New Categories For Air Permit Exemptions Proposed

Minnesota Pollution Control Agency (MPCA) is proposing to adopt amended air quality rules within “exempt source/conditionally insignificant activities rules” to clarify permit requirements for small sources of air emissions and update rules governing the treatment of small air pollution emitting activities (“insignificant activities” and “conditionally insignificant activities”). Written comments on the proposed rules are being accepted until May 29, 2018.

Permitted Dust Control System

Changes create four new categories of conditionally exempt stationary sources where emissions primarily come from one type of activity; auto-body refinishing facilities, coating facilities, woodworking facilities, and insignificant facilities that meet applicable technical standard would be exempt from obtaining an air emissions permit. Changes to the existing categories of conditionally exempt sources, gasoline service stations and concrete manufacturing, are made to align with the rule structure for the new categories.

Caltha LLP | Your Air Permitting Partner

REACH, ROHS, Prop 65 and Other Chemical Compliance Certifications

Caltha LLP Project Summary

Project: Certification of REACH, ROHS, Prop 65, Conflict Minerals, Biocidal Products Compliance
Client: Component Manufacturer 
Location(s): Minnesota

Key Elements: EU Chemical Regulations, California Proposition 65 Labeling, Conflict Minerals Compliance Certifiaction

Overview: Caltha LLP was retained by this component manufacturer to compile compliance documentation and to prepare Certification of Compliance. Certification of compliance was required by customers who purchased manufactured components and incorporated them into their final products which were exported to the European Union and other areas.

Caltha prepared a certification form and background information to be completed by raw material suppliers that allowed each supplier to provide an informed certification statement regarding presence/absence of regulated chemical substances, and if present, documentation that concentrations are below regulatory thresholds.

Comments On Repeal Of Carbon Pollution Rule Due April 28

The public comment period on the EPA Proposed Rule "Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units" is scheduled to close on April 28, 2018.

As background, on October 16, 2017, the Environmental Protection Agency published an announcement of its intention to repeal the Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, commonly referred to as the Clean Power Plan, as promulgated on October 23, 2015. The proposal also requested public comment on the proposed rule. The EPA held public hearings on November 28 and 29, 2017, in Charleston, West Virginia, and extended the public comment period until January 16, 2018.

In response to numerous requests for additional opportunities for the public to provide oral testimony on the proposed rule in more than one location, EPA announced that three listening sessions will be held:

Wednesday, February 21, 2018 - Kansas City, Missouri;
Wednesday, February 28, 2018 - San Francisco, California;
Tuesday, March 27, 2018 - Gillette, Wyoming.

EPA also reopened the public comment period until April 26, 2018.


Caltha LLP | Your Air Permit, Wastewater Permit,
Storm Water Permit Partner

Overview of Management Systems Used By EHS Professionals

Overview of Management Systems For EHS Professionals

Click on link above to download presentation slides from " Environmental and Safety Management Systems For EHS Professionals"

Wastewater Permit And Compliance Overview

Overview of Clean Water Act 



Click link above to download presentation slides.



Overview of the Clean Water Act and underlying programs. Clean Water Act; CWA; wastewater; NPDES; pretreatment permit; water quality standards; permit limits; effluent guidelines; effluent standards; waters of the US, water quality criteria, SPCC rule

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

Is Hazardous Waste Allowed In City Sewer?

FAQ: Is It Legal To Discharge Hazardous Waste Into Sewer?

Possibly, if certain conditions are met.

The Clean Water Act (CWA) Pretreatment Program regulations require that Industrial Users (IUs) report any substance discharged to the Publicly Owned Treatment Works (POTW) which, if otherwise disposed of, would be considered a Resource Conservation and Recovery Act (RCRA) hazardous waste. Under RCRA’s Domestic Sewage Exclusion (DSE), any mixture of domestic sewage and other wastes that passes through a sewer system to a POTW is not considered a hazardous waste for the purposes of RCRA.

However, reporting of such discharges are regulated under the CWA as follows:

• 40 CFR 403.12(p) requires a one-time report for each substance discharged to a POTW that, if otherwise disposed of, would be considered RCRA hazardous waste.
• 40 CFR 403.12(j) requires a report in advance of any substantial change in volume or character of any IU discharge.

Who Must Submit Notification of Hazardous Waste Discharge?

All IUs that discharge a substance that, if otherwise disposed of, would be characteristic or listed wastes under 40 CFR Part 261 and meet the following criteria:

• Total waste discharged is greater than or equal to 15 kg/month; or
• Waste discharged is acute hazardous waste.

Where Does Notification Need To Be Sent?

If notification of hazardous waste discharge is required, it needs to be submitted to:

1. Local Sewerage Authority(i.e., POTW)
2. EPA Regional Waste Management Director, and
3. State Hazardous Waste Authority

What Does Notification Need To Include?

The notification must contain:

For hazardous wastes ≥ 15 kg/month or any quantity of acute, the one-time notification from an IU to a POTW must contain:

1. Name of the hazardous waste as set forth in 40 CFR Part 261.
2. EPA hazardous waste number (code).
3. Type of discharge to the sewer (continuous, batch, or other).
4. A certification that the IU has a program in place to reduce the volume and toxicity of hazardous wastes generated to the degree it has determined to be economically practical.

If the IU discharges more than 100 kg of acute or non-acute hazardous waste per calendar month to the POTW, the notification must also contain the following items of information, to the extent such information is known and available:

• An identification of the hazardous constituents contained in the hazardous wastes.
• An estimation of the mass and concentration of such constituents in the waste stream discharged during the calendar month in which the one-time report is made.
• An estimation of the mass of constituents in the wastestream expected to be discharged during the 12 months following the notification.

Common Questions Regarding Notification Of Hazardous Waste Discharge To City Sewer

 

Caltha LLP | Your Air Permit, Wastewater Permit, 

Storm Water Permit Partner