Archive for the ‘Audit’ Category

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
Client:
National Food Processing Company
Location(s):
Iowa

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

Steel Processing Facility Air Compliance Audit

Monday, November 9th, 2015

Caltha LLP Project Summary

Project: Air Regulation Focused Compliance Audit
Client:
Steel Processing Facility
Location(s):
Minnesota

Key Elements: Environmental compliance audit, Air permit compliance, Air emission tracking, Control Equipment Operation and Maintenance Plans

Overview: Caltha LLP was retained by this steel processing facility to conducted a focus environmental compliance audit. The scope was limited to compliance with a Minnesota MPCA issued air permit and compliance with Minnesota Chapter 7007 air permitting rules. Records reviewed included required equipment inspections, control equipment O&M Plans, air emission factor calculation, emission tracking spreadsheets and related documents. An audit report was prepared summarizing areas of non-compliance and other recommended areas of improvement.

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

Environmental Due Diligence For Mississippi Food Manufacturing Plant

Thursday, January 30th, 2014

Caltha LLP Project Summary

Project: Techncial Support for Environmental Due Diligence During Corporate Merger
Client:
National Food Ingredient Manufacturer/External Legal Counsel
Location(s):
Mississippi

Key Elements: Technical support to resolve issues related to due diligence assessments, environmental compliance audit, Phase I ESA

Overview: Caltha LLP provided expect technical support to this national food manufacturing corporation through their external legal counsel. Work was to provide expert technical reviews and consultant services related to due diligence preformed by the merger partner consultant. Issues were related to resolving Recognized Environmental Conditions, conformance to the new ASTM Standard Practice E 1527-13, and obligations related to shared environmental permits for air emissions, wastewater and stormwater.

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

Environmental Compliance Audit For Equipment Manufacturer To Meet ISO 14001

Sunday, December 15th, 2013

Caltha LLP Project Summary

Project: Scheduled Multimedia Compliance Audit
Client:
International Equipment Manufacturer
Location(s):
Minnesota

Key Elements: Compliance audit, State and Federal requirements, Air permit compliance, Waste management

Overview: Caltha Consultants was selected by this facility to conduct a routine environmental compliance audit. Audits were used to comply with the operation’s ISO 14001 environmental management system. The scope of the audit was based on the legal and other requirements identified for the operation. Key elements of the audit included:

  • Title V air emission permit, including NSPS and NESHAP requirements
  • Wastewater discharge permit, including categorical effluent standards
  • State and Federal hazardous waste generator requirements applicable to large quantity generators
  • Industrial stormwater discharge permit requirements
  • EPCRA reporting under 311, 312, 313
  • TSCA and PCB waste handling and disposal requirements,
  • Above ground tank requirements
  • Underground storage tank requirements,
  • Other

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

RCRA and TSCA Compliance Audit For Multiple Facilities To Meet ISO 14001 Requirements

Thursday, November 7th, 2013

Caltha LLP Project Summary

Project: Combined RCRA and TSCA PCB Management Audit For 26 Facilities
Client:
Electric Utility
Location(s): 26 locations

Key Elements: RCRA hazardous waste audit, TSCA PCB management, Used oil management, Universal waste management, ISO 14001

Overview: Caltha was retained to conduct a compliance audit of 26 facilities to assess compliance with:

  • EPA hazardous waste rules (40 CFR Part 260-262)
  • Minnesota hazardous waste rules (MPCA Chapter 7045)
  • North Dakota hazardous waste rules
  • Federal and State requirements for used oil management (40 CFR Part 279)
  • Federal and State requirements for universal waste management (40 CFR Part 273)
  • EPA Toxic Substances Control Act (TSCA) requirements for PBC management (40 CFR Part 261)

Audits were conducted to satisfy ISO 14001 standards for scheduled audits, under ISO 14001 clause 4.5.2.1. Audits were completed with a combination of records review and on-site inspections.

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

Regulatory Compliance Audit and Due Diligence For Minnesota and North Dakota Food Manufacturing Plants

Sunday, September 1st, 2013

Caltha LLP Project Summary

Project: Compliance Audit and Environmental Due Diligence For Minnesota and North Dakota Food Manufacturing Plants 
Client:
 International Food Manufacturing Industry 
Location(s):
Minnesota and North Dakota

Key Elements: Environmental Compliance Audit, Phase 1 Environmental Site Assessment

Overview:  Caltha was retained by this multinational food manufacturer to conduct an environmental regulatory compliance audit and a Phase I ESA at two of its plants located near Minneapolis, Minnesota and near Bismarck, North Dakota. Compliance audits were conducted to assess compliance with EPA, Minnesota Pollution Control Agency (MPCA), and Hennepin County requirements in Minnesota, and EPA and North Dakota Department of Health (NDDH) requirements in North Dakota. Regulatory requirements evaluated included:

  • Clean Air Act,
  • Clean Water Act,
  • RCRA hazardous waste and solid waste requirements,
  • Emergency Preparedness and Community Right-to-know Act (EPCRA) requirements,
  • Toxic Substance Control Act,
  • Above and underground tank requirements,
  • OSHA Hazard Communication.

Caltha also completed a Phase I Environmental Site Assessment (ESA) for both sites, in accordance with ASTM E1527-05.

 

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

Phase 1 Environmental Assessment and Compliance Review For Racine, WI Facilities

Monday, August 12th, 2013

Caltha LLP Project Summary

Project: Environmental Due Diligence, Phase 1 ESA and Compliance Assessment For Operations Near Racine, Wisconsin
Client: Real Estate Holding Company
Location(s): Wisconsin
Key Elements: Pre-acquisition Due Diligence, Phase I Environmental Assessment, Permit Review

Overview: Caltha was retained by this Real Estate Holding Company to conduct environmental due diligence of three properties located near Racine, Wisconsin they intended to acquire and continue to operate. Caltha staff conducted a Phase 1 ESA in accordance with ASTM standard practice E 1527-05. The ESA was augmented with a review of business risks associated with the acquisition and operation of these three existing businesses. Although no Recognized Environmental Conditions were identified, several business risks were revealed, including lack of spill prevention and control measures required under Federal rules, and lack of a State air emission permit for certain VOC emitting sources. Caltha recommended that both deficiencies be addressed prior to closing.

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

Environmental Compliance Audit For Iowa Food Ingredient Manufacturer

Monday, July 29th, 2013

Caltha LLP Project Summary

Project: EHS Compliance Audit For Iowa Food Ingredient Manufacturer
Client: Food Ingredient Manufacturer
Location(s): Iowa

Key Elements: Multi-media Compliance Audit

Overview:

Caltha was retained by this food ingredient manufacturer to conduct a multi-media compliance audit of its operations located in northwest Iowa. The operations were self certified as being in conformance with the Environmental Management System (EMS) requirements specified under ISO 14001. The audit was being conducted in advance of a planned merger and was required by the prospective business partner.

The scope of the compliance audit included applicable Federal, State and local regulations:

OSHA
Hazard Communication


EPCRA
EPCRA 311-312
EPCRA 313


Hazardous and Solid Waste Management
Federal RCRA rules

Iowa waste rules

Universal waste rules


Air
Federal air emission rules

Federal NESHAP standards

Iowa air emission permit

Iowa air emission rules


Clean Water Act
Authorized/Unauthorized Discharges

Iowa Stormwater Discharge Permit compliance

SPCC Rule Compliance

Iowa Spill Notification and Reporting

Federal Industrial pretreatment rules

Local Industrial discharger permit compliance


TSCA
Current registration

Inventory Update Rule IUR Reporting

Chemical Data Rule CDR Reporting


Tanks
Iowa aboveground tank rules

Iowa underground tank rules

The audit was completed under attorney client privilege through external legal counsel.

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

Air Permit Compliance Assessment and Option D Registration Permit Source Review

Thursday, May 30th, 2013

Caltha LLP Project Summary

Project: Air Permit Compliance Audit and Registration Permit Tracking Review

Client: International Beverage and Food Product Company

Location(s): Minnesota

Key Elements:  Air Emission Reporting Review, Air Emission Inventory, Permit Compliance Assessment

Overview: This facility retained Caltha to conduct a review of air permit compliance with the MPCA Option D Registration Permit. The review was prompted by recent staff  turn-over at the facility and an impeding multi-media audit being conducted by the corporate group. Facility management wanted to assure that all applicable air emission sources were permitted, emission tracking systems were accurate and complete, and that new staff responsible for on-going permit compliance activities were provided with ”on-the-job” training .

Caltha staff conducted on on-site inspection of the facility to identify all equipment and processes which were subject to air emission permitting. Emission tracking records and calculation spreadsheets were reviewed to confirm that all applicable emission sources were included and that calculations were accurate. Some revisions to spreadsheets were required. Caltha staff then provided training to facility staff on new tracking procedures.

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

Environmental Compliance Audit For Georgia Chemical Repackaging Plan

Wednesday, April 3rd, 2013

Caltha LLP Project Summary

Project: Multi-media Environmental Compliance Audit
Client: Chemical Repackaging Plant
Location(s): Georgia

Key Elements: Compliance audit

Overview: Caltha preformed a multimedia compliance audits for this chemical mixing and repackaging operation located near Atlanta, Georgia. The scope of the audit included Federal, State, County and City requirements in addition to company policies and industry standards applicable to the operations environmental aspects. Regulatory programs addressed in the audit included:

OSHA
Hazard Communication

EPCRA
EPCRA 311-312,
EPCRA 313

Hazardous and Solid Waste Management
Federal RCRA rules
State waste rules
Universal waste rules

Clean Air Act
Federal air emission rules
Federal NESHAP standards
Federal RMP rule
Site air emission permit
State air emission rules

Clean Water Act
Authorized/Unauthorized Discharges
Stormwater Discharge NEC compliance
SPCC Rule Compliance
Spill Notification and Reporting
Federal Industrial pretreatment rules
Industrial discharger permit

TSCA
Current registration
Inventory Update Rule IUR Reporting
Chemical Data Rule CDR Reporting

Tanks
Aboveground tank rules
Underground tank rules

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