Posts Tagged ‘Iowa’

Due Diligence Compliance Audit – RMP Audit of Iowa Ammonia Refrigeration Operation

Wednesday, April 12th, 2017

Caltha LLP Project Summary

Project: Due Diligence RMP Focused Compliance Audit of Cold Storage Facility
National Food Processing Company

Key Elements: Due Diligence, Environmental compliance audit, Multimedia compliance audit, Accidental Release Prevention, Risk Management Program

Overview: Caltha LLP was retained by a national food processing company to conduct a multimedia environmental compliance audit of this cold storage facility as part of its due diligence. The scope of the audit covered all media including wastes, hazardous waste, wastewater, hazardous materials, DOT HazMat and air emissions. Due to the use of anhydrous ammonia refrigerant systems, the facility was subject to the Accidental Release Prevention provisions of 40 CFR 68. The majority of the audit was to review operations for compliance with the requirements of the Risk Management Program and Process Safety Management. This included conformance with the International Institute of Ammonia Refrigeration guidelines. Caltha provided IIA certified auditors to conduct the review.

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

Tier II Reporting In Iowa | When Are Tier 2 Chemical Inventory Reports Due?

Sunday, December 25th, 2016

EPCRA 302/311/312 reports (“Tier II Reports”) are due on an annual basis to the State and Local Emergency Planning Committee and local emergency response agencies, such as the fire department. The information provided is used in the evident of an emergency, such as a fire, to evaluate potential chemical and other hazards at the property, and to select appropriate protection equipment and fire fighting techniques. EPCRA reporting facilities disclose the types, quantities and locations of hazardous materials. Facilities also provide with Safety Data Sheets for each material.

There are separate reporting requirement for hazardous materials (any material that requires a Safety Data Sheet under OSHA rules) and Extremely Hazardous Substances (EHS) which are a specific chemicals listed by US EPA. A very common example of one such EHS is sulfuric acid.

When are Tier 2 reports due in Iowa?

The Tier II report is due March 1 of each year and is based on chemicals stored at your site during the previous calendar year. Reporting can be completed by using the Iowa DNR Online Tier II Reporting System.

Caltha LLP provides technical support to facilities in Iowa that submit reports under EPCRA 311 and EPCRA 312.
Click here for a summary of some recent changes to EPCRA Tier II reporting requirements

For more information or to request a quote go to:
Caltha LLP EH&S Compliance Support Services

Iowa Hazardous Waste Generators Update Training To Align With New RCRA Rules

Sunday, December 11th, 2016

On May 30th, 2017, new hazardous waste generator rules become effective in Iowa. These new hazardous waste regulations effect all sizes of hazardous waste generators, from very small businesses generating only a minimal quantity of waste each month to large facilities, regulated as “large quantity generators” or LQG.

Click here for an overview of the new hazardous waste generator rules

Caltha LLP provides hazardous waste training to facilities in Iowa who are affected by these new rules. Training can include:

  • Annual employee training for staff handling and managing hazardous waste
  • Basic hazardous waste management training for Small and Very Small Quantity Generators
  • Spill and Emergency Response training required by RCRA contingency plans
  • Basic spill and emergency response for responding to incidental spills in the workplace
  • SPCC annual training
  • Triennial DOT HazMat certification training for employees who ship wastes

Visit the Employer’s Environmental Health and Safety Training Center page for further information and to request a quote for training services

Hazardous Waste Generator Improvements Rule – States Immediately Affected

Thursday, November 24th, 2016

The Hazardous Waste Generator Improvements Rule is now signed and published in the Federal Register on November 28, 2016. The effective date is May 30, 2017. This leaves hazardous waste generators to sort out how this will affect them, and when.

Immediate Affect of the Hazardous Waste Generator Improvements Rule
The Generator Improvements Rule modified the Federal rules under RCRA and therefore has direct affect on hazardous waste generators located in States that have not been delegated RCRA authority (Iowa and Alaska) and some other areas, including Tribal lands. However, many States have incorporated portions of the RCRA rules by reference into their authorized programs – therefore, in these States revisions to Federal RCRA rules can have an immediate affect on State rules. This can significantly increase the population of hazardous waste generators that will be affected by the Hazardous Waste Generator Improvements Rule s ix months after publication in the FR – likely late May 2017.

For generators located in States that have not incorporated generator requirements by reference, the impact of the rule revision will be uncertain. Rule changes will only become effective when States modify their own hazardous waste generator requires. To add to the uncertainty, States will only be required to modify their rules to incorporate portions of the Hazardous Waste Generator Improvements Rule that are MORE stringent than current rules. Other portions of the new EPA rules that add flexibility, are less stringent, or are incorporate clarifications to the rule would not need to be addressed by States to maintain their authorized programs under RCRA.

Iowa DNR Collection of Air Permits (CAP) Program Summary

Monday, February 29th, 2016

The Iowa DNR is proposing to create a new air quality construction permit option called a Collection of Air Permits (CAP). Current construction permit practice is to issue one permit per emission point. The new CAP permit option will still assign a permit number to each emission point but will consolidate requirements in one permit document.

Several changes have been proposed to the CAP based on comments received during the first CAP comment period in January 2016. Additionally, the CAP was modified to be consistent with the recently updated standard permit format.

Once finalized,  applicants will be able to request the CAP option on the Form FI when completing their requests for a permit and will also be able to combine existing permits into a CAP. An applicant might request a CAP to:

  • Organize permits with emission caps over several pieces of equipment into one permit document
  • Combine permits for emission points/emission units often modified together
  • Combine emission units with multiple emission points into one document
  • Combine all emission point/emission units in a “project” or “process”
  • Combine emission points/emission units with the same federal requirements

Tier 2 Hazardous Material Report For Minnesota, Wiscsonsin and Iowa Plants

Monday, December 30th, 2013

Caltha LLP Project Summary

Project: Tier 2 Hazardous Material Reporting For Minnesota, Wisconsin, Iowa Manufacturer
Regional Manufacturing Company
Minnesota, Wisconsin, Iowa

Key Elements: Tier II Report, Tier 2 threshold, Hazardous Material Inventory, EPCRA 311, EPCRA 312

Overview: Caltha LLP was selected to provide technical consultant services by this regional industrial corporation. Caltha staff provided technical support to six locations in Minnesota, Wisconsin and Iowa. The project included providing technical support and internal inventory summary forms to indivuals at each of the locations to allow each to conduct a self inventory of hazardous materials which may require reporting to State and local agencies. Caltha staff then reviewed inventory sheets and determined which materials exceeded the Tier 2 threshold and required reporting. Caltha then prepared Tier 2 reports for each of the locations to be submitted to appropriate agencies.

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

EPA Agreement With Iowa Department of Natural Resources On NPDES Permit Enforcement For CAFO

Saturday, September 14th, 2013

EPA has reached an agreement with the Iowa Department of Natural Resources (IDNR) to make changes to Iowa’s Clean Water Act (CWA) permit and compliance program for concentrated animal feeding operations (CAFOs). The agreement includes specific actions IDNR intends to take to remedy the program and a timeline for implementation of those actions to ensure clean, healthy water. Public comments, including feedback from the agricultural community, were taken into consideration in the drafting of the final agreement.

On July 12, 2012, EPA released a report outlining its initial findings, which identified issues in IDNR’s program that the state agency will need to correct. Among other findings, EPA found that IDNR does not have an adequate program to assess whether unpermitted CAFOs need NPDES permits. The findings also noted that IDNR must clarify its authority to issue NPDES permits to confinement (roofed) CAFOs that discharge. EPA also found that in a number of cases involving CWA violations, IDNR failed to take timely and adequate enforcement actions, and assess adequate penalties.

EPA’s investigation of Iowa’s permit and compliance program for CAFOs was carried out in response to a petition for withdrawal of the National Pollutant Discharge Elimination System (NPDES) program authorization from IDNR that was filed in 2007 by several organizations.

In the agreement, IDNR has committed to:

  • Conduct a comprehensive survey of all large CAFOs and medium animal feeding operations that currently don’t have CWA wastewater discharge permits and identify those that discharge to a water of the U.S. and have failed to comply with the permit application or other Iowa requirements. Size thresholds for each species define large and medium operations.
  • Review all relevant available information to evaluate site specific factors that may signal the likelihood of a wastewater discharge to local waterways. This desktop assessment will document baseline conditions at a facility and determine whether an on-site inspection will be conducted.
  • Conduct on-site inspections following agreed upon inspection procedures for all large CAFOs. For medium operations, on-site inspections will be conducted when certain site specific circumstances exist or the desktop assessment determines that an on-site inspection is needed.
  • Inspect all permitted NPDES CAFOs within five years following an agreed upon inspection procedure.
  • Issue timely wastewater discharge permits to all CAFOs determined to discharge to local waterways.
  • Take timely and appropriate enforcement actions when needed, including assessing penalties that ensure violators do not gain competitive advantage from non-compliance.
  • Change several provisions of Iowa’s CAFO rules so that Iowa state law is consistent with the federal CWA.

USDA Environmental Assessment Worksheet For Proposed Iowa Food Processing Plant

Monday, September 9th, 2013

Caltha LLP Project Summary

Project: USDA Environmental Assessment Worksheet For Proposed Food Processing Plant
Food Processer and Regional Economic Development Corporation

Key Elements: USDA Environmental Assessment Worksheet, Environmental Effects & Impacts, Regulatory and Permitting Requirements

Overview: Caltha LLP was retained by the project proposer, a food processing company, and the Regional Economic Development Corporation to prepare an Environmental Assessment Worksheet for the proposed project as required by the US Department of Agriculture (USDA) to secure a USDA backed loan for the project. Caltha staff worked in coordination with the project proposer and local USDA staff to prepare the EAW document. EAW elements evaluated included:

I. Project Description Purpose and Need
II. Primary Beneficiaries and Related Activities
III. Description of the Project Area
IV. Environmental Impacts Resource Criteria

1. Air Quality
2. Surface Water, Water Supply Quality, Groundwater, Storm Water, and Waste Water
3. Solid Waste Management and Hazardous Waste Management
4. General Land Use
5. Transportation
6. Natural Environment
7. Human Population Socio-Economic/Environmental Justice
8. Construction
9. Energy
10. Miscellaneous

V. Coastal Zone Management Areas
VI. Cultural Resources, Historical, Archaeological
VII. Wild and Scenic Rivers
VIII. Biological Resources Critical Habitat and Endangered/Threatened Species Act
IX. Important Farmland
X. Floodplain Management and Wetlands Management
XI. Coastal Barrier Resources System
XII. State Environmental Policy Act
XIII. Intergovernmental Review
XIV. Environmental Analysis Of Participating Federal Agency
XV. Reaction To Project
XVI. Cumulative Impacts
XVII. Adverse Impacts
XVIII. Alternatives, Including the Proposed Action
XIX. Mitigation
XX. Consistency with Rural Development Environmental Policies

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

EPA Proposes To Approve Revised Polk County Board of Health Rules and Regulations and Iowa SIP

Friday, August 30th, 2013

Environmental Protection Agency (EPA) has proposed to approve revisions to the State Implementation Plan (SIP) for the state of Iowa. The purpose of these revisions is to update the Polk County Board of Health Rules and Regulations. These proposed revisions reflect updates to the Iowa statewide rules previously approved by EPA and are intended to assure consistency between the applicable local agency rules and Federally-approved rules. Comments on this proposed action must be received in writing by September 26, 2013.

EPA is approving the Iowa SIP revision as a direct final rule without prior proposal because it views this as a noncontroversial revision amendment and anticipates no relevant adverse comments to the action.

Phase 1 Environmental For Historic Fort Dodge, Iowa Building

Monday, June 24th, 2013

Caltha LLP Project Summary

Project: Phase 1 ESA for Historic Building Renovation
Client: Developer
Location(s): Iowa

Key Elements: Phase 1 Environmental Assessment

Overview: The project developer for this building renovation retained Caltha to perform a Phase I ESA for the building and property located in Fort Dodge, IA. Detailed historical use records were found dating back to 1800’s. The Phase 1 met ASTM standard method E 1527-05 and US EPA All Appropriate Inquiry (AAI)requirements. The Phase 1 report was used to secure project financing from investors.

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