AWAIR Requirements - Minnesota OSHA

Since 1991, Minnesota OSHA has required many employers to develop and use "A Workplace Accident and Injury Reduction (AWAIR)" program. Employers engaged in certain specific industrial classification codes (NAICS codes) are required to develop and implement a written safety and health program with specific actions designed to reduce the incidence of workplace accidents and injuries.

An employer subject to these rules must establish a written AWAIR program that includes:

1. how managers, supervisors and employees are responsible for implementing the program and how continued participation of management will be established, measured and maintained;
2. the methods used to identify, analyze and control new or existing hazards, conditions and operations;
3. how the plan will be communicated to all affected employees so they are informed of work-related hazards and controls;
4. how workplace accidents will be investigated and corrective action implemented;
5. how safe work practices and rules will be enforced.

An employer must conduct and document a review of the workplace accident and injury reduction program at least annually and document how the procedures included in the program are being met.

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

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Tier I SPCC Plan - SPCC Template Plan

In 2008, US EPA finalized its streamlined SPCC Rule (40 CFR 112). The amended rule tailored the SPCC requirements for a subset of qualified facilities. The owner or operator of a qualified facility has the option to self-certify their SPCC Plan and comply with other streamlined requirements.

The final rule designated a subset of qualified facilities (“Tier I qualified facilities”) as those that meet the current criteria to self-certify their SPCC Plan and that have no oil storage containers with an individual aboveground storage capacity greater than 5,000 gallons. A Tier I qualified facility has the option to complete a self-certified SPCC Plan template instead of a full SPCC Plan. By completing the SPCC Plan template, an owner or operator of the facility will certify that the facility complies with a set of streamlined SPCC rule requirements. All other qualified facilities will be designated “Tier II qualified facilities.”

Caltha LLP assists facilities in complying with SPCC Rules, including several very cost effective options for Tier I Qualified Facilities to prepare their SPCC Plan Template. For futher information on SPCC services, go to:
SPCC - 40 CFR 112 Compliance Services

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

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Boiler MACT and Incineration Unit Proposed Rule

On April 29, 2010, the U.S. Environmental Protection Agency (EPA) published proposed two rules relating to hazardous air pollutant (HAP) emission standards for industrial, commercial and institutional boilers, process heaters(Boiler MACT rule), and commercial and industrial solid waste incineration units (CISWI rule). Industrial boilers and process heaters burn fuels such as natural gas, coal and oil to produce heat or electricity; CISWIs burn solid waste.

Section 112 of the Clean Air Act requires EPA to set emission standards for categories of major sources of HAPs. Major sources are those facilities that emit or have the potential to emit 10 tons per year of a single HAP or 25 tons per year of total HAPs. The 1990 CAA Amendments required those standards to be based on the Maximum Achievable Control Technology (MACT). EPA first finalized a set of Boiler MACT and CISWI rules in September 2004. In 2005, EPA reconsidered the rule package, modified a portion, and again published a final rule package. In June 2007, the D.C. Circuit Court of Appeals vacated the Boiler MACT and CISWI rules and ordered EPA to revise the rules.

The new proposed Boiler MACT rules set HAP standards for industrial, commercial and institutional boilers and process heaters at major source facilities. The proposed Boiler MACT rule is expected to reduce mercury and other organic air toxics, including dioxin emissions. The proposed rule package also includes HAP standards for boilers and process heaters at “area sources”, which are also known as “minor sources”; area source facilities may subject to MACT or Generally Available Control Technology (GACT).

The proposed CISWI rule sets New Source Performance Standards and emission guidelines for commercial and industrial solid waste incineration units. The proposed CISWI rule establishes emission limits for mercury, lead, cadmium, hydrogen chloride, particulate matter, carbon monoxide, dioxin/furans, nitrogen oxides and sulfur dioxide.

To determine whether a major source will be subject to the Boiler MACT rule or the CISWI rule, EPA has also proposed a definition of “non-hazardous solid waste.” The proposed definition could move some facilities out of the boiler category and into the CISWI category.

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
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Proposed Rule to Reduce Mercury Emissions From Boilers, Incinerators

The U.S. Environmental Protection Agency (EPA) is issuing proposals that would cut U.S. mercury emissions by more than half and would significantly cut other pollutants from boilers, process heaters and solid waste incinerators.

Combined, EPA estimates that these proposals would cut annual mercury emissions from about 200,000 industrial boilers process heaters and solid waste incinerators by more than 50 percent. Estimated annual costs of installing and operating pollution controls required under these rules would be $3.6 billion.

These actions cover emissions from two types of combustion units. The first type of unit, boilers and process heaters, burns fuel such as natural gas, coal, and oil to produce heat or electricity. These units can also burn non-hazardous secondary materials such as processed tires and used oil. Boilers are located at large industrial facilities and smaller facilities, including commercial buildings, hotels, and universities. The second type of unit, commercial and industrial solid waste incinerators, burns solid waste.

Large boilers and all incinerators would be required to meet emissions limits for mercury and other pollutants. Facilities with boilers would also be required to conduct energy audits to find cost effective ways to reduce fuel use and emissions. Smaller facilities, such as schools, with some of the smallest boilers, would not be included in these requirements, but they would be required to perform tune-ups every two years.

EPA is also proposing to identify which non-hazardous secondary materials would be considered solid waste and which would be considered fuel. This distinction would determine whether a material can be burned in a boiler or whether it must be burned in a solid waste incinerator. The agency is also soliciting comment on several other broader approaches that would identify additional non-hazardous secondary materials as solid waste when burned in combustion units.

EPA will take comment on these proposed rules for 45 days after they are published in the Federal Register. EPA will hold a public hearing on these rules soon after they are published 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

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

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New Chemicals Proposed for Toxic Release Inventory - TRI

U.S. Environmental Protection Agency (EPA) is proposing to add 16 chemicals to the Toxics Release Inventory (TRI) list of reportable chemicals. TRI is a publicly available EPA database that contains information on toxic chemical releases and waste management activities reported annually by certain industries as well as federal facilities.

Four of the chemicals are being proposed for addition to TRI under the polycyclic aromatic compounds (PACs) category. The PACs category includes chemicals that are persistent, bioaccumulative, toxic (PBT) and are likely to remain in the environment for a very long time. These chemicals are not readily destroyed and may build up or accumulate in body tissue.

The chemicals proposed for addition are:

• 1-Amino-2,4-dibromoanthraquinone
• 2,2-bis(Bromomethyl)-1,3-propanediol
• Furan
• Glycidol
• Isoprene
• Methyleugenol
• o-Nitroanisole
• Nitromethane
• Phenolphthalein
• Tetrafluoroethylene
• Tetranitromethane
• Vinyl Fluoride
• 1,6-Dinitropyrene
• 1,8-Dinitropyrene
• 6-Nitrochrysene
• 4-Nitropyrene
  

EPA is accepting public comments on the proposal for 60 days after it appears 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