Service Environmental Engineering, Inc, (SEE) can provide a responsive and complete regulatory compliance package that assists in meeting federal, state and local regulatory standards. Our staff's working knowledge of CERCLA, RCRA, the Clean Water Act, the Clean Air Act, and Waste Managements Acts allows for regulatory negotiation, environmental permit application and compliance reporting services. These services may be integrated with SEE's other services, depending on the clients requirements. SEE can assist with the following permit and compliance issues:
Service Environmental Engineering, Inc, offers an environmental audit and the development of an auditing program to assist with compliance issues. The objectives of an audit are to improve facility environmental performance, provide effective solutions to common environmental problems, focus attention on current and upcoming regulatory requirements and develop check-lists and protocols which will assist your facility to better manage itself.
Service Environmental Engineering, Inc, can provide professional support to clients to produce:
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.
In general, the following activities are regulated under environmental laws and your facility may need a permit: Manufacturing, Public Warehousing, Transportation, Mining, Open Landfills, Steam Electric Power Plants, Recycling Facilities, Waste Water Treatment and Hazardous Waste Storage Facilities. Your SIC code will tell you the kind of permit that is required. If the industrial materials and products that you use or produce are in contact with storm water, then it is likely that your facility will need a Storm Water Pollution Prevention Plan (SWPPP) in operation so that there is the required level of protection for the receiving waters. If your facility is in an area where there are combined sewers, you likely will not need an SWPPP. It is possible that there is no exposure at your facility and you can obtain a "No Exposure Certification" and you will not need a permit or a SWPPP. Service Environmental Engineering (SEE) can help you with this determination.
Service Environmental Engineering has prepared and managed more than 100 SWPPPs for a wide variety of industrial facilities in the Southeast Michigan Area. The preparation and implementation of the SWPPP is required for certain business codes per Federal Regulations. SEE can prepare your plan, be your Certified Storm Water Operator or work with your Certified Operator. SEE can be your go-between with Michigan Department of Environmental Quality (MDEQ) that oversees SWPPPs. SEE can perform the required inspections, sample collections or even help to train your employees to perform the needed activities.
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:
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.
Certain industrial facilities may require a Special Discharge Permit which may include a Slug Control/Spill Prevention Plan (SC/SPP) depending on the discharge from the facility. The Industrial Waste Control Division of Detroit Water ad Sewage Department, the Great Lakes Water Authority, and other units of government allow the discharge generated and/or accumulated form groundwater, storm water, site remediation (not subject to SARA and CERLA) and other waste water sources into the particular discharge system in accordance with certain conditions. The following are typical and SEE can help your facility meet these conditions by completing any application, maintaining any pretreatment system, collecting required samples and performing any periodic reporting and meeting with any inspectors.
The facility cannot discharge any waste water into the specific system without a Special Discharge Permit.
The permit application must include:
The public water and sewage department can accept a certain maximum special water discharge of, for example, 100,00 gallons per day based on a twenty-four (24) hour period. The discharge may be further limited by the sewer carrying capacity of the connected sewer outfall.
The applicant shall install a waste water treatment system pretreatment system when it is determined that it is necessary.
The public water and sewage department shall inspect the remediation and treatment facility before and during any discharges made.
No permit will be issued until the entire requirements are met.
The Special Discharge Permit shall contain discharge limitations, monitoring requirements, design and location of the treatment system map and other general conditions needed for compliance.
The applicant shall comply with established conditions and requirements as issued on the Special Discharge Permit. Failure to comply may result in immediate permit revocation and appropriate enforcement action.
Service Environmental Engineering has performed the above requirements for industrial facilities in a satisfactory manner - SEE has maintained the Special Discharge Permit for one local facility for nearly fifteen years.
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:
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:
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.
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