Oil Spill Reporting - Federal Sheen Rule Criteria

Under the Clean Water Act, the "sheen rule" provides the framework for determining whether an oil spill should be reported to the federal government. Federal regulation requires the person in charge of a facility or vessel responsible for discharging oil that may be "harmful to the public health or welfare" to report the spill.

The regulation establishes the criteria for determining whether an oil spill may be harmful to public health or welfare, thereby triggering the reporting requirements:

• Discharges that cause a sheen or discoloration on the surface of a body of water;
• Discharges that violate applicable water quality standards; and
• Discharges that cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorelines.

These reporting criteria are independent of local or State spill reporting requirements. Therefore, spills might be reportable even if State spill reporting thresholds are not exceeded.

Because the Oil Pollution Act of 1990, which amended the Clean Water Act, broadly defines the term "oil," the sheen rule applies to both petroleum and non-petroleum oils and fats (e.g., vegetable oil, milk). The regulation also provides several exemptions from the notification requirements.

40 CFR 112 SPCC compliance and SPCC Plan services

Caltha LLP provides expert environmental consultant services in Michigan 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

RCRA, SWPPP, Hazcom, SPCC Training

Many of the regulatory programs that affect our clients include some requirements for employee training. In order to maintain compliance, improve performance and reduce liabilities and costs, many of our clients may also conduct employee training that may not be required by specific regulations

RCRA Training & Universal Waste Handling Training
Some facilities are required to provide routine training to employees regarding hazard waste management. Facilities that generate only “universal wastes”, such as spend light bulbs, batteries, etc, need to document that employees have been trained on the proper handling of wastes. Caltha will develop RCRA training materials specific to your facility for you to present, or can provide an experienced RCRA trainer to present waste handling training to your employees.

Hazard Communication Training, HazCom Training
OSHA’s Hazard Communication standard includes a strong training component. Caltha prepares HazCom Training Programs for your trainers to present, or we can supply one of our expert trainers.

EMS Awareness and ISO 14001 Training
One of the key compliance elements is development of an Employee Training Program. Based on an individual employees job responsibilities, different level of training may be required, included training certification. Caltha provides stormwater training in a number of flexible formats, including “train the trainer” to maximize your training investment.

Stormwater and SWPPP Training
Caltha has provided SWPPP training to meet State stormwater permit requirements in over 40 different States. Stormwater training has included Employee SWPPP Awareness Training, Inspector Training, Stormwater Monitoring Training, and Overall Permit Compliance Training modules.

SPCC Training & 40 CFR 112 Compliance Training
Facilities that exceed the SPCC rule oil storage threshold of 1,320 gallons need to prepare a Spill Prevention, Control & Countermeasure (SPCC) Plan and comply with the US EPA SPCC Rule. Caltha prepares SPCC Plans, including the new SPCC Template Plan used by smaller facilities, and assists facilities in developing their SPCC rule compliance program, including SPCC inspections and SPCC training.

Environmental Training & EHS Compliance Training
Caltha has several training programs designed to provide an overview of environmental and EHS regulations that affect a typical facility. Training modules have including RCRA, EPCRA, CERCLA, above ground and underground tanks, wastewater, air emissions, hazard communication, hazardous material management, environmental management systems, compliance audits, and numerous State rules. A training program can be customized to meet our client’s special requirements

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

For further information contact Caltha LLP at

info@calthacompany.

or

Caltha LLP Website

Spill Reporting and SPCC Rule 40 CFR 112 Compliance

Caltha LLP provides technical support to facilities nationwide to comply with US EPA Spill Prevention, Control & Countermeasure (SPCC) Rules (40 CFR 112) and Michigan-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: Spill Plans, Spill Reporting and SPCC Rule 40 CFR 112 Compliance Services

Caltha LLP provides expert environmental consultant services in Michigan 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

Michigan SPCC - Tier I - Tier 1 Qualified SPCC Template Plan

Effective February 3, 2009, US EPA streamlined SPCC Rule (40 CFR 112) became effective. The amended rule tailored the SPCC requirements for a subset of qualified facilities. Now 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 nationwide 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.

Caltha LLP provides expert environmental consultant services in Michigan 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