Regulatory Compliance Services

Environmental Audits

Service Environmental Engineering, Inc. personnel will perform a Limited Environmental Assessment Audit by conducting walk-throughs, discussions and reviews with administrative, management, and operations personnel to note significant observations that will be helpful in the assessment. In addition, SEE can provide comments or suggestions based on conditions noted in the compliance audit, for changes in the operational procedures that may enhance safety in the work practice, minimize waste through recycling, or reduce compliance obligations through equipment or work practice’s changes.

Facility Compliance Audit may consist of the following:

Air Water RCRA Permits to Install NPDES/POTW ID Number Permits to Operate Storm Water Plan Prevention Resource Title V facilities’ Conservation and Recovery Act (RCRA)

Hazardous Waste Management

EPA Facility ID# / Manifests / Generator Type Annual Reporting / Record Keeping / Training Records Hazardous Waste Characterization / Labeling of Hazardous Waste Waste Minimization Assessment / Analytical Testing of Waste Streams

Oil and Waste Oil Management

Types of Oil shipped / Classification of the Oils / Analytical Testing of the Oils
Is the Oil shipped for recycling, recovery, or proper disposal?

Storm Water Pollution Prevention Plan

Is the plan updated, Signed, Permit Type, Facility Map, Quarterly Inspections?
Sampling Requirements, Visual Assessment Reports, Sampling Point or Points

Spill Prevention Control and Countermeasures Act (SPCC) Plan

The amount of Oil stored in Equipment / Tanks / Containers
Is the above ground storage greater than 1320 gallons
Is there oil storage in underground storage tanks

Emergency Planning and Community Right-to-Know (SARA Title III)

Hazardous Chemical Reporting, Reporting Requirements, Tier I Inventory Reporting, Tier II Inventory Information, Tire II Reporting, Safety Data Sheets, Amount of Chemicals stored on site, Sections 311 and 312 of SARA Title III, 313 Form “R”

Air

Daily, Monthly, Yearly Emission Levels, Any Permits.

The Spill Prevention, Control and Countermeasure (SPCC) Plan

If your facility has the capacity to store more than 1,320 gallons of oil substances in tanks or 55-gallon drums above ground or 42,000 gallons in tanks below ground and oil-filled equipment, it is likely in Michigan that you need a SPCC plan according to the Federal Regulations. A facility that stores, processes, refines, uses or consumes oil and is non-transportation related is potentially subject to the SPCC rule. The reason for this is that if there is a spill at your facility the navigable waters and shoreline could be endangered. Even a ditch leading to a nearby stream is of consequence.

The kinds of oils covered by the regulations include synthetic oils, petroleum and refined products such as mineral spirits, gasoline, diesel fuel, vegetable oils, animal fats and fluids but does exclude certain substances such as milk.

As required in Title 40 Part 112 of the Code of Federal Regulations (40 CFR 112), the SPCC Plan describes equipment, workforce, procedures, including record keeping, training, control including containment and provides adequate countermeasures to the discharge of oil. If there is a release of oil or certain other materials then there is release reporting that is necessary including that related to Michigan Part 5 rules of Michigan Act 451. Further, your plans have to be reviewed every five years.

There have been amendments and revisions to the Federal Regulations that may require that your plan be updated as soon as possible.
Clarification and changes in requirements include:

• Updating of criteria used to determine who must prepare a SPCC plan.
• Above ground storage tanks and underground piping must be tested periodically.
• Additional requirements for corrosion protection for underground piping.
• Increase in requirements for design, performance and the Professional Engineer (PE) certification of secondary containment systems.
• Clarification of requirements for certain mobile facilities to prepare SPCC plans.
• The owner's responsibility concerning training and implementation of the plan.
• Enhanced storm water management and record keeping requirements.
• Enhanced requirements for routine facility inspections and record keeping.
• Changes in training requirements for employees that handle petroleum products.
• Changes of requirements for the PE's role in SPCC Plan preparation and certification

In certain cases where your facility is not a bulk oil facility it may be advantageous or necessary for the facility to prepare a Pollution Incident Prevention Plan (PIPP) per Part 5 that is updated every there years. This plan must be submitted and certified to the State of Michigan whereas the SPCC Plan does not have to be submitted to the EPA. There are other related environmental plans that might meet your needs such as an Integrated Contingency Plan and a Facility Response Plan.

Service Environmental Engineering has prepared SPCC Plans for a range of facilities from bulk petroleum facilities to foundries and is ready to assist you to determine if you meet the requirements and prepare or help you prepare an SPCC Plan. Again, there must be signed management approval and certification of the plan by a registered engineer.

The Pollution Incident Prevention Plan (PIPP)

If your on-land facility has polluting materials that meet or exceed threshold management quantities (TMQs) or the Department of Natural Resource and Environment (DNRE) determines a release from your facility could cause substantial harm to the surface waters or ground waters of the state then your facility is required to have a PIPP and meet associated requirements. This is pursuant to Part 5 Rules promulgated under Part 31 of Act 451.

TQMs are as follows:

• For salt used, stored or otherwise managed on the contiguous properties.
  In solid form - 5 tons;
  In liquid form - 1,000 gallons
• For polluting materials listed in table 1 of the Part 5 Rules for a discrete use or at a storage area.
  Outdoors - 440 pounds:
  Indoors - 2,200 pounds
• For oil - DNRE-Part 5
  Single container or tank having a capacity of more than 660 gallons or total capacity of 1,320 gallons in above ground tanks and there are other polluting materials besides oil. (Underground tanks fall under other regulations.)

There are exemptions to the Part 5 rules. Many of these exemptions apply if the facility is subject to other specific regulations related to oil and gas, flammable or combustible materials and hazardous wastes. With the exemption there are still some requirements including surveillance, procedures, development of specific storage areas or containments and release reporting.

The components of the PIPP includes:

• Facility information including emergency contacts
• Spill control and clean-up procedures
• Inventory of polluting materials exceeding TMQs
• Site Plan
• Description of outdoor secondary containment for liquid polluting materials
• Other spill control measures
• General facility physical security methods
• Emergency notification procedures that include release reporting

New facilities or existing facilities that are changing operations that they will be above or meeting TMQs must have a PIPP completed before beginning those operations. Plans must be reviewed every three years or after any significant release.

Within a month after completion or modification of a PIPP, the owner or operator must notify the local emergency planning committee, the local health department and the DNRE District Office Part 5 Rules Program.

A certification stating that the facility is in compliance with all of the Part 5 Rules must be submitted to the DNRE. A voluntary submittal or the category of polluting materials is requested. The DNRE may want a copy of your PIPP.

PIPPs may be combined with Integrated Contingency Plans (ICP). An ICP may be the way to cover all bases if the facility is subject to multiple regulations.

Service Environmental Engineering has developed and reviewed PIPPs. Let us help your business meet your environmental compliance needs.