Posts Tagged ‘Michigan’

Updated Great Lakes Restoration Initiative Action Plan Public Comment Meetings

Wednesday, May 15th, 2013

The Great Lakes Interagency Task Force has scheduled meetings for the public to provide input to a planned update of the Great Lakes Restoration Initiative Action Plan.

The updated Action Plan would direct Great Lakes restoration for fiscal years 2015-2019. The public may comment directly to the federal agencies and to the Great Lakes Advisory Board (GLAB), a panel of experts established to provide recommendations to the federal agencies. Comments may be given at any of the following scheduled meetings:

•May 21-22 – Great Lakes Advisory Board Inaugural Meeting & Public Comment to GLAB
•May 23 – Webinar
•May 28 – Buffalo, New York.
•May 30 – Milwaukee, Wisconsin.
•June 3 – Webinar
•June 5 – Cleveland, Ohio.

In February 2010, the Task Force released the GLRI Action Plan for FY2010-2014. The Action Plan identified goals, objectives, measurable ecological targets, and specific actions to help rehabilitate the Great Lakes. The Action Plan targets investments to reduce toxic contamination, rehabilitate fish and wildlife habitat, improve nearshore health, reduce nutrients and other land-based pollution, prevent invasive species, and promote accountability, education, and collaboration.

Temporary Corporate HSE Staffing – Site Remediation Oversight

Friday, March 22nd, 2013

Caltha LLP Project Summary

Project: Corporate HSE Staffing-Site Remediation Oversight
Client: Multi-national Chemical Company
Location(s): California, Illinois, Indiana, Minnesota, North Carolina, Ontario, Canada, Michigan, Kentucky, Arizona

Key Elements: Environmental Health & Safety Staffing, Site remediation

Overview: This chemical company contracted with Caltha to provide temporary staffing in its corporate HSE Department for the position that oversaw numerous site remediation projects being conducted across the US and Canada. Due to staff turnover the position needed to be filled quickly to assure that process on projects continued, on-site contractors had questions and issues addressed, and that required agency submittals were reviewed, approved and submitted on time. Caltha provided a highly experienced HSE professional to fill the position until the corporation could hire a permanent replacement. Caltha staff were then able to provide transitional support.

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

Review and Updates To Existing List of ISO 14001 Legal and Other Requirements

Thursday, March 21st, 2013

Caltha LLP Project Summary

Project: Review and Documentation of Legal and Other Requirements
Client: International Steel Manufacturer
Location(s): Michigan

Key Elements: Review of regulatory requirements, preparation of ISO 14001 documentation of legal and other requirements

Overview:  Caltha was contracted by the client to conduct a review of their existing listing of “Legal and Other Requirements” prepared to conform to ISO 14001 Clause 4.3.2. An environemtnal management system that conformas to ISO 14001 must include a procedure to identify legal and other requirements that the oganization believes are applicable to its operations. The organization also needs to have a system to be able to access the current version of these requirements. The list of requirements is also essential for complying with other Clauses of the standard. This list becomes the scope of scheduled compliance audits the organization must perform. Caltha provided a technical update to the organization’s existing listing of requirements, which included several new regulations that had been recently promulgalted on both the Federal and STate level.

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

Logistics Industrial Storm Water Permitting & Compliance

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: International Retailer
Location(s): California, Washington, Utah, Georgia, Florida, Virginia, North Carolina, Pennsylvania, Ohio, Massachusetts, New York, Kansas, Virginia, Louisiana, Texas, Tennessee, Minnesota, Illinois, Indiana, South Carolina, Colorado, Nevada, New Jersey, Connecticut, Missouri

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this international retailer at multiple logistics and warehousing locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State or EPA application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

SWPPP and SWP3 Certification – What Is Certified, What States Require Certifications and Who Needs To Sign?

Thursday, March 7th, 2013

Under State and EPA stormwater permitting rules, a Stormwater Pollution Prevention Plan (SWPPP) may need to be certified. This signed SWPPP Certification is in addition to other types of certifications that may be required. The types of certifications will vary depending on the State and type of permit; in addition to SWPPP Certification, some other types of certifications might include:

  • Non-stormwater Discharge Certification,
  • No-exposure Monitoring Exemption Certification;
  • Heavy Metal No-exposure Certification (in Texas);
  • Annual Site Compliance Certifications;
  • Endangered Species Certifications;
  • Historic Places Certification,
  • Environemental Professional Certifiaction (in Indiana)
  • Certified Stormwater Operator Certifiacxtion (in Michigan)
  • Others.

SWPPP Certification – What is Being Certified?

In most cases, the SWPPP Certification statement indicates that the SWPPP has been 1) prepared; 2) implemented and that 3) the SWPPP conforms to the requirements of the discharge permit. The SWPPP Certification generally includes a statement that the information documented is correct. The exact wording and scope of the certification statement will vary from State-to-State, but here is an example:

“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”
Who needs to certify the SWPPP?

In some States (for example, Michigan, Indiana, Connecticut and others), the SWPPP needs to be signed by a certified or qualified environmental professional.

In most States, the SWPPP also needs to be signed by a Responsible Company Officer, or his/her duly authorized representative. State or EPA rules will determine who can sign the SWPPP. This SWPPP Certification can be in addition to any certifications needed by a qualified environmental professional.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

EPA Rulemaking To Address State Requirements For Startup, Shutdown, or Malfunction

Friday, February 22nd, 2013

The EPA is proposing to take action on a petition for rulemaking filed by the Sierra Club in 2011 concerning the treatment of excess emissions in state rules by sources during periods of startup, shutdown, or malfunction (SSM). EPA is proposing to grant in part and to deny in part the request to rescind its policy interpreting the Clean Air Act (CAA) to allow states to have appropriately drawn state implementation plan (SIP) provisions that provide affirmative defenses to monetary penalties for violations during periods of SSM. The EPA is also proposing either to grant or to deny the Petition regarding existing SIP provisions related to SSM in each of 39 states identified in the petition.

For each of those states where EPA proposes to grant the petition concerning specific provisions, EPA also is proposing to find that the existing SIP provision is substantially inadequate to meet CAA requirements and proposes a “SIP call.” For those affected states EPA will require the states to submit a corrective SIP revision. Comments on the proposed actions must be received on or before March 25, 2013.

Through this rulemaking, EPA intends to clarify its interpretation of the CAA regarding excess emissions during SSM events. EPA may find specific SIP provisions to be substantially inadequate to meet CAA requirements; if a state’s existing SIP provision allows an automatic exemption for excess emissions during periods of startup, shutdown, or malfunction, then the EPA may determine that the SIP provision is substantially inadequate because the provision is inconsistent with requirements of the CAA.
The affected States include:

Alabama
Alaska
Arizona
Arkansas
Colorado
Delaware
District of Columbia
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
New Hampshire
New Jersey
New Mexico
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Rhode Island
South Carolina
South Dakota
Tennessee
Virginia
Washington
West Virginia
Wyoming

EPA Proposes FIP For Taconite Operations In Minnesota and Michigan

Wednesday, February 6th, 2013

EPA is finalizing a Federal Implementation Plan (FIP) to implement emission limits that represent Best Available Retrofit Technology (BART) for certain taconite ore processing facilities in Minnesota and Michigan. The Clean Air Act (CAA or the “Act”) and the regional haze rule require implementation plans to contain BART emission limits for sources subject to BART in order to meet the national goal of preventing any future and remedying any existing impairment of visibility in mandatory class I Federal areas arising from manmade air pollution. This final rule is effective on March 8, 2013.

The regional haze rule required states to submit State Implementation Plans (SIPs) to implement the rule’s requirements in 2007. Neither Minnesota nor Michigan submitted regional haze SIPs by the required date. In 2009, EPA formally found that both Minnesota and Michigan had failed to timely submit SIPs addressing the regional haze requirements, which triggered EPA’s duty to either promulgate a regional haze FIP for Minnesota and Michigan or approve subsequently submitted regional haze SIPs.

Minnesota subsequently submitted to EPA a regional haze SIP in 2009, a draft supplement in January 2012, and a final supplement in May 2012. EPA had previous approved in part the both states’ regional haze SIPs for addressing most regional haze requirements. However, EPA deferred action on the states’ BART determinations for taconite facilities in order to further evaluate the sufficiency of those determinations. On August 15, 2012, EPA proposed to disapprove in part the states’ regional haze SIPs with regards to their BART determinations for taconite facilities, and to propose a FIP. Although EPA has not finalized its disapproval of the states’ BART determinations, EPA believes it has the continuing authority and obligation to promulgate a FIP based on its earlier finding that Minnesota and Michigan had failed to timely submit regional haze SIPs. EPA’s duty to promulgate a FIP ends only when it has fully approved a state submission.

What Are Great Lakes Water Quality Wildlife Criterion and How Are They Calculated?

Wednesday, November 14th, 2012

The Water Quality Guidance for the Great Lakes System, also known as the Great Lake Initiative or GLI (40 CFR 132), created a few new types of water quality standards intended to be applied to waters in the Great Lakes basin.

A Great Lakes Water Quality Wildlife Criterion (GLWC) is intended to protect avian (bird) and mammalian wildlife populations in the Great Lakes basin from adverse effects resulting from the ingestion of water and aquatic prey taken from surface waters of the Great Lakes. These criteria are based on existing toxicological studies  and information about the exposure of wildlife species to the substance (i.e., food and water consumption rates).

Since toxicological and exposure data for individual wildlife species are very limited, a GLWC was calculated using a similar methodology to that used to derive noncancer human health criteria. Separate avian and mammalian values are developed using toxicity and exposure data for representative Great Lakes basin wildlife species.

Five wildlife species were selected to be representative of bird and animal species living in the Great Lakes basin which are likely to experience the highest exposures to bioaccumulative contaminants through the aquatic food web:

  • bald eagle,
  • herring gull,
  • belted kingfisher,
  • mink, and
  • river otter.