Iowa DNR Proposes To Formalize Compliance & Enforcement Actions

The Iowa Department of Natural Resources (DNR) is proposing rule making to formalize the variety of informal compliance and enforcement options the DNR may consider in responding to possible violations of environmental statutes, rules, permits, licenses, certifications, and plans. The DNR has been using these or similar procedures for many years, and this rule making process intends to formalize the practice. The DNR is proposing a new administrative rules chapter, Chapter 9A: Compliance and Enforcement Procedures.

The Iowa DNR is requesting public input on an upcoming rule making effort and will collect suggestions or comments from the public regarding the proposed rule making until Friday, November 18, 2011.

Caltha LLP provides expert environmental consultant services in Iowa 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

Iowa SPCC Rule Compliance - 40 CFR 112 Deadline Extended

US EPA is extending the compliance date by 1 year for certain facilities subject to recent amendments to the Spill Prevention Control and Countermeasure (SPCC) rule. Last year, EPA amended the SPCC rule and regulated facilities are required to amend and implement these changes as part of their overall SPCC plans. Types of facilities not eligible for the extension must comply by November 10, 2010 include drilling, production or workover facilities that are offshore or that have an offshore component, and onshore facilities required to have and submit facility response plans (FRPs). These amendments do not remove the regulatory requirement for owners or operators of facilities in operation before August 16, 2002, to maintain and continue implementing an SPCC plan in accordance with the SPCC regulations then in effect.

Types of facilities are eligible for the one year extension include:

Onshore oil production, farms, electric utility plants, petroleum refining and related industries, chemical manufacturing, food manufacturing, manufacturing facilities using and storing animal fats and vegetable oils, metal and other manufacturing, real estate rental and leasing, retail trade, contract construction, wholesale trade, other commercial, transportation, arts entertainment & recreation, other services (except public administration), petroleum bulk stations and terminals, education, hospitals & other health care, accommodation and food services, fuel oil dealers, gasoline stations, information finance and insurance, mining, warehousing and storage, religious organizations, military installations, and government facilities.

In summary, the rule would extend the date by which the owners or operators of certain facilities must prepare or amend and implement an SPCC plan until November 10, 2011. The amendment also would delay the compliance date by which facilities must address milk and milk product containers that are constructed according to the current applicable 3-A sanitary standards, and subject to the current applicable grade “A” pasteurized milk ordinance (PMO) or a state dairy regulatory requirement equivalent to the current applicable PMO until one year after EPA finalizes a rule for these facilities.

Caltha LLP assists private and public clients in Iowa in meeting SPCC Rule and SPCC Plan requirements. To request further information or request a quote, go to Caltha Quote Web Page.

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

SPCC Plan - SPCC Training In Iowa

Caltha LLP 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.

Caltha specializes in assisting smaller to medium sized facilities that qualify for self certification of their SPCC Plan and/or qualify to use the SPCC Template Plan format. The SPCC Rule (40 CFR 112) now allows SPCC Plans to be self-certified (no PE certification required) by facilities, if they meet a certain conditions. Some facilities, “Tier I Facilities”, can also use a streamlined SPCC Plan format, the SPCC Template Plan. For Tier I Qualifying facilities, the facility must also certify that it meets all the requirements necessary to use the SPCC Template Plan format.

For more information, go to:

Spill Prevention, Control & Countermeasure – SPCC Rule Compliance 40 CFR 112

Caltha LLP provides expert environmental consultant services in Iowa 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

Regulatory Compliance Updates - EHS Rule Compliance

Caltha LLP maintains several websites to provide regulatory updates and discussion of current environmental, health and safety topics, as listed below. Interested parties can register to receive automatic notification when a new topic is posted.

SWPPP - Stormwater Pollution Prevention Plans - Stormwater Permits - Stormwater Training
Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits, Stormwater Pollution Prevention Plans, monitoring, training, spill prevention and control, SPCC compliance.

Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits
Discussion of a variety of topics related to State and Federal water quality standards, ambient water quality criteria, sediment criteria, NPDES & site-specific discharge standards, water quality management, aquatic toxicology, aquatic community impacts, and water quality assessment.

Environmental Sustainability - Sustainable Environmental Management Systems
Discussion of sustainability topics, including pollution prevention, waste reduction, material reuse, environmental management systems, product stewardship, and international environmental standards.

Environmental Due Diligence - Site Assessments - Phase I ESA - Environmental Liability
Discussions and comments regarding environmental due diligence, environmental liabilities, CERCLA liabilities, Phase I environmental site assessments, corporate liabilities, environmental compliance liabilities, quantitative environmental liability assessment.

Regulatory Briefings
Regulatory Briefings are published periodically by Caltha to highlight new or proposed regulations on a wide range of environmental, health & safety topics. These briefings are generally 2- to 4-pages in length and provide an overview of the regulations and discuss potential impacts on the regulated community. Participants must sign up to receive an email link to new Regulatory Briefings as they are posted.

Caltha LLP provides expert environmental consultant services in Iowa 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

Iowa SPCC Requirements - Amended Definition of Navigable Waters

In November 2008, The Environmental Protection Agency (EPA) promulgated a final rule to amend a Clean Water Act (CWA) Section 311 regulation that defines the term “navigable waters'', effective November 26, 2008. This amendment affects compliance requirements with the SPCC Rule, 40 CFR 112.

As background, the SPCC rule was originally promulgated on December 11, 1973. The 1973 SPCC rule defined “navigable waters''. In 2002, EPA amended the SPCC rule including a revision to the regulatory definition of “navigable waters”.

On March 31, 2008, the U.S. District Court for the District of Columbia ruled that the Agency's promulgation of the revised definition of "navigable waters'' in the July 2002 SPCC rule violated the Administrative Procedure Act. The court vacated the July 2002 SPCC regulatory definition of "navigable waters'' and specifically restored the 1973 SPCC regulatory definition.

[Read more about recent changes to SPCC Rule]

Caltha LLP provides expert environmental consultant services in Iowa 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

Iowa Environmental Consulting - EH&S Consultant Services

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

Iowa (IDNR) Air Permit Compliance – Air Emission Permitting Services
Iowa (IDNR) Stormwater Permit Compliance – Storm Water Permitting Services
Iowa (IDNR) Environmental Assessment– Phase I (Phase 1) ESA Services
Iowa Environmental Audit – Environmental Compliance Services
Iowa RCRA Compliance Services
Iowa Haz Com – Hazard Communication Compliance Services

For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Website: http://www.calthacompany.com/

Change in SPCC Rule Compliance Deadline - Iowa SPCC Plan

EPA is extending the compliance dates for all facilities and establishing new compliance dates for farms and production facilities subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule. This amendment extends the dates by which the owner or operator of any SPCC-regulated facility must prepare or amend and implement its SPCC Plan. It also establishes the dates by which the owner or operator of a farm must prepare or amend and implement its SPCC Plan.

For all facilities subject to the recent amendments, the compliance deadline was extended to November 20, 2009. For farm and production facilities, the deadline for compliance with amended SPCC Rule requirement will be either November 20, 2009, or November 20, 2013, depending on whether or not the facility meets some specific criteria.

Caltha LLP assists companies in addressing their requirements under Federal SPCC rules. Caltha specializes in developing cost effective SPCC Plans for facilities nationwide using the new SPCC Template Plan format. Click here to request further information on SPCC and SWPPP Services.

For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Website: http://www.calthacompany.com/

EHS Training - RCRA HazCom SPCC SWPPP Auditing EMS

Caltha LLP offers a wide variety of Environmental Training courses developed to meet requirements of numerous regulatory programs.

Training is offered in a number of flexible formats, ranging from traditional classroom training presented periodically in different locations, to facility-level training conducted at individual sites to meet employee and/or contractor training needs. Caltha offers web-based and remote training options. Caltha also creates facility-specific training materials and conducts “train-the-trainer” sessions for facility training staff.

Caltha provides training in the following areas:
[Click on area to request information on upcoming training programs and training options]

RCRA - Hazardous Waste Generator (LQG) Training
HazCom - Hazard Communication Training
Stormwater Pollution Prevention - SWPPP Training [read more about State-specific SWPPP training]
Spill Prevention Control & Countermeasure - SPCC Training
Internal Compliance Audit Training
Internal EMS Audit Training
Contractor Training Programs
Facility Environmental Regulatory Overview Course


For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Website: http://www.calthacompany.com/

Streamlined SPCC Requirements for Qualified Facilities

On December 8, 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.

This final rule designates 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 Iowa in complying with SPCC Rules, including several very cost effective options for Tier I Qualified Facilities to prepare their SPCC Plan Template. Click here to request information on SPCC Template services.

For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Website: http://www.calthacompany.com/

Certification of SPCC Plan - Rules for Self Certifcation

The SPCC Rule (40 CFR 112) now allows SPCC Plans to be self-certified (no PE certification required) by facilities, if they meet a few qualifications:

• On-site oil storage capacity must be less than 10,000 gallons;
• Over the past three years, no single spill greater than 1,000 gallons, and no more than two spills greater than 42 gallons have occurred;
• The SPCC meets all SPCC Rule (40 CFR 112) requirements, without the use of “environmentally equivalent” or “impracticality” determinations.
  

SPCC Plans will still need to be signed by a responsible person on behalf of the facility. By signing the SPCC Plan, that person certifies that he/she is:

• Familiar with SPCC requirements,
• Has visited and reviewed the facility,
• The Plan was prepared in accordance with accepted and sound industry practices,
• Procedures for inspections and testing have been established,
• The Plan is fully implemented, and
• The facility meets all the requirements to qualify for self certification.

Caltha LLP offers expert technical and regulatory support to facilities in Iowa to develop "self-certified" facility Spill Prevention, Control & Countermeasure (SPCC) plans. Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112 requirements.

For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Website: http://www.calthacompany.com/

Iowa Spill Training - SPCC Training

Caltha LLP offers a number of different training opportunities related to Spill Prevention Control and Countermeasure (SPCC) training and compliance with SPCC Rules (40 CFR 112). Training sessions are offered periodically in locations around Iowa (Click here to request upcoming schedule), or are presented at an individual facility to meet employee training requirements.

SPCC-related training offered includes:

SPCC Training (required by 40 CFR 112)
SPCC Compliance Overview
SWPPP Training


Caltha LLP provides expert support to facilities subject to 40 CFR 112 (SPCC Rule), including SPCC Training and preparation of SPCC Plans.

For further information, contact Caltha LLP at:
Email: info@calthacompany.com
Website: http://www.calthacompany.com/