February 17, 2013

OEPA Issues New Industrial Storm Water Permit For Marinas

The Ohio Environmental Protection Agency (OEPA) has issued an industrial stormwater discharge permit specifically to cover marinas which would otherwise need to apply for coverage under the Ohio multisector general permit (MSGP). Marinas nationwide are subject to industrial stormwater under the Transportation Sector. OEPA under General Permit No. OHRM00002 became effective on January 22, 2013. Marinas that wish to be covered under this permit are required to submit an application (“Notice of Intent, or NOI”) to OEPA.

Compliance requirements under the Marina general permit are similar in many ways to the Ohio MSGP, including:
  • Requirement to prepare and implement a stormwater pollution prevention plan (SWPPP) meeting the requirements listed in the permit
  • Requirement to eliminate non-stormwater discharges
  • Requirement to conduct regular facility inspections
  • Requirement to develop and implement an employee training program
  • Requirement to conduct regular visual monitoring of stormwater discharges.
Read a summary of the Ohio Multisector General Permit

There are some important differences also:
  • Marinas are allowed to discharge wash water from boat cleaning, although cleaning of engines or other oily parts is prohibited; use of detergents or other chemical cleaning agents is prohibited.
  • Larger marinas (greater than 200 total slips) must conduct chemical monitoring of stormwater discharges on an annual basis.
Read a summary of Ohio general permit monitoring requirements for marinas

Read about Caltha’s new SWPPP Template and Compliance Plan Template for the Ohio marina general permit


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

December 26, 2012

Salt Storage Guidelines and Permit Requirements Issued By Ohio EPA

Ohio EPA has released a guidance document on the elements of salt storage that are relevant to preventing contamination include siting, design, and operation. The document provides guidance on salt storage practices to prevent the contamination of ground water and surface water. “Salt”, as used here, includes solids such as the popular sodium chloride (NaCl), as well as potassium chloride (KCl), calcium chloride (CaCl2), and magnesium chloride (MgCl2). It also includes mixtures of the same substances with abrasives such as sand, cinder, slag, etc.

Recently, several salt storage operations have been identified by Ohio EPA as the source of high chlorides in public or private ground water supplies. While Ohio has no rules specifically governing the storage of salt, ORC 6111 prohibits unauthorized discharge of pollutants to waters of the state, including runoff from salt storage. Ohio EPA considers brine created from rainfall passing through salt piles to be an industrial wastewater that is subject to permitting requirements. For a new salt storage site, Ohio EPA’s Division of Surface Water (DSW) can require a permit-to-install (PTI) to ensure adequate protection of water quality resources. When complaint investigations or routine audits for existing facilities indicate impacts to water resources due to poor management practices, DSW can take action to address any problems identified. Storm water permitting requirements pursuant to 40 CFR 122.26 and OAC 3745-39 must be met, as well as any local zoning requirements. For salt piles in designated urban areas, best management practices can be required under a Municipal Separate Storm Sewer System Permit (MS4), although there are no specific siting or design criteria. For salt stored at an industrial site, the Industrial Multi-Sector General Storm Water Permit would apply and would require the salt to be properly covered/enclosed. Ohio EPA-DSW can require a National Pollutant Discharge Elimination System (NPDES) permit for any site, regardless of location, if it is aware of pollution. Additionally, characterization and abatement of a release from a salt facility can be required under ORC 6111.04.

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

October 1, 2012

Lake Erie Great Lakes Restoration Initiative Grants Awarded To Ohio

The U.S. Environmental Protection Agency has awarded Great Lakes Restoration Initiative grants for projects in Ohio to improve water quality and reduce excess nutrients that contribute to harmful algal blooms in Lake Erie and to to reduce nutrients in the Lake Erie basin. The Lake Erie projects awarded are:
  • $780,745 to the Ohio Environmental Protection Agency for a Lucas County Stormwater Demonstration Project: This project expands ongoing efforts to improve urban stormwater management throughout the Ohio portion of the Lake Erie watershed. This project will demonstrate the use of green infrastructure (bioswales, pervious pavement, community rain gardens and bio-retention cells) at nine highly visible locations and assess the effectiveness of these measures to reduce nutrient and sediment loads in the Maumee River watershed.
  • $414,765 to the Nature Conservancy for Nutrient Reduction in the South Findlay Area of the Upper Blanchard Watershed: The project will reduce nutrient loading to the Upper Blanchard River Watershed, south of Findlay, Ohio, through the use of two-stage ditches, buffer strips and cropping systems which will filter nutrients and trap sediment. This project is expected to prevent 1,644 tons of sediment, 5,647 pounds of nitrogen and 3,406 pounds of phosphorus from reaching Lake Erie during the first three years after the erosion control measures are implemented.
  • $472,491 to the University of Toledo for Reduction in Nutrient, Sediment and Bacterial Loading in Maumee Bay State Park: The project will make Maumee State Park Beach safer by reducing bacteria, sediment and nutrient loading from Wolf Creek. A bed-load sediment collector and a sedimentation pond will be installed adjacent to Wolf Creek. A wetland will also be constructed to restore riparian habitat.
  • $527,152 to the Ohio Environmental Protection Agency for a Powell Creek Nutrient Reduction Project: This project will implement nutrient reduction practices recommended in the approved Total Maximum Daily Load for Powell Creek within the Maumee River basin and demonstrate the environmental benefits of targeting nutrient reduction actions in small geographical areas. These practices include replacing failing septic systems, planting 3,600 acres of cover crops, managing controlled drainage on 320 acres, and restoring or installing 20 acres of wetlands. This project is expected to prevent 9,077 pounds of nitrogen, 2,586 pounds of phosphorous and 908 tons of sediment from reaching Lake Erie each year.
  • $193,923 to The Ohio State University to Increase Nutrient Management Plan Expertise in the Blanchard Watershed: The project will increase the technical skills of agricultural professionals working in the Blanchard River watershed in Ohio, particularly pertaining to the development of Nutrient Management Plans (NMPs) for farms. NMP implementation will be focused on fields with the greatest potential to address dissolved reactive phosphorus loading in the Blanchard Watershed.

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

September 9, 2012

Proposed Changes To Training For Water and Wastewater Treatment Plant Operators

The Ohio EPA has proposed rules that will eventually allow a third party provider to sponsor and administer certifications exams for Water and Wastewater treatment plant operators. By using the third party, Ohio EPA hopes to provide examinations more often, in more locations throughout the state, using computer based testing. The Agency also believes that by using the third party, the pool of questions will expand and the third party will be responsible for verifying the validity of those test questions.

The cost of the third party administration may be passed on to applicants in the form of higher fees. In the interim, State-Sponsored exams will continue to be held twice per year in order to give operators the choice of the computerized approved exam-provider or the additional state examination. The Ohio EPA hopes to eventually eliminate the state sponsored exam and rely solely on the examinations provided by the approved exam provider.

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

May 30, 2012

Brownfields Grants To Investigation and Cleanup Ohio Sites

The U.S. Environmental Protection Agency (EPA) has announced $2.8 million in grants to redevelop contaminated properties, create jobs and protect public health in Ohio. These “brownfield grants” are used to assess and clean up abandoned industrial and commercial properties.
The Ohio brownfield grants were distributed as follows:
  • Lockland, Site Assessment, Hazardous Substances, $200,000
  • Lorain Port Authority, Site Assessment, $400,000
  • Newark, Site Assessment, Hazardous Substances, $200,000
  • Northeast Ohio Four County Regional Planning & Development Organization, Site Assessment, $600,000
  • Ottawa County, Site Assessment, $400,000
  • Toledo, Site Assessment, $800,000
  • Vinton Baptist Church, Cleanup, Field of Hope Community Campus, $200,000
The Ohio grants are part of the EPA’s $69.3 million 2012 nationwide brownfields grants to clean up and redevelop contaminated properties, boost local economies, create jobs and protect public health.

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

May 15, 2012

Use of Diesel Fuel In Fracking Operations

US EPA has released draft underground injection control (UIC) program permitting guidance for Class II wells that use diesel fuels during hydraulic fracturing activities. EPA developed the draft guidance to clarify how companies can comply with a law passed by Congress in 2005, which exempted hydraulic fracturing operations from the requirement to obtain a UIC permit, except in cases where diesel fuel is used as a fracturing fluid.

The draft guidance outlines for EPA permit writers, where EPA is the permitting authority, requirements for diesel fuels used for hydraulic fracturing wells, technical recommendations for permitting those wells, and a description of diesel fuels for EPA underground injection control permitting. The draft guidance describes diesel fuels for these purposes by reference to six chemical abstract services registry numbers. The agency is requesting input on this description.

According to EPA, while this guidance undergoes public notice and comment, decisions about permitting hydraulic fracturing operations that use diesel fuels will be made on a case-by-case basis, considering the facts and circumstances of the specific injection activity and applicable statutes, regulations, and case law, and will not cite this draft guidance as a basis for decision. EPA will take public comment on the draft guidance for 60 days upon publication in the Federal Register to allow for stakeholder input before it is finalized.

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

February 29, 2012

Proposed GHG Prevention of Significant Deterioration Rule

U.S. Environmental Protection Agency (EPA) is proposing not to change the greenhouse gas (GHG) permitting thresholds for the Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs, and also proposing steps the agency believes would streamline the permitting process for large sources. EPA has proposed not to include additional, smaller sources in the permitting program at this time. EPA will be accepting comments on the proposal for 45 days after it is published in the Federal Register.

The GHG Tailoring Rule would continue to address a group of six greenhouse gases. Under the approach maintained in the current proposal, new facilities with GHG emissions of at least 100,000 tons per year (tpy) carbon dioxide equivalent (CO2e) continue to be required to obtain PSD permits. Existing facilities that emit 100,000 tpy of CO2e and make changes increasing the GHG emissions by at least 75,000 tpy CO2e, must also obtain PSD permits. Facilities that must obtain a PSD permit, to include other regulated pollutants, must also address GHG emission increases of 75,000 tpy or more of CO2e. New and existing sources with GHG emissions above 100,000 tpy CO2e must also obtain operating permits.

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

November 10, 2011

Regional Haze SIP - Schedule For Action On Ohio Plan

The U.S. Environmental Protection Agency (EPA) has announced a court ordered schedule to review and act on more than 40 state regional haze reduction plans (including Ohio), designed to improve visibility in national parks and wilderness areas. The EPA action by itself does not establish control requirements; EPA will work with the states to approve their plans by the court ordered deadline in the agreement. Under the terms of the consent decree, if a state plan cannot be approved, EPA will determine an appropriate federal plan.

The dates for promulgation of final rules (either accepting or rejecting State plans) begin December 13, 2011 and run through November 15, 2011. The dates for action on the Ohio regional haze SIP are:
Proposed Promulgation: January 17, 2012
Final Promulgation: May 15, 2012

EPA initially issued a rule in 1999 requiring states to submit regional haze plans. These plans were due in December 2007, but no action was taken by the agency in response to the submittals. National Parks Conservation Association and other environmental groups sued the agency in August 2011 to take action on these plans, and the consent decree resolves this litigation. EPA will accept public comment on this agreement for 30 days following publication of a notice in the Federal Register.

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


September 22, 2011

Amendments To Ohio Water Quality Trading Rules

The Ohio Environmental Protection Agency (OEPA) has proposed changes to the rules that govern trading programs for wastewater discharge permits issued by the State. Ohio Administrative Code (OAC) 3745-5 provides the administrative requirements for the development and implementation of water quality trading programs in Ohio. A majority of the revisions consist of minor updates to references and grammatical edits. In addition, the following specific changes are being considered:

Rule 03 – Revising rule to state that use of a water quality credit shall not cause or contribute to a violation of water quality standards. Adding provision that nonpoint source load reductions funded through Ohio EPA’s Water Resource Restoration Sponsor Program are not eligible to generate water quality credits
Rule 04 – Adding date by which two existing trading programs must submit water quality trading management plans
Rule 06 – Changing the size of the hydrologic unit codes that must be used when identifying areas where nonpoint source projects might be located
Rule 11 – Identifying additional compliance-related provisions that will be included in NPDES permits when the permittee is participating in a water quality trading program.
Rule 14 – Revising language to include biological and stream habitat parameters in ambient water quality monitoring plans

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

July 16, 2011

Most Efficient Designation Label For Consumer Products

U.S. Department of Energy (DOE) and U.S. Environmental Protection Agency (EPA) have announced a new product recognition label for the most energy-efficient products in their category. The new designation of “Most Efficient” aims to provide all manufacturers with an incentive for greater product energy efficiency while providing consumers new information about the products that comprise the top tier in the categories.

Products that receive the Most Efficient designation demonstrate exceptional efficiency performance. The Most Efficient recognition will represent approximately the top 5% of models on the market in the following categories: clothes washers, heating and cooling equipment, televisions, and refrigerator-freezers.

Consumers will be able to identify Most Efficient products on the Energy Star website and in stores by looking for the Most Efficient designation. In addition to meeting established performance requirements, products must also be Energy Star qualified and certified by an EPA-recognized certification body. EPA is encouraging manufacturers to submit products that meet the requirements for recognition.

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


June 8, 2011

EPA Revokes CBI For Some TSCA Studies

U.S. Environmental Protection Agency has made public the identities of more than 150 chemicals contained in 104 health and safety studies that had previously been claimed confidential by industry. For these 104 studies, the chemical identity will no longer be redacted. The chemicals involved are used in dispersant formulations and consumer products such as air fresheners, non-stick and stain resistant materials, fire resistant materials, nonylphenol compounds, perfluorinated compounds, and lead.

In 2010, EPA requested that the industry voluntarily declassify unwarranted claims of confidential business information (CBI). The agency also issued new guidance outlining plans to deny confidentiality claims for chemical identity in health and safety studies under the Toxic Substances Control Act (TSCA). Based on this guidance, EPA notified a number of companies in February 2011 that the agency had determined that their CBI claim was not eligible for confidential treatment under TSCA and that EPA intended to make the information public. The health and safety studies include some declassified by the agency and other voluntary declassifications by companies in response to EPA’s 2010 request.

In addition to these actions, EPA has recently taken other steps to make chemical information more readily available. The agency has provided the public with free access to the consolidated TSCA Inventory on the EPA and Data.Gov websites. EPA also launched a new chemical data access tool gives the public the ability to electronically search EPA’s database of more than 10,000 health and safety documents on a wide range of chemicals.


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


April 27, 2011

Summary of Revised Industrial Stormwater Permit Requirements In Ohio

Ohio EPA has completed public comment on its proposed draft industrial multi-sector permit, and plans to issue the NPDES industrial general permit renewal in May with an effective date of June 1, 2011.

Currently, Ohio EPA plans to mail renewal notices to all permittees of the current industrial general permit (OHR000004) in mid-June. The renewal notice will include a blank NOI application form to submit to Ohio EPA within 90 days to continue general permit coverage until May 31, 2016.

The 90-day period is intended to allow permitted facilities with sufficient time to:

1. Select, design, install, and implement control measures to meet numeric and non-numeric effluent limits in the new permit;and
2. Develop a new SWPPP according to the requirements in the new permit.


[click here to review a Regulatory Briefing on the new SWPPP and permit compliance 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


April 26, 2011

OEPA Draft Industrial Permit - Storm Water Benchmark Sampling

The proposed stormwater monitoring requirements in the proposed General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP) include both effluent monitoring requirements for some facilities and benchmark monitoring requirements for most permitted facilities in Ohio. Consistent with the US EPA MSGP, the OEPA draft permit contains numeric effluent limitations based on Effluent Limitations Guidelines for Sectors A, C, D, E, J and O. [more information on difference between effluent limitations and benchmark concentrations]



The Ohio MSGP requires benchmark monitoring, specific for each industrial sector, for pollutant parameters which US EPA has determined to be of concern by industrial sector. The draft Ohio general permit requires that 19 of the 29 industrial sectors perform benchmark analytical monitoring. The benchmark monitoring requirements are not effluent limitations. Benchmark values represent a level to determine whether a facility’s SWP3 is effective.



The benchmark monitoring is based on a collection of 4 quarterly samples. If the average of the 4 monitoring values for any parameter does not exceed the benchmark value, the permittee has fulfilled their monitoring requirements for that parameter for the permit term. If this average exceeds the benchmark for a parameter, then the permittee will need to review their SWP3 and control measures and modify accordingly. Additional monitoring would be required. The US EPA MSGP’s primary source of benchmark concentrations is derived from EPA’s National Water Quality Criteria. For a majority of the benchmarks, USEPA used the acute aquatic life, fresh water ambient water quality criteria. USEPA believes these acute freshwater values best represent the highest concentrations at which typical fresh water species can survive exposures of pollutants for short durations, such as a storm discharge event.
[read recent comparison of benchmark concentrations to typical industrial sector monitoring data]



Ohio EPA evaluated each benchmark monitoring parameter and followed US EPA’s methodology, but used Ohio Water Quality Criteria when available. As such, some US EPA benchmark values have been changed to be consistent with Ohio Water Quality Criteria. The benchmark values of some metals are dependent on water hardness. For these parameters, permittees will need to determine the hardness of the receiving water to determine the benchmark concentration that applies to their facility. Depending on the condition of the receiving water, benchmark values for heavy metals can vary widely between facilities.

Caltha LLP provides expert consulting services to public and private sector clients in Ohio & nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWP3), Stormwater Monitoring (including determination of the effects of receiving water hardness on benchmark concentrations), and Stormwater Training.




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



Benchmarks For Metals In Ohio Industrial MSGP

The Ohio Environmental Protection Agency (OEPA) has released its draft Multi-sector General Permit (MSGP) which, once finalized, will replace the existing industrial stormwater discharge general permit, which will expire on May 31, 2011. The draft MSGP is modeled after the US EPA MSGP, released in 2008, and is significantly different compared to the existing Ohio permit.


One of the key changes is the requirement for most permitted facilities to conduct benchmark monitoring of their industrial storm water discharge. Results are compared to a list of sector-specific benchmark concentrations to determine if improvements to the stormwater pollution prevention program are needed, and whether or not further benchmark monitoring is needed.


The benchmark concentrations for each sector are listed in the permit, with several important exceptions. These are benchmarks for seven metals:





  • Beryllium



  • Cadmium



  • Copper



  • Lead



  • Nickel



  • Silver



  • Zinc



The benchmarks for these chemicals must be calculated for each individual facility based on the hardness of the receiving water, which each facility must determine. This will require individual facilities or groups of facilities to collect additional samples and do additional testing prior to starting their benchmark monitoring program.


The necessity to determine site-specific stormwater benchmarks only affects certain Ohio discharges, includes some or all facilities in fall into ten of the industrial sectors:




Sector A – Timber Products
Sector C – Chemical and Allied Products Manufacturing, and Refining
Sector F – Primary Metals
Sector G – Metal Mining
Sector K – Hazardous Waste Treatment, Storage, or Disposal Facilities
Sector M – Automobile Salvage Yards
Sector N – Scrap Recycling and Waste Recycling Facilities
Sector Q – Water Transportation Facilities
Sector Y – Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
Sector AA – Fabricated Metal Products


Caltha LLP provides expert consulting services to public and private sector clients in Ohio and nationwide to address stormwater permitting & regulatory support, including determination of stormwater benchmarks for water hardness dependant metals, development of Stormwater Pollution Prevention Plans (SWPPP) using a SWPPP template prepared to meet the new permit requirements, stormwater monitoring and stormwater training.



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



April 25, 2011

Storm Water Plan Template and Compliance Plan To Meet New OEPA General Permit

The Ohio Environmental Protection Agency (OEPA) has proposed a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP. This permit will replace the existing Ohio general permit, which expires on May 31, 2011. The draft Ohio general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For most facilities subject to the existing general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP.


To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on Ohio permit requirements, including Ohio specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Ohio Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the OEPA general permit.


For further information on Caltha's Ohio SWPPP Templates, email: info@calthacompany.com


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




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


April 12, 2011

Regulation of Milk and Milk Products Under SPCC Rule

The U.S. Environmental Protection Agency (EPA) has exempted milk and milk product containers from the Oil Spill Prevention, Control and Countermeasure (SPCC) rule, potentially saving the milk and dairy industries more than $140 million per year. Based on input from the milk industry, EPA had previously delayed SPCC compliance requirements for milk and milk product containers until the mandated regulatory process could be completed. In January 2009, EPA proposed the rule to exempt milk containers from the SPCC rule. Milk production is already subject to certain construction and sanitary standards and requirements that help prevent spills.

The final exemption applies to milk, milk product containers, and milk production equipment. In addition, because some of these facilities may still have oil storage subject to the spill prevention regulations, EPA is also amending the rule to exclude milk storage capacity from a facility’s total oil storage capacity calculation. The agency is also removing the compliance date requirements for the exempted containers.

The SPCC regulations require facilities with the capacity to store more than the threshold quantity of oils and fats to create and implement plans to prepare, prevent and respond to spills. The current exemption for milk does not apply to fuel oil and other applicable oils stored on farms; farms that store above the regulatory threshold of fuel oil and other applicable oils are covered under the SPCC.

Caltha LLP provides specialized expertise to clients nationwide in the preparation and certification of SPCC Plans, development of emergency preparedness & response plans, and preparation of stormwater pollution prevention programs.


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


March 4, 2011

Chemicals Added To Safe Drinking Water Act Monitoring

U.S. Environmental Protection Agency (EPA) is proposing 30 currently unregulated contaminants for monitoring in water systems. Sampling will take place at all systems serving more than 10,000 people and at a representative sampling of systems serving less than 10,000 people.

Under the Safe Drinking Water Act (SDWA), EPA currently regulates more than 90 contaminants in drinking water. The SDWA requires that EPA identify up to 30 unregulated contaminants for monitoring every five years. This current proposal is the third Unregulated Contaminant Monitoring Regulation and includes requirements to monitor for two viruses and 28 chemical contaminants that could be present in drinking water and do not currently have health-based standards.

EPA is requesting public comment on the proposed list of 30 contaminants until May 2, 2011. EPA anticipates finalizing the list in 2012, with sampling to be conducted from 2013 to 2015.

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

February 10, 2011

TSCA Confidential Business Information Claims Denied

The U.S. Environmental Protection Agency has notified five companies that the identities of 14 chemicals associated with a number of health and safety studies submitted under the Toxic Substances Control Act (TSCA) and claimed as confidential are not eligible for confidential treatment. Last year, EPA put in place a plan to review confidentiality claims for the name of chemicals addressed in health and safety studies. Under these new procedures EPA is moving to declassify many chemical identities so they are no longer secret. EPA expects that more chemical names connected with health and safety studies will be released in the future. The agency plans to deny confidentiality claims for chemical identity in health and safety studies provided to the agency under TSCA unless the chemical identity contains process or mixture information that is expressly protected by the law.

EPA has begun reviewing past CBI claims for chemical identity in health and safety studies. Where EPA determines that the information is not eligible for confidential treatment under the law, the agency will notify companies of the determination and that EPA will make the information public on the 31st day after receiving the determination unless the company challenges the disclosure in federal court.

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

December 17, 2010

Partnership To Share Technical Data On Chemical Hazards

U.S. EPA and the European Chemicals Agency (ECHA) have announced a partnership to promote enhanced technical cooperation on chemical management activities. ECHA implements the European Union’s chemical management program known as REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals). The partnership was formalized through a statement of intent at the Transatlantic Economic Council (TEC) meeting in Washington, D.C. The statement describes a process for cooperating on a range of issues of mutual interests including toxicity testing, the hazard and risk assessment of chemicals, risk management tools, scientific collaboration, and information exchange.

A major area of collaboration will be in the exchange of data and information between ECHA and EPA, including non-confidential information on hazards, uses, and substance identification, and data collected under REACH. The two agencies will also share criteria for managing confidential business information (CBI).

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

November 24, 2010

Certified Water Efficiency Homes WaterSense Certification

EPA has recognized the first WaterSense labeled homes in the country. WaterSense is a partnership program sponsored by EPA that seeks to promote water efficiency. The program helps homebuyers cut water and energy use and reduce utility bills. Four WaterSense labeled new homes have been built by KB Home in Roseville, California, and will save an average of 10,000 gallons of water and at least $100 on utility costs each year.

Each house includes WaterSense labeled plumbing fixtures, an efficient hot water delivery system, water-efficient landscape design, and other water and energy-efficient features. Each WaterSense labeled new home is independently inspected and certified to ensure EPA’s criteria are met for both water efficiency and performance. A WaterSense labeled new home is built to use about 20 percent less water than a typical new home.

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