Multimedia Compliance Audits, Management System Audits, EHS Audits

Brief project summaries for consulting work completed by Caltha LLP. Project summaries archived here include compliance audits, multimedia audits, regulatory program audits, including air rule audits, hazardous waste - RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits, audit training and others.


Click here to see a summary of projects completed by Caltha LLP related to compliance audits, multimedia audits, regulatory program audits, air rule audits, hazardous waste, RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits.

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

Hazardous Waste Generator Improvements Rule

Hazardous Waste Generator Improvements Rule proposes an update to the hazardous waste generator regulations to make the rules easier to understand, facilitate better compliance, provide greater flexibility in how hazardous waste is managed, and close important gaps in the regulations.

Two key provisions where EPA is proposing flexibility are:
1.Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed and
2.Allowing a conditionally exempt small quantity generator (CESQG) to send its hazardous waste to a large quantity generator under control of the same person.

In addition to proposing key flexibilities, the rule will enhance the safety of facilities, employees, and the general public by improving hazardous waste risk communication and ensuring that emergency management requirements meet today’s needs.

EPA is also proposing a number clarifications without increasing burden including a reorganization of the hazardous waste generator regulations so that all of the generator regulations are in one place

Recent Changes to Comment Period


UPDATE:
This rule was finalized on October 28, 2016. Click here is review a summary of the final Hazardous Waste Generator Improvement rule and information on which States and other areas will be affect immediately.


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

Tier 2 Reporting Under EPCRA 311 and 312 and Local Hazardous Material Reporting Regulations

With the end of the year approaching, many facilities will soon be reviewing the hazardous chemicals they store on-site to determine if they exceed the thresholds for Tier 2 reporting under EPCRA 312 (40 CFR 370) and equivalent State regulations. Local emergency response agencies can have additional hazardous chemical reporting requirements, in addition to Tier 2 reports.

The EPA rules that determine reporting requirements set out two options for determining thresholds.

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

Click here to review example Caltha projects for EPCRA and other compliance reporting support.

RCRA and Universal Waste Annual Training For Minnesota Waste Generator

Caltha LLP Project Summary

Project: RCRA Hazardous Waste Generator and Universal Waste Generator Training
Client: International Chemical Products Manufacturer
Location(s): Minnesota

Key Elements: RCRA training, Universal waste training

Overview: Caltha prepared and presented training to facility staff and to on-site contractors who were responsible for generation of hazardous wastes and universal wastes at this site located in Minneapolis, Minnesota. Training was conducted to comply with Federal, state and county hazard waste rules, including:
40 CFR Part 260-262 – Hazardous Waste Management
40 CFR Part 273 – Standards for the Management of Universal Wastes
40 CFR Part 279 – Standards for the Management of Used Oil
Minnesota Rules Chapter 7045: Hazardous Waste Rules
Minnesota Rules Chapter 7035: Solid Waste

Training was provided at the facility and included a summary of regulatory requirements, and site-specific procedures for handling wastes generated at the site. Training also including a summary of the site Contingency Plan, spill prevention and related emergency preparedness and response procedures.



For more information on Caltha LLP EH&S training services, go to the Caltha Employer's EH&S Training Center.



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 

 

Regulatory Compliance Audit and Due Diligence For Minnesota and North Dakota Food Manufacturing Plants

Caltha LLP Project Summary

Project: Compliance Audit and Environmental Due Diligence For Minnesota and North Dakota Food Manufacturing Plants
Client: International Food Manufacturing Industry
Location(s): Minnesota and North Dakota

Key Elements: Environmental Compliance Audit, Phase 1 Environmental Site Assessment

Overview: Caltha was retained by this multinational food manufacturer to conduct an environmental regulatory compliance audit and a Phase I ESA at two of its plants located near Minneapolis, Minnesota and near Bismarck, North Dakota. Compliance audits were conducted to assess compliance with EPA, Minnesota Pollution Control Agency (MPCA), and Hennepin County requirements in Minnesota, and EPA and North Dakota Department of Health (NDDH) requirements in North Dakota. Regulatory requirements evaluated included:

• Clean Air Act,
• Clean Water Act,
• RCRA hazardous waste and solid waste requirements,
• Emergency Preparedness and Community Right-to-know Act (EPCRA) requirements,
• Toxic Substance Control Act,
• Above and underground tank requirements,
• OSHA Hazard Communication.

Caltha also completed a Phase I Environmental Site Assessment (ESA) for both sites, in accordance with ASTM E1527-05.



For more information on Caltha LLP services, go to the Caltha Audit 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 

 

RCRA and TSCA Compliance Audit For Multiple Facilities To Meet ISO 14001 Requirements

Caltha LLP Project Summary

Project: Combined RCRA and TSCA PCB Management Audit For 26 Facilities
Client: Electric Utility
Location(s): 26 locations

Key Elements: RCRA hazardous waste audit, TSCA PCB management, Used oil management, Universal waste management, ISO 14001

Overview: Caltha was retained to conduct a compliance audit of 26 facilities to assess compliance with:

• EPA hazardous waste rules (40 CFR Part 260-262)
• Minnesota hazardous waste rules (MPCA Chapter 7045)
• North Dakota hazardous waste rules
• Federal and State requirements for used oil management (40 CFR Part 279)
• Federal and State requirements for universal waste management (40 CFR Part 273)
• EPA Toxic Substances Control Act (TSCA) requirements for PBC management (40 CFR Part 261)

Audits were conducted to satisfy ISO 14001 standards for scheduled audits, under ISO 14001 clause 4.5.2.1. Audits were completed with a combination of records review and on-site inspections.



For more information on Caltha LLP auditing services, go to the Caltha Compliance and EMS SMS Audit 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 

 

Air Permit Compliance Assessment and Option D Registration Permit Source Review

Caltha LLP Project Summary

Project: Air Permit Compliance Audit and Registration Permit Tracking Review

Client: International Beverage and Food Product Company

Location(s): Minnesota

Key Elements: Air Emission Reporting Review, Air Emission Inventory, Permit Compliance Assessment

Overview: This facility retained Caltha to conduct a review of air permit compliance with the MPCA Option D Registration Permit. The review was prompted by recent staff turn-over at the facility and an impeding multi-media audit being conducted by the corporate group. Facility management wanted to assure that all applicable air emission sources were permitted, emission tracking systems were accurate and complete, and that new staff responsible for on-going permit compliance activities were provided with ”on-the-job” training .

Caltha staff conducted on on-site inspection of the facility to identify all equipment and processes which were subject to air emission permitting. Emission tracking records and calculation spreadsheets were reviewed to confirm that all applicable emission sources were included and that calculations were accurate. Some revisions to spreadsheets were required. Caltha staff then provided training to facility staff on new tracking procedures.

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