Compliance Case Studies
Environmental Compliance Assessments and Response Actions, Permitting, Consulting and Assistance
Confidential Auto Supplier
Superior was retained by an auto supplier to assist with obtaining a construction permit to expand facilities in Howell, Michigan. Due to air emission odor complaints from a neighbor, the Genoa Township Board tabled a decision on the requested permits for 18 months, greatly impacting the company's ability to expand its business.
Superior developed the scope of work to complete the first phase of the operation. After assessing the situation, a team of experts were assembled, which included Superior and a subcontractor. The team was successful in obtaining limited permit approval that allowed the plant expansion to commence through permits issued by the township and county. A new Thermo Oxidizer was designed and installed to address potential emissions or odors and alleviate community concerns.
Follow-up work involved a second phase of the project regarding air emission/odor monitoring with potential for preparation of a Michigan Department of Environmental Quality (MDEQ) Air Permit.
Environmental Compliance Audits, Waste Materials Inventory and Hazardous Materials Management Plan Preparation, and Compliance Remediation
Confidential Communication Company
Superior was retained by a confidential communication company to complete environmental compliance audits for several facilities in Washtenaw County, Michigan. Superior personnel conducted a walk-over of the properties and generated site maps illustrating relevant site features such as hazardous materials storage locations, storm drains, potential spill flow pathways, and traffic areas. Superior personnel interviewed on-site personnel at each location to acquire an understanding of the daily operations and waste streams specific to the location.
At the maintenance facilities, an inventory was completed of all existing waste materials, including automotive service fluids, fleet vehicle hazardous materials (propane), and waste materials generated during the service of fleet vehicles. At central office facilities, lead acid battery inventory and on-site chemical usage (household quantities) was documented. Superior inventoried and tabulated this information for each location to present to the Washtenaw County Environment and Infrastructure Services Pollution Prevention Program. This information and data gathered during the site reconnaissance activities were used to prepare a Hazardous Materials Management Plan for submission to Washtenaw County for each property as part of the state and local regulatory requirements.
Washtenaw County Department of Environmental Health Regulation personnel identified a source of potential environmental impact beneath a telephone pole storage rack during a routine facility audit at one of the confidential communication company fleet locations. At the request of our client, Superior conducted a site investigation to identify the contaminants present, investigated the extent of the impact beneath the pole rack, and developed a strategy for remediation of the impacted soil that included sampling and waste characterization. Our client also implemented alternative housekeeping practices proposed by Superior for pollution prevention and minimization.
Following completion of the remedial soil excavation activities, laboratory analytical data verified that no impact remained to the native soil beneath the pole rack. A concrete pad was constructed beneath the pole rack to retain any future drips or leaks from impacting the environment. Based on the investigative and remedial activities completed, no further action was warranted and the site remained in compliance.
Air Permitting for Parts Remanufacturing Plant and Permit to Construct and Operate
Confidential Tier 1 Manufacturing Supplier
A major industrial manufacturing company retained Superior to prepare the application for an air permit to construct and operate its new manufacturing facility in north-central Indiana. This diversified company, known mainly as a Tier 1 automotive parts manufacturer, is also a premier re-manufacturer of locomotive diesel power assemblies, which was the operation to which this project applied.
The operations were previously permitted but were being moved to a new location, making it a new facility in the eyes of the Indiana Department of Environmental Management (IDEM) Office of Air Quality. Additional equipment and processing activities also were being added and required first time permitting. Due to time constraints on equipment installation and desired startup, submittal of the permit application was expedited.
Superior first performed a site visit to the old and new plant locations to develop an air emissions inventory by identifying all potential sources of air emissions and locations of all exhaust vents and stacks. As a re-manufacturing operation, the primary activity was metal machining to restore worn assembly components with related combustion- and electrically-heated washing operations, painting, and other solvent-based activities.
The permitting action for the old location was reviewed next, and the previous Potential to Emit (PTE) and permitting determinations for the equipment to be relocated were re-analyzed. The PTE of the additional equipment also was determined to assess the full regulatory and permitting status for the new source, after which the permit application could be prepared and submitted.
The unique aspect of this project was the re-evaluation of particulate matter PTE for abrasive blasting. In the previous permit, the abrasive blasting in the facility’s old location was the most significant emitting activity, resulting in issuance of a state-level operating permit. In the new permit, Superior identified regulatory determinations made by the IDEM Office of Air Quality for similar abrasive blasting operations in which the particulate matter controls had been approved as integral-to-process, rendering the particulate matter emissions insignificant. Superior submitted justification for this and IDEM issued an exempt status for the operation.
Emergency Generator Air Permitting
Confidential Communication Company
Superior provided environmental consulting services to update air permits for a telecommunication company’s central offices in Chicago, Illinois and Indianapolis, Indiana. It was determined in an internal audit that the emergency generators installed at a number of their central offices required air permitting. Superior augmented the client’s environmental staff to perform this time-sensitive task.
The activities at the telecommunication company’s central offices are considered critical, and their full-time operation is guaranteed by emergency electrical generators with diesel fuel systems. While the United States Environmental Protection Agency (USEPA) and both the states of Illinois and Indiana recognize in their air regulations the necessity of emergency generators and accommodate their use in the form of standard exemptions and special consideration in calculating Potential to Emit (PTE), the exemptions have thresholds of applicability. In Indiana, if a sufficient number of such units are present to exceed the threshold, permitting is required, which was the case with the eight generators at the downtown Indianapolis Central Office.
The Chicago area was a special case where local city and county rules did not recognize the state exemption threshold. All combustion units at commercial offices, including hot water heaters and building heat sources, in the City of Chicago and Cook County, Illinois require installation and operating certificates.
Superior inspected office locations, gathered equipment and stack data, and prepared applications for new or amended air installation and operating permits. A file review was also performed at the permitting agencies for the Chicago and Cook County Central Offices. The absence of permitting was determined, in most cases, due to the replacement of equipment, and in these cases the permits simply needed to be updated with the new information.
Compliance Description, Air
Confidential Helicopter Parts Manufacturer
Superior was successful in applying for and gaining approval of a Michigan Department of Environmental Quality (MDEQ) Air Permit to Install for a high profile helicopter parts manufacturer. Superior was retained at the initial launch of a project that added a piece of process equipment to the existing facility operations. Superior operated in the capacity of supplying regulatory oversight for the project, and closely collaborating with facility management to gain intimate knowledge of the equipment being installed and the regulatory requirements applied to the process equipment. Calculations were completed along with all required MDEQ forms and required information was submitted to the MDEQ Air Quality Division (AQD). Through Superior’s healthy professional relationship with MDEQ regulators, Superior was able to expedite the approval process by nearly 2 months. This allowed the client to have ample time to test the process equipment and fine-tune it before beginning full scale operation, allowing them to provide their customers with the highest level of quality starting with the very first part.
Spill Prevention, Control and Countermeasures Planning
Major Automotive Parts Manufacturer in Northern Ohio
A major automotive parts manufacturer contracted Superior to develop a spill prevention plan for their northern Ohio plant. Under the federal Spill Prevention, Control & Countermeasure (SPCC) rule, which stipulates oil pollution protection requirements for industries of this nature, the client needed a new SPCC plan due to significant changes in site operations.
Superior worked closely with the client to fully understand their needs and the methods of operation. This required intensive research of the new facility operations. Superior defined the potential hazards for spills, methods for handling materials, and a preparedness plan, which includes listing the appropriate spill response equipment in the event of an emergency. In addition to being a management tool, the document was used for instructional purposes for employees handling materials and for establishing an efficient petroleum products inventory system.
Superior's close working relationship with the client and ability to design a quality SPCC plan enabled us to meet the client's criteria and schedule. The flexibility of the plan allowed for smooth implementation of any future changes in the client's needs or methods of operation. The automotive manufacturer now has a prevention plan that maintains environmental compliance and allows for continued safe plant operation.
Storm Water Pollution Prevention Plans for Multiple Railroad Facilities
Confidential Rail Operator
A short-line rail operator and a railroad industry subcontractor retained Superior to evaluate storm water compliance status at a variety of their operating rail sites in Michigan and to prepare Storm Water Pollution Prevention (SWPP) Plans for each site. Superior worked closely with the client as a necessary step at each location to fully understand their needs and methods of operation in order to draft the document.
Superior customized a SWPP Plan to fulfill the client’s requirements while meeting state and federal regulations. This approach included intensive research of facility operations to develop a proper plan. The SWPP Plan defined the potential hazards for spills, methods for storing and handling significant materials, and contained a preparedness plan, which included a listing of the appropriate spill response equipment in the event of an emergency. In addition to being a management tool, the document is being used as an instructional guide for employees handling significant materials and for establishing an efficient petroleum products inventory system.