permit compliance, Air emission tracking, Hazardous waste management

Overview: Caltha LLP was retained by this printing facility to assisting in preparing the air emission inventory report required by the Wisconsin DNR under their FESOP for VOC emitting equipment. Caltha staff reviewed operations and developed material usage tracking systems and monthly air emission estimate tracking sheets. The tracking system incorporated adjustments based on hazardous waste disposal records. This allowed the facility to comply with monthly recordkeeping requirements which were then available for annual air emission reporting using the WDNR on-line reporting system. Caltha provided training to facility staff on emission tracking procedures.

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

Wisconsin Air Emission Reports Due To WDNR By March 1, 2017

Air emission inventory submittals are due to the Wisconsin Department of Natural Resources by March 1, 2017. Submittals are made using the WDNR Air Reporting System (ARS). The Air Reporting System allows facilities to report annual air emissions on the Internet using web-based software.


For permitted facilities that cannot submit their emission estimates by March 1, an extension must be requested through the WDNR. Those facilities granted an extension have until March 17, 2017 to submit their emission inventory.




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

Tier II Hazardous Material Reporting in Wisconsin | When Are Tier 2 Reports Due?

EPCRA 302/311/312 reports (“Tier II Reports”) are due on an annual basis to the State and Local Emergency Planning Committee and local emergency response agencies, such as the fire department. The information provided is used in the evident of an emergency, such as a fire, to evaluate potential chemical and other hazards at the property, and to select appropriate protection equipment and fire fighting techniques. EPCRA reporting facilities disclose the types, quantities and locations of hazardous materials. Facilities also provide with Safety Data Sheets for each material.

There are separate reporting requirement for hazardous materials (any material that requires a Safety Data Sheet under OSHA rules) and Extremely Hazardous Substances (EHS) which are a specific chemicals listed by US EPA. A very common example of one such EHS is sulfuric acid.

When are Tier II reports due in Wisconsin?

The Tier 2 report is due March 1 of each year and is based on chemicals stored at your site during the previous calendar year. Reporting can be completed by using the Wisconsin Hazmat Online Planning and Reporting System.

Caltha LLP provides technical support to facilities in Wisconsin that submit reports under EPCRA 311 and EPCRA 312.

Click here for a summary of some recent changes to EPCRA Tier II reporting requirements

For more information or to request a quote go to:
Caltha LLP EH&S Compliance Support Services

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

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

Preparation Of Response To Request For Information From EPA Regarding NESHAP Compliance

Caltha LLP Project Summary

Project: Preparation of Technical Response To EPA Region V Request For Information
Client: Foam manufacturer
Location(s): Wisconsin

Key Elements: Air emission, NESHAP, Subpart OOOOOO

Overview: Caltha was retained by this manufacturer to contact State and EPA air compliance personnel and to prepare a response to a Request For Information sent by US EPA Region V. The issue involved compliance with a specific National Emission Standards for Hazardous Air Pollutants (NESHAP). EPA believed that the facility may have been subject to 40 CFR 63, Subpart OOOOO (6O) - Flexible Polyurethane Foam Production & Fabrication Area Sources. After reviewing site operations, it was determined that the facility was not subject to 6O. Documentation was prepared and submitted to EPA and the State. No further actions were required by the facility.

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

 

Wisconsin Prevention of Significant Deterioration For GHG Emissions Approved

In a final rule, US EPA has approved revisions to the Wisconsin State Implementation Plan (SIP), submitted by the Wisconsin Department of Natural Resources (WDNR) in 2011 and 2012. The revisions modify Wisconsin's Prevention of Significant Deterioration (PSD) program to establish emission thresholds for determining which new stationary sources and modification projects become subject to Wisconsin's PSD permitting requirements for their greenhouse gas (GHG) emissions. Additionally, these revisions defer until July 21, 2014, the application of the PSD permitting requirements to biogenic carbon dioxide (CO2) emissions from bioenergy and other biogenic stationary sources in the State of Wisconsin. EPA has made the preliminary determination that these revisions are in accordance with the Clean Air Act (CAA) and EPA regulations regarding PSD permitting for GHGs and is approving Wisconsin's revisions.

Caltha LLP provides specialized expertise to clients in Wisconsin and  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 
 

Reissue of PM2.5 Determination For Milwaukee-Racine, Wisconsin Area

EPA has proposed to determine that the Milwaukee-Racine, Wisconsin area had attained the 2006 24-hour fine particle (2006 PM2.5) National Ambient Air Quality Standard (NAAQS) and to more clearly explain EPA's interpretation on the applicability of CFR 51.1004(c) to the 2006 PM2.5 NAAQS.

As background, on April 24, 2012, EPA published a proposed determination that the Milwaukee-Racine, Wisconsin area had attained the 2006 PM2.5 NAAQS. EPA received comments on the original proposal suggesting that the suspension of certain Clean Air Act (CAA) requirements cannot be applied in this instance because it only pertains to the 1997 PM2.5 NAAQS and not to the 2006 PM2.5 NAAQS. As a result, EPA has reproposed portion of the original proposed determination to address this issue. EPA will address all comments received on the original proposal and the current reproposal in the Federal Register final notice. Comments must be received on or before January 28, 2013.

Caltha LLP provides specialized expertise to clients in Wisconsin and 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

Proposed Action On Wisconsin PM2.5 SIP

EPA is proposing to disapprove a revision to Wisconsin's State Implementation Plan (SIP) submitted by the Wisconsin Department of Natural Resources (WDNR) in a letter dated May 12, 2011. The revision concerns permitting requirements relating to particulate matter of less than 2.5 micrometers (PM2.5). EPA is proposing to disapprove the revisions because they do not meet the 2008 PM2.5 SIP requirements.

As background, in May 2008 EPA finalized regulations to implement the New Source Review (NSR) Implementation Rule for PM2.5 to include the major source threshold, significant emissions rate and offset ratios for PM2.5, interpollutant trading for offsets and applicability of NSR to PM2.5 precursors. On October 20, 2010, EPA amended the requirements for PM2.5 under the Prevention of Significant Deterioration (PSD) program by adding maximum allowable increase in ambient pollutant concentrations and screening tools known as the Significant Impact Levels and Significant Monitoring Concentration (SMC) for PM2.5.

On May 12, 2011, Wisconsin requested a revision to its SIP to include new permit requirements relating to PM2.5. The provisions were designed to match the requirements set forth in the May 2008 and October 2010 rules. The submittal included permanent rules to define major source thresholds and significant emission increase levels; establish the SMC for PM2.5; establish interpollutant trading ratios for PM2.5, sulfur dioxide (SO2) and nitrogen oxides (NOX); and clarify existing nonattainment area permitting rules.

On July 21, 2011, EPA announced a change in its policy concerning the development and adoption of interpollutant trading provisions for PM2.5. The new policy requires that any ratio involving PM2.5 precursors submitted to EPA for approval for use in a state's interpollutant offset program for PM2.5 nonattainment areas must be accompanied by a technical demonstration that shows the net air quality benefits of such a ratio for the PM2.5 nonattainment area in which it will be applied. In a letter dated March 5, 2012, WDNR requested to withdraw its request to have NR 408.06(1)(cm), the provision pertaining to interpollutant trading ratios, included in its 2011 submittal.

EPA has evaluated WDNR's proposed revisions to the Wisconsin SIP in accordance with the Federal requirements governing state permitting programs. EPA is proposing to disapprove these revisions because they do not meet all the requirements of the 2008 rules. According to EPA, Wisconsin's current SIP does not contain the explicit language to account for PM2.5 and PM10 condensables in permitting decisions, as codified in 51.166(b)(49)(vi) and 40 CFR 52.21(b)(50)(vi), and to date, the State has not made a submission with such revisions.

EPA is proposing to disapprove the revisions to Wisconsin rules NR 400, 404, 405, 406, 407, 408 and 484, submitted by the State on May 12, 2011, for approval into the SIP. The full or partial disapproval of a SIP revision triggers the requirement under section 110(c) that EPA promulgate a Federal Implementation Plan (FIP) no later than two years from the date of the disapproval unless the state corrects the deficiency, and the Administrator approves the plan or plan revision before the Administrator promulgates such FIP.

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

Spill Plan and Above Ground Tank Rules In Wisconsin

One of the most common questions Caltha receives from facilities in Wisconsin is “Can Wisconsin facilities self-certify their SPCC Plans?” and “Can my facility in Wisconsin use the SPCC Template format to comply with 40 CFR 112?”. The confusion regarding the self-certification of SPCC Plans in Wisconsin is due primarily to the overlapping Federal and State regulations involving aboveground storage tanks (AST).

Two rules can apply to facilities with above ground tanks, 1) Federal SPCC Rules (40 CFR 112), and 2) Wisconsin Rules on Storage of Flammable, Combustible and Hazardous Liquids (Chapter Comm 10). For any given facility, some tank systems may only be subject to SPCC Rules, some may only need to comply with Wisconsin Chapter Comm 10, and still other tanks may actually need to comply with both sets of rules.

There is a significant amount of over lap and similarity between the two rules; however, they differ in many aspects, included when a written spill plan is required and in situations where documents need to be prepared by and certified by a Wisconsin-licensed professional engineer. Whether or not a facility needs to use a PE to approve their plans will depend on a number of factors, including the size and location of their tanks, and the specific liquids being stored in them.

If you want further information on above ground tank rules and SPCC rule compliance in Wisconsin, email Caltha at info@calthacompany.com

Caltha LLP provides specialized expertise to clients in Wisconsin and 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

Court Upholds Wisconsin New Source Review Reforms

The Seventh Circuit Court of Appeals has upheld Wisconsin’s adoption of U.S. EPA’s Clean Air Act New Source Review (NSR) reforms. In 2006, Wisconsin adopted and incorporated the federal NSR reforms into its state implementation plan, which EPA approved in 2008. Shortly thereafter, environmental groups submitted to EPA a petition to reconsider its approval of Wisconsin’s NSR reforms. In January 2010, EPA denied the petition. The groups then filed petitions in the Seventh Circuit, seeking judicial review of EPA’s denial of their petition for reconsideration.

The three elements of the NSR reforms at issue were:
1. The use of the “actual-to-projected future actual” test to determine whether a stationary source modification will cause an increase in emissions that is large enough to trigger Prevention of Significant Deterioration (PSD) or Non-Attainment Area NSR permitting obligations.
2. A rule allowing permit applicants to select any 24-month consecutive period out of the last ten years of emissions data to establish a facility’s baseline emissions.
3. A rule allowing the use of a plantwide applicability limitation (PAL).

Throughout the case, environmental groups argued that these three elements could result in an overall increase in emissions from stationary sources in Wisconsin, contrary to anti-backsliding prohibitions in the Clean Air Act. The Seventh Circuit rejected these arguments in favor of the air modeling EPA conducted to provide technical support for its NSR reforms. However, the court did note that, at some point, air modeling will need to be replaced with actual data to demonstrate whether NSR reforms are or are not causing an increase in emissions. Also, EPA’s approval of Wisconsin’s NSR reforms does not relieve the state of its obligations to prevent emissions increases.

Caltha LLP provides specialized expertise to clients in Wisconsin and 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

Registration Of Water Withdrawals In Wisconsin Due June 30

The Wisconsin Department of Natural Resources (WDNR) has announced that industrial water users that exceed specific thresholds will need to register with the State by June 30, 2011. All industries that withdraw 100,000 gallons or more of water per day, or 70 gallons or more per minute, from any water source, are required to register with the WDNR. The registration requirement applies to both existing and new withdrawals from either surface or groundwater sources. This requirement also applies to industries that only make temporary withdrawals. Each property that meets the registration threshold must be registered separately

Registered withdrawals will need to measure or estimate the volume of water withdrawn every month and report that information to the WDNR each year by March 1. WDNR intends to send reminders of the annual reporting requirements and the process for submitting the information.

Caltha LLP provides specialized expertise to clients in Wisconsin and 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

Wisconsin Lead Renovation, Repair and Painting Rule

Beginning April 22, 2010, contractors nationwide who perform renovation activities in residential homes and child-occupied facilities built before 1978 must be certified and follow specific lead-safe work practices to prevent lead contamination.

While this new requirement will apply nationwide under the U.S. Environmental Protection Agency’s (EPA) 2008 Lead Renovation, Repair and Painting Rule, Wisconsin recently passed an emergency administrative rule adopting the EPA requirements at the state level. As a result, contractors performing renovation activities in Wisconsin will be required to obtain certification through the Wisconsin Department of Health Services (WDHS), instead of the EPA. Wisconsin is the first state to receive federal approval to enforce the new EPA standards at the state level. Wisconsin’s emergency rule is expected to be finalized April 2010.

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

WI DNR Environmental Compliance Audit Program

The State of Wisconsin has extended its program to encourage regulated entities within the State to conduct environmental compliance audits and to self-report non compliance issues. The program had been scheduled to sunset on July 1, 2009.

The Environmental Compliance Audit Program (section 299.85) provides enforcement relief to public or private sector regulated facilities if they:
1) Notify the Wisconsin Department of Natural Resources (WDNR) at least 30 days in advance of a scheduled environmental compliance audit;
2) Conduct the audit in accordance with WDNR requirements; and
3) Submit the audit report to WDNR within 45 days of completion.

If violations are found during the audit, the audit report would include a plan and schedule for corrective actions.

The WDNR would defer enforcement action for facilities that self report violations and meet their approved plan and schedule to come into compliance.

Caltha LLP provides specialized expertise to clients nationwide in the conducting environmental compliance audits, developing compliance procedures, and preparing cost-effective EH&S compliance management programs.

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