Environmental Review Compared to Environmental Site Assessment

Is Environmental Review the same as a “Phase I” or “Phase 1 Environmental Site Assessment”?

No; a Phase I ESA is not the same as “Environmental Review”. Environmental Review is usually much broader in scope. However, there can be some overlap – some environmental reviews might include some of the same inquiries and document reviews that would be included in a Phase I ESA.

Click here for more information on Environmental Review & Environmental Impact Assessment

Click here if you need more information on Phase I Environmental Assessment
Or click here if you need information on Small Business Administration (SBA) or HUD Phase I ESA requirements

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Cleveland Airport Targeted for Discharge Regulation

U.S. Environmental Protection Agency has proposed regulations requiring airports to collect at least some of the deicing fluid after it is used on aircrafts with a goal of cutting chemical discharge by 22%. The regulations would require six of the 14 major U.S. airports that are the biggest users of deicing fluid to install deicing pads or other collection systems to capture 60% of fluid sprayed and to install deicing pads or other collection systems. Some of the targeted airports include:

• New York's John F. Kennedy and LaGuardia airports,
• Chicago's O'Hare,
• Boston Logan International,
• Cleveland-Hopkins International, and
• New Jersey's Newark Liberty International

It would then be the airports' responsibility to ensure that the collected fluid was treated and handled in accordance with requirements. Some 200 smaller facilities around the US would have to collect 20 percent of the fluid by using technologies such as a glycol recovery vehicle, while airports with fewer than 1,000 yearly jet departures would not be impacted.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

SBA Environmental Assessment Requirements - Records Search With Risk Assessment

The Small Business Administration (SBA) procedures under SOP 50-10(5) Lender and Development Company Loan Programs under certain circumstances requires Lenders to conduct a Records Search with Risk Assessment (RSRA) in order to evaluate the likelihood of contamination at the Subject Property and neighboring properties. If the RSRA concludes that there exists a high risk for contamination, additional environmental investigation may be required.

Caltha LLP provides cost-effective Records Search with Risk Assessment (RSRA) services to SBA Lenders across Ohio.

To request a quote for a Records Search with Risk Assessment (RSRA), go to:

SBA Records Search with Risk Assessment Services

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

MSDS Requirements - Hazard Communication Changes

OSHA has proposed to modify its existing Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The proposed modifications to the standard include:

• revised criteria for classification of chemical hazards;
• revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements;
• a specified format for safety data sheets; and
• related revisions to definitions of terms used in the standard, requirements for employee training on labels and safety data sheets.

OSHA is also proposing to modify provisions of a number of other standards, including standards for flammable and combustible liquids, process safety management (PSM), and most substance-specific health standards, to ensure consistency with the modified HCS requirements. Written comments are due by December 29, 2009.

For more information on Caltha's services relating to chemical hazard assessment and product stewardship, go to:

Chemical Hazard Assessment, Product Stewardship & Product Compliance Services

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

SPCC 40 CFR 112 Compliance - SPCC Plan - SPCC Training

Caltha LLP provides technical support to facilities nationwide to comply with US EPA Spill Prevention, Control & Countermeasure (SPCC) Rules (40 CFR 112) and State-specific spill prevention, spill preparedness and spill reporting requirements. Caltha specializes in preparing SPCC Plans, including using the new SPCC Template Plan format.

Caltha provides SPCC Plan services in a number of flexible formats, ranging from turn-key services where we provide a complete SPCC Plan, to ad hoc technical guidance to facility or corporate staff as they prepare Plans and compliance programs. Caltha also provides technical support in developing and implementing SPCC Inspection programs, and in developing and presenting annual SPCC Training.

For information, go to:

SPCC 40 CFR 112 Compliance Services

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Ohio TRI Reports - Changes to Toxic Release Inventory Requirements

Toxics Release Inventory (TRI) reporting requirements were changed on March 11, 2009 as part of the Omnibus Appropriations Act of 2009. These changes affect TRI reports due July 1, 2009. The 2009 Omnibus Appropriations Act returned TRI reporting requirements back to the rules in effect prior to December 22, 2006.

The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals be submitted on "Form R,", which is the more detailed form. For all other chemicals the shorter form, “Form A” may be used only if the annual reporting amount is 500 pounds or less and that the chemical was manufactured, processed or otherwise used in an amount not exceeding 1 million pounds during the reporting year. EPA will issue a rule shortly revising the regulatory text in the Code of Federal Regulations to reflect these changes. TRI-ME software and other reporting assistance materials are also being revised.

As background, in December 2006 U.S. EPA revised the reporting requirements for releases of listed chemicals (commonly known as 313 chemicals) required under Section 313 of the Emergency Planning & Community Right-to-Know Act (EPCRA). The revisions made by EPA in 2006 related to the Forms used to report 313 chemical releases. Form R is typically used to report releases, and data submitted on Form R is released to the public. Form A is a streamlined reporting process, used for 313 chemicals released in smaller quantities. Data submitted on Form A is not released to the public. The revision made by U.S. EPA changed the thresholds for when Form A could be used. Form R could always be used to report data, even for small quantities.

The 2006 revision allowed some facilities to use a streamlined reporting process; chemicals reported using the streamlined process would not be included in facility TRI reports released to the public. In response, twelve States filed a law suit against U.S. EPA in November 2007. The suit claims that the revision prevented citizens and communities from having access to the critical information required under EPCRA.

The 2009 changes to TRI reporting only affects how TRI data are reported; it does not change the thresholds used to determine if a TRI report is required. This change only applies to TRI reporters with total releases less than 5,000 lbs/year. No revisions were made by U.S. EPA for reporting 313 chemicals that have releases greater than 5,000 lbs/year.


[Read more about recent changes to TRI reporting for auxiliary facilities]

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Pollution Prevention (P2) Grants - EPA P2 Grants for 2009

The Pollution Prevention Grant Program has recently announced the availability of Pollution Prevention (P2) Grants for 2009. The Pollution Prevention Grant Program supports State and Tribal technical assistance programs which in turn help businesses identify better environmental strategies and solutions for reducing or eliminating waste at the source. Grants will be awarded and managed by each of EPA's 10 Regional Pollution Prevention Program Offices.

The goal of the P2 Grant Program is to assist businesses in adopting P2 practices that reduce pollution at its source, including the conservation of water and energy. EPA is interested in supporting projects that reflect a comprehensive and coordinated approach toward implementing P2 practices on behalf of businesses within the State or Tribe.

P2 includes what is commonly called “in-process recycling,” but not “out-of-process recycling”. Some examples of P2 projects include equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control.

Grant proposals must be received by the applicable Regional P2 Program Coordinator no later than April 17, 2009.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

EPA P2 Plan - Draft Pollution Prevention Strategies

The US EPA Pollution Prevention (P2) Program is requesting comments on its draft strategic plan, "Promoting Pollution Prevention to Achieve Sustainability: A Strategic Plan for the US Environmental Protection Agency's Pollution Prevention Program , 2009-2014,"

This draft plan identifies a number of areas where EPA believes that enhanced collaboration and coordination among federal, state, tribal, and local partners would be beneficial. Examples include:

• Increasing policy and programmatic dialogue on sustainability, climate change, and other issues;


• Continuing to work together to address regulatory barriers to P2; and


• Developing unified national approaches to promote further environmental progress in specific sectors.

EPA is accepting written comments on this Draft Strategic Plan to through Tuesday, March 31, 2009.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address sustainability, pollution prevention and effective environmental management systems.

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

OH EPA Proposed Water Quality Standards and Antidegradation Rules

The Ohio Environmental Protection Agency (OEPA) is currently in the process of revising State Rules relating to Water Quality Standards and Antidegradation (Non-Degradation) Rules. The draft Rules are being published independently; however, because all the Rules are interrelated, OEPA has extended the public comment period.

The draft Rules applying to Antidegradation were released for comment near the end of 2008. Some of the key revisions being proposed include:

• The definition of “best available demonstrated control technology” (BADCT) is being updated to include new design criteria and effluent limits for nitrogen and phosphorus.


• Definitions for “designated uses”, “existing uses”, and “threatened species” are being removed since these definitions are located in the Water Quality Standards Rule.


• Definitions for “local and regional drainage pattern”, “loss of use”, “preferred alternative”, and “40 C.F.R.” are being added.


• The types of alternatives to be considered under the definitions for “minimal degradation alternative” and “non-degradation alternative” are being clarified.


• The definition of “regulated pollutant” is being revised to clarify that parameters include narrative and numeric water quality criteria and those limited by best professional judgment in a NPDES permit.


• The rule exemption in paragraph for net increases from existing sources is being clarified.
  Applications for Section 401 water quality certifications for wetlands will be exempt from the submital of alternatives analysis and social and economic justification information


• Section 401 water quality certifications impacting Lake Erie or its shoreline will be exempt from the mandatory public hearing


• New language is included regarding what constitutes the loss of a beneficial use.


• The set aside revision process for special high quality waters in is being clarified.


• The tables of special high quality waters are being updated.

The deadline for comments on the draft rule has not been determined yet. A draft rule addressing mitigation requirements or impacts on streams will be made available for review and comment in early 2009. Because the content of that rule relates to part of the antidegradation rule, the comment deadline for both rules will be 60 days after the stream mitigation rule is made available.

[Read more about water quality standards, aquatic toxicology, and site specific water quality standards]

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Great Lakes Inland Waters Beach Water Quality Standards

The Beaches Environmental Assessment and Coastal Health Act (“Beaches Act”) amended the Clean Water Act to address the special water quality concerns associated with the recreational uses of coastal waters. The Beaches Act requires US EPA to conduct studies concerning pathogen indicators in coastal recreation waters (Section 104(v)), and to publish new or revised water quality criteria for pathogens and pathogen indicators (Section 304(a)).

In response to the Beaches Act, US EPA adopted a Critical Path Science Plan (CPSP) for the new/revised criteria. The CPSP describes research and science for establishing the scientific foundation for new/revised criteria and outlines research to be completed by to publish new or revised criteria in 2012. The major CPSP research areas include:

• Epidemiology Studies and Quantitative Microbial Risk Assessment (QMRA)


• Site Characterization


• Indicators/Methods Development and Validation Modeling


• Application of Criteria to Inland Waters

Between now and 2010 EPA will be conducting additional research into indicators, methods, fate & transport studies, and predictive modeling. Between 2010 and 2012, work will begin on developing the new recreational water quality criteria. EPA plans to publish the water quality criteria in 2012.

[Read more about water quality standards, aquatic toxicology, and site specific water quality standards]

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

EPCRA TRI Change for Ohio Auxiliary Facilities

In 2007, EPA issued a final rule requiring that facilities reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), commonly called the toxics release inventory (TRI), identify the nature of their business by using North American Industry Classification System (NAICS) codes. Beginning with reports submitted 2007, NAICS codes replaced Standard Industrial Classification (SIC) codes that have been in use since TRI was initiated in 1987.

With one exception, the switch to NAICS did not affect facilities already required to report under TRI. No industry groups were added to or deleted from the list as a result of the change.

The exception involves businesses classified as "auxiliary facilities" which, under SIC, are those facilities that provide support functions for a manufacturing activity. For example, a distribution center operated by a paper products manufacturer was assigned the same SIC code as the manufacturing operation it supported. Under NAICS, the same distribution center would be assigned a code reflecting the warehousing and logistics operations.

Auxiliary facilities traditionally reported to TRI using the SIC code of the establishment they supported. NAICS did not adopt the SIC concept of auxiliary establishments. Under NAICS, these facilities now report their TRI according to their own activities.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

NEIWPCC Petitions EPA To Control Ohio Mercury Emissions

The New England Interstate Water Pollution Control Commission has petitioned that EPA regarding Section 319(g) of the Clean Water Act, which requires controls on air emissions of mercury. EPA is being asked to bring together a management conference with eleven States that contribute much of the mercury emissions that end up in water bodies in the Northeast.

The petition prepared by the New England Interstate Water Pollution Control Commission says that Ohio, Pennsylvania, Virginia, New Jersey, West Virginia, Maryland, Michigan, Indiana, Kentucky, North Carolina and Illinois each contribute significant nonpoint source mercury pollution that prevent them from meeting their goals.

The EPA approved a Northeastern regional mercury TMDL last year that the States beleive can only can be achieved through stricter federal air emission controls on mercury. Under Section 319(g) of the Clean Water Act, States can petition the EPA to bring together "a management conference of all states which contribute significant pollution resulting from nonpoint sources,".


Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

Ohio Environmental Consultant - EHS Consulting Services -

Caltha LLP provides expert technical consulting services to private and public sector clients across Ohio. For further information, click on links below:

Ohio (OEPA) Water Quality - NPDES Permitting Services
Ohio (OEPA) Stormwater Permit Compliance – Storm Water Permitting Services
Ohio SPCC – Spill Plan Services
Ohio Product Stewardship - Product Compliance Services
Ohio Haz Com – Hazard Communication Compliance Services
Ohio EHS Staffing - Contract Employee Services
Ohio Wastewater Compliance - NPDES Permitting Services

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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

GLI Water Quality Standards - Use of Secondary Values

The Water Quality Guidance for the Great Lakes System, also known as the Great Lake Initiative (40 CFR 132), promulgated ambient water quality criteria that applied to waters in the Great lakes basin. The methodologies used to calculate these water quality standards were essentially the same as those used by US EPA since 1994 to calculate National Water Quality Criterion, with the addition of several new types of standards, such as wildlife-based criteria.

[Read more about GLI Wildlife-based Water Quality Criteria]

A minimum data set is required to calculate water quality criteria for both National and GLI (“Tier I”) standards. However, the GLI did provide for methodology States could use to calculate standards for other chemicals which may not have enough data to fulfill these minimum requirements. The resulting standards are referred to as “Tier II” values, or “secondary” values.

Under the GLI, if all minimum data requirements for calculating Tier I are not met, a “safety factor” or “adjustment factor” is applied to the existing data to calculate a water quality standard. All the same requirements for test data acceptability apply equally to Tier I and Tier II standards.

Because the Tier II values use conservative adjustment factors and assumptions, and rely on a limited data set, standards derived using Tier II methodologies will typically result in much lower concentrations compared to Tier I standards.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

[Read more about water quality standards, aquatic toxicology, and site specific water quality standards]

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

Midwest CHMM Overview Seminar - EHS Regulatory Course

CHMM Overview Course for the Institute of Hazardous Material Managers (IHMM) Examination
April 22 – April 24, 2009
Bloomington, Minnesota

The North Star Chapter of the Academy of Certified Hazardous Materials Managers presents this CHMM Overview Workshop. The Regulatory / CHMM Overview Workshop provides a comprehensive overview of the major environmental, health & safety topics.

Course topics include:

• Federal Environmental Statutes Overview
• Environmental Liability and Compliance Overview
• Clean Water Act (CWA)
• Clean Air Act (CAA)
• Toxic Substances Control Act (TSCA)
• Comprehensive Environmental,Response, Compensation and Liability Act (CERCLA)
• Emergency Preparedness and Community Right-to-Know Act (SARA Title III - EPCRA)
• Chemistry of Hazardous Materials
• Toxicology Overview
• Geology Overview
• Radiation Principles for Hazardous Materials Managers
• Asbestos Overview
• Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
• Hazardous Materials Transportation
• OSHA Regulatory Overview
• Incident/Accident Response Overview
• Environmental Management Systems
• Environmental Considerations in Real Estate/ Due Diligence Assessments
• Underground Storage Tanks
• Resource Conservation & Recovery Act (RCRA)
• Waste Analysis Overview
• Hazardous Waste Treatment Technologies
• Waste Reduction/Minimization and Pollution Prevention
• Environmental Compliance Audits and Auditing
• Motivation of Employees with Respect to Environmental Matters
  

The full brochure for this workshop is available in .pdf format. Registration is also available online at the ACHMM-NSC web site: http://www.achmm-nsc.org/course.htm


Caltha LLP is pleased to support the North Star Chapter in presenting this valuable training course by providing volunteer instructors.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

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