What Industrial Sector SIC Needs SPCC Plan?

What Types of Industries or SIC Codes Need an SPCC Plan?

Answer: SPCC Rules (40 CFR 112) apply to all types of sites. The rules can apply to industrial sites, commercial and retail sites, offices, restaurants, hotels, construction sites, municipal properties, and even farms.

Whether or not the SPCC Rule applies depends on the amount of regulated oil and fat storage capacity on-site, regardless of the type or use.

For more information on Caltha's SPCC services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

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

Universal Waste Rule - Pharmaceutical Wastes

US EPA has proposed to add hazardous pharmaceutical wastes to the Universal Waste Rule in order to provide a system for disposing hazardous pharmaceutical wastes that is protective of public health and the environment. The proposed addition will make it easier for generators to collect and properly dispose of these items as hazardous wastes, resulting in a simpler and more streamlined waste management system.

The proposed rule applies to:

• pharmacies,
• hospitals,
• physicians’ offices,
• dentists’ offices,
• outpatient care centers,
• ambulatory health care services,
• residential care facilities,
• veterinary clinics, and
• other facilities that generate hazardous pharmaceutical wastes.

The proposed rule also encourages generators to dispose of non-hazardous pharmaceutical waste as universal waste. The addition of hazardous pharmaceutical waste to the Universal Waste Rule will facilitate the collection of personal medications from the public at various facilities so that they can be more properly managed.

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

Compliance Status Report Due For Plating and Polishing Operations

On or before July 1, 2010, plating facilities subject to the plating or polishing operations National Emission Standards for Hazardous Air Pollutants (NESHAP) will have to submit their Notification of Compliance Status. In 2008, EPA published the NESHAP for Plating and Polishing Operations, which impacted many metal finishing operations, including facilities with plating, polishing or thermal spray processes that contain cadmium, nickel, lead, manganese and/or chromium.

The rule specifies several notification, recordkeeping and reporting requirements:
• Submit an Initial Notification by Oct. 29, 2008.
• Submit a Notification of Compliance Status by July 1, 2010 for existing processes, or at startup for new processes.
• Submit an annual compliance certification and,
• Submit an annual deviations report, if applicable.

EPA did not establish emission limits for plating and polishing operations, but required plating and polishing facilities to follow management practices as the generally available control technology (GACT) standards. The rule requires owners or operators of affected plating and polishing operations to demonstrate continuous compliance by adhering to the management and pollution prevention practices specified in the rule, and by maintaining the appropriate records to document their compliance.

Caltha LLP provides specialized expertise to clients nationwide in the preparation of regulatory reporting documents, developing EH&S compliance procedures, and preparing cost-effective compliance management programs.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website

TSCA Inventory Update Rule IUR For 2010

On January 1, 2010, a new TSCA Inventory Update Rule (IUR) reporting year began. Although reports will not be submitted until 2011, manufacturers and importers need to be collecting the necessary data to be able to submit their IUR report for 2010.

Every five years, companies that either manufacture or import chemicals or mixtures of chemicals on the “TSCA List” must report their activities. The reporting requirement, referred to as the “Inventory Update Rule”, or IUR, is only one of several requirements in the Toxic Substances Control Act (TSCA) enacted in 1985. The IUR requirements are the most broadly applicable of all the TSCA requirements.

For more information on the IUR, including a flow chart to determine if the Rule applies to your operations, go to:

TSCA Inventory Update Rule Regulatory Briefing

Caltha LLP provides specialized expertise to clients nationwide in the development of straighforward TSCA IUR tracking procedures and preparing TSCA IUR reports.

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

TRI Reporting Obligations for Metal Mining Activities

The Toxics Release Inventory (TRI) currently requires reporting from metal mining facilities if they manufacture or process 25,000 pounds or more of a listed chemical or otherwise use 10,000 pounds or more of a listed chemical.

EPA had considered naturally occurring materials to be "manufactured" by natural processes. A recent court order set aside EPA's interpretation of manufacture in the context of mining, concluding that naturally occurring ores in situ have not been manufactured within the meaning of Emergency Planning and Community Right to Know Act (EPCRA) section 313. EPA is currently considering clarifying how the definitions of manufacturing and processing under EPCRA section 313 apply to the mining sector processes of extraction and beneficiation. According to EPA, this action will not affect the coal extraction activities exemption. EPA anticipates that their revised guidance on application of TRI report to mining activities will be completed by February 2011.

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

Changes To TRI 313 Reporting Requirements

Over the past two years, several changes have been made to the reporting requirements under EPCRA 313 - or commonly referred to as Toxic Release Inventory (TRI) reporting. Depending on the amounts of 313 chemicals processed or "otherwise used" at a facility, a TRI report may be required.

Links to relevant amendments to TRI reporting requirements:

Use of NAICS codes, instead of SIC codes to determine applicability

Changes to reporting Persistent, Bioaccumulative and Toxic Chemicals (PBT) on Form R Reports

Proposed additional chemicals to list of 313 chemicals subject to TRI report

EPA Clarification of Article Excemption Under EPCRA Section 313

Caltha LLP provides specialized expertise to clients nationwide in the determine TRI reporting requirements, developing 313 chemical tracking procedures, and preparing Toxic Release Inventory reports.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website

Solvent Contaminated Materials - Proposed Rule Change

EPA has extended the comment period for a rule initially proposed in 2003 regarding hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA) for certain solvent-contaminated materials.

EPA proposed to modify its hazardous waste management regulations under the Resource Conservation and Recovery Act for materials such as reusable shop towels, rags, disposable wipes and paper towels. Specifically, EPA proposed to:

• Conditionally exclude from the definition of hazardous waste disposable industrial wipes that are contaminated with hazardous solvents and are going to disposal and,
• Conditionally exclude from the definition of solid waste reusable industrial shop towels and rags that are contaminated with hazardous solvents and are sent for laundering or dry cleaning.

The proposal affects contaminated industrial wipes being sent to both landfill and non-landfill (e.g., laundries and combustion) facilities and is applicable to industrial wipes exhibiting a hazardous characteristic (i.e., ignitability, corrosivity, reactivity, or toxicity) due to use with solvents; or industrial wipes contaminated with F001-F005 spent F-listed solvents or comparable P- and U-listed commercial chemical products that are spilled and cleaned up with industrial wipes.

The proposed rule amendment would resolve, at the federal level, long-standing issues associated with the management of solvent-contaminated industrial wipes by:

• Facilitating pollution prevention and waste minimization opportunities, including the recycling of the spent solvents extracted from contaminated industrial wipes;
• Fostering improved solvents management by generators and handling facilities;
• Reducing compliance costs;
• Increasing consistency in the regulations governing solvent-contaminated industrial wipes across the United States;
• Clarifying existing federal rules; and
• Creating flexibility for generators to work with industrial laundries, as appropriate, to ensure compliance with local pretreatment standards established by Publicly Owned Treatment Works (POTWs).
  

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