Posts Tagged ‘Arizona’

ADEQ Considering Amedments To Rules Governing Reclaimed Water

Tuesday, August 23rd, 2016

ADEQ is considering changes to all the reclaimed water rules and expects to publish proposed rule changes, likely in the fall of 2016,

Reclaimed water is highly treated wastewater from a wastewater treatment plant. A.R.S. § 49-201(32). Reclaimed water has uses such as for irrigation. Using reclaimed water offsets and conserves potable water for human consumption and domestic purposes.

The Arizona Department of Environmental Quality (ADEQ) seeks to amend R18-9-704 in order to allow incidental runoff of reclaimed water under certain conditions. This rulemaking would be limited to amending only R18-9-704, as ADEQ is working with stakeholders to consider other changes to the reclaimed water rules.

ADEQ Final 2013 Construction General Permit Compliance Date Set As June 3

Sunday, April 21st, 2013

The Arizona Department of Environmental Quality (ADEQ) has finalized the new 2013 Construction General Permit (CGP) which will become effective Monday, June 3, 2013. According to ADEQ, existing operators covered by the 2008 CGP are required to update their SWPPPs and be in compliance with the new permit as of that date, but to not need to reapply for permit coverage. Beginning on that date, operators of new projects requiring coverage must apply under the new permit. ADEQ expects to send an update and reminder approximately two weeks before the implementation date.

As background, US EPA finalized Effluent Limitations Guidelines and New Source Performance Standards for the construction and development industry ( “C&D rule”) on December 1, 2009. The C&D rule became effective on February 1, 2010, and include a suite of non-numeric effluent limitations that apply to all permitted construction sites. The non-numeric effluent limits include requirements for:

  • Erosion and Sediment Controls;
  • Soil Stabilization;
  • Pollution Prevention Measures;
  • Dewatering;
  • Prohibited Discharges; and
  • Protection of Surface Outlets.

ADEQ’s 2013 CGP includes language that implements US EPA’s C&D rule non-numeric limits. The permit also includes water quality-based requirements for construction sites discharging stormwater to waters requiring additional pollutant control.

US EPA’s C&D rule requirements include (1) non-numeric effluent limitations that apply to all permitted discharges from construction sites , and (2) a numeric effluent limit for turbidity (which is the subject of an indefinite stay) that applies to certain larger sites. USEPA has issued the stay for the numeric limit for turbidity so that the limit can be recalculated. Until a new limit is promulgated, USEPA and authorized states (including Arizona) are not required to incorporate a numeric turbidity limitation into their permits.

The C&D rule’s non-numeric effluent limitations are incorporated into the AZPDES 2013 stormwater Construction General Permit (2013 CGP). The C&D rule contains non-numeric effluent limitations that require the operator to minimize the discharge of pollutants including the prevention of the mobilization and discharge of sediment, turbidity, and other sediment-bound pollutants, such as metals and nutrients, and to prevent or minimize the exposure of stormwater to construction materials, debris, and other sources of pollutants on construction sites. In addition, these non-numeric effluent limitations limit the generation of dissolved pollutants, such as nutrients, organics, pesticides, herbicides and metals that may be present naturally in the soil on construction sites, such as arsenic or selenium, or may have been contributed by previous activities on the site such as agriculture or industrial.

Pre-Divestiture Environmental Assessment and Hazardous Material Abatement For Arizona Manufacturing Plant

Thursday, April 4th, 2013

Caltha LLP Project Summary

Project: Pre-Divestiture Due Diligence Assessment and Site Cleanup
Client: Multinational Electronics Manufacturer
Location(s): Arizona
Key Elements: Phase 1 ESA, Phase 2 investigations, Abatement of hazardous materials, Site redevelopment

Overview: This project was performed for a multinational electronics company at its manufacturing location near Tucson, Arizona. Work was to perform environmental due diligence and site clean up in advance of plant closure, sale and redevelopment for a different manufacturing use. Work comprised of a Phase 1 Environmental Site Assessment which could be provided to interested potential Buyers. The Phase 1 ESA identified hazardous materials at the site, including accumulated hazardous dusts due to past fugitive emissions inside the building. Caltha investigated the extent of hazardous materials to be abated, coordinated with abatement contractors and conducted verification sampling after work was completed. Plant was ultimately sold and redeveloped for a different manufacturing sector.

For more information on Caltha LLP services, go to the Caltha Contact Page

Temporary Corporate HSE Staffing – Site Remediation Oversight

Friday, March 22nd, 2013

Caltha LLP Project Summary

Project: Corporate HSE Staffing-Site Remediation Oversight
Client: Multi-national Chemical Company
Location(s): California, Illinois, Indiana, Minnesota, North Carolina, Ontario, Canada, Michigan, Kentucky, Arizona

Key Elements: Environmental Health & Safety Staffing, Site remediation

Overview: This chemical company contracted with Caltha to provide temporary staffing in its corporate HSE Department for the position that oversaw numerous site remediation projects being conducted across the US and Canada. Due to staff turnover the position needed to be filled quickly to assure that process on projects continued, on-site contractors had questions and issues addressed, and that required agency submittals were reviewed, approved and submitted on time. Caltha provided a highly experienced HSE professional to fill the position until the corporation could hire a permanent replacement. Caltha staff were then able to provide transitional support.

For more information on Caltha LLP services, go to the Caltha Contact Page

Corporate EH&S Staffing For Electronics Manufacturer

Thursday, March 21st, 2013

Caltha LLP Project Summary

Project: Corporate EH&S Staffing
Client: Multi-national Electronics Manufacturer
Location(s): California, Arizona, Oklahoma, North Dakota, Wisconsin, Minnesota

Key Elements: Staffing, Reporting, Permitting

Overview: Caltha provided temporary staffing to this Minnesota-based multi-national manufacturer to fill two key positions in the Corporate Environmental Health and Safety Services department. The positions required frequent interactions with facility EHS, engineering and plan management staff to address issues and questions, and provided reoccurring training required by regulations. Therefore, positions were staffed by Caltha with highly experienced EHS professionals that were capable of addressing a wide range of regulatory and technical issues with minimal support. Caltha staff prepared air emission inventory reports, EPCRA Tier 2 reports, TRI reports and other required submittals on behalf of facilities. Caltha staff also prepared air and wastewater permit applications for submittal. Caltha staff provided had 20 to 25 years of experience in the EHS field. Ultimately, the company was able to hire to fill these positions and Caltha staff were available to train the new hires during the transition.

For more information on Caltha LLP services, go to the Caltha Contact Page

Logistics Industrial Storm Water Permitting & Compliance

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: International Retailer
Location(s): California, Washington, Utah, Georgia, Florida, Virginia, North Carolina, Pennsylvania, Ohio, Massachusetts, New York, Kansas, Virginia, Louisiana, Texas, Tennessee, Minnesota, Illinois, Indiana, South Carolina, Colorado, Nevada, New Jersey, Connecticut, Missouri

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this international retailer at multiple logistics and warehousing locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State or EPA application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

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

Pre-Acquisition Due Diligence Assessment For Food Sector

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: Pre-Acquisition Due Diligence Assessment
Client: International Food Manufacturer
Location(s): California, Arizona, Minnesota

Key Elements: Phase 1 ESA; Compliance audit

Overview: This project was performed for a Minnesota-based international food manufacturer and was coordinated through a Minneapolis-based law firm. The scope of the assessment was to perform environmental due diligence for multiple facilities located in California and Arizona they intended to acquire, and comprised of a Phase 1 Environmental Site Assessment, performed in accordance with ASTM 1527-05, and a compliance audit to assess the current compliance of existing equipment and operations with applicable State and Federal regulations. Numerous compliance issues and Recognized Environmental Conditions were identified. Caltha staff provided technical support to estimate the potential costs associated with corrective actions required. Caltha also provide technical support to coordinating law firm in developing contract documents and purchase agreements that address environmental issues identified during the assessments.

For more information on Caltha LLP services, go to the Caltha Contact Page

EPA Rulemaking To Address State Requirements For Startup, Shutdown, or Malfunction

Friday, February 22nd, 2013

The EPA is proposing to take action on a petition for rulemaking filed by the Sierra Club in 2011 concerning the treatment of excess emissions in state rules by sources during periods of startup, shutdown, or malfunction (SSM). EPA is proposing to grant in part and to deny in part the request to rescind its policy interpreting the Clean Air Act (CAA) to allow states to have appropriately drawn state implementation plan (SIP) provisions that provide affirmative defenses to monetary penalties for violations during periods of SSM. The EPA is also proposing either to grant or to deny the Petition regarding existing SIP provisions related to SSM in each of 39 states identified in the petition.

For each of those states where EPA proposes to grant the petition concerning specific provisions, EPA also is proposing to find that the existing SIP provision is substantially inadequate to meet CAA requirements and proposes a “SIP call.” For those affected states EPA will require the states to submit a corrective SIP revision. Comments on the proposed actions must be received on or before March 25, 2013.

Through this rulemaking, EPA intends to clarify its interpretation of the CAA regarding excess emissions during SSM events. EPA may find specific SIP provisions to be substantially inadequate to meet CAA requirements; if a state’s existing SIP provision allows an automatic exemption for excess emissions during periods of startup, shutdown, or malfunction, then the EPA may determine that the SIP provision is substantially inadequate because the provision is inconsistent with requirements of the CAA.
The affected States include:

District of Columbia
New Hampshire
New Jersey
New Mexico
North Carolina
North Dakota
Rhode Island
South Carolina
South Dakota
West Virginia

Arizona Department of Environmental Quality Extends 2008 Construction General Permit

Thursday, February 21st, 2013

The Arizona Department of Environmental Quality (ADEQ) has administratively continued the current statewide construction general permit (2008 CGP) which expires on February 28, 2013.

In accordance with a provision made in SB1289 during the 2012 Legislative session, which amended the AZPDES statute by adding ARS § 49 – 255.01(M), the CGP 2008 will be continued beyond February 28, 2013. According to ADEQ, construction site operators may continue to apply for stormwater permit coverage under the 2008 CGP after February 28, 2013, until the Department’s approval and issuance of the the AZPDES 2013 Construction General Permit (2013 CGP). Approval and issuance are anticipated to occur before May 1, 2013.

EPA Action On Arizona Regional Haze Program SIP

Friday, December 21st, 2012

EPA is proposing to approve in part and disapprove in part a revision of Arizona’s State Implementation Plan (SIP) to implement the regional haze program for the first planning period through July 31, 2018. This proposed action includes all portions of the SIP except for three electric generating stations that were addressed in a final rule published in the Federal Register on December 5, 2012.

EPA is taking action on Arizona’s Best Available Retrofit Technology (BART) control analysis and determinations, Reasonable Progress Goals (RPGs) for the State’s 12 Class I areas, Long-term Strategy (LTS), and other elements of the State’s regional haze plan. If EPA takes final action to disapprove any portion of the SIP, EPA will work with the State to develop plan revisions to address the disapproved provisions. The Clean Air Act (CAA) requires states to adopt and submit to EPA SIPs that assure reasonable progress toward the national goal of achieving natural visibility conditions in 156 national parks and wilderness areas designated as Class I areas.