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.
Monday, November 16, 2015
Sunday, December 15, 2013
RCRA and Universal Waste Annual Training For Minnesota Waste Generator
Caltha LLP Project Summary
Project: RCRA Hazardous Waste Generator and Universal Waste Generator TrainingClient: 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 PlantsClient: 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.
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 FacilitiesClient: 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)
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 ReviewClient: 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
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 InformationClient: 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
Environmental Compliance Audit For Iowa Food Ingredient Manufacturer
Caltha LLP Project Summary
Project: EHS Compliance Audit For Iowa Food Ingredient ManufacturerClient: Food Ingredient Manufacturer
Location(s): Iowa
Key Elements: Multi-media Compliance Audit
Overview:
Caltha was retained by this food ingredient manufacturer to conduct a multi-media compliance audit of its operations located in northwest Iowa. The operations were self certified as being in conformance with the Environmental Management System (EMS) requirements specified under ISO 14001. The audit was being conducted in advance of a planned merger and was required by the prospective business partner.
The scope of the compliance audit included applicable Federal, State and local regulations:
OSHA |
Hazard Communication |
EPCRA |
EPCRA 311-312 EPCRA 313 |
Hazardous and Solid Waste Management |
Federal RCRA rules |
Iowa waste rules |
|
Universal waste rules |
|
Air |
Federal air emission rules |
Federal NESHAP standards |
|
Iowa air emission permit |
|
Iowa air emission rules |
|
Clean Water Act |
Authorized/Unauthorized Discharges |
Iowa Stormwater Discharge Permit compliance |
|
SPCC Rule Compliance |
|
Iowa Spill Notification and Reporting |
|
Federal Industrial pretreatment rules |
|
Local Industrial discharger permit compliance |
|
TSCA |
Current registration |
Inventory Update Rule IUR Reporting |
|
Chemical Data Rule CDR Reporting |
|
Tanks |
Iowa aboveground tank rules |
Iowa underground tank rules |
The audit was completed under attorney client privilege through external legal counsel.
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
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