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Presented by:Dan Cooper, P.E.
Senior Client ManagerEnvironmental UpdateMay 24, 2018
of Client Service
Northeast Alabama Environmental and Safety Conference
May 24, 2018
• Environmental Update – What is new in ADEM Programs?
• Electronic Reporting
– Permit Compliance Inspections – Enforcement Strategy
What’s New ?
• Electronic Reporting–Air Emissions
•Air Emissions Electronic Reporting System (AEERS)
–Wastewater Discharge DMR•e-DMR
ADEM Web Page
• e-Gov Portal
ADEM e-Government Portal
• AEERS• E-DMR• E-DWRS• E-NOI• E-Pay• E-Permit
AEERS• Electronic method for submitting facility emissions data as required in Title V of the Clean Air Act.
AEERS e-page
• Cover Page– Facility manages
• Users– ADEM manages
• Responsible Officials– Facilities Details Report
• Federal ECHO Profile
Air Attainment Status
• All Areas in Jackson and DeKalb Counties are designated as Attainment for All Air Quality Standards.
• Should make in easier to expand production and obtain air permit modifications.
Water Permits
• General Operational Stormwater Permit– Industry Specific
• Individual NPDES – To receiving stream
• State Indirect Discharge (SID) – To publically owned treatment system
• No Exposure Certification
e-DMR
Discharge Monitoring Reports –e-DMRs
• Monitoring results shall be summarized for each month on a Discharge Monitoring Report (DMR).
• The DMR shall be submitted so that theDMR is received by the Director no later than the twenty-eighth day of the month following the reporting period specified in the permit.
• DMRs shall be submitted electronically by the permittee to the Director in compliance with rules 335-6-1-.04 and 335-6-5-.14.
StormwaterPollution Prevention
• Integrated Best Management Practices (BMP) Plan– General Facility Information– Potential Pollution Sources– Control Measures– Inspections and Testing– Training – Record Keeping
No Exposure Certification
• “The industrial facility operator must maintain a condition of no exposure at its facility or site in order for the no exposure exclusion to remain applicable. If conditions change resulting in the exposure of materials and activities to stormwater, the facility operator must obtain coverage under an NPDES stormwater permit immediately”.
Common Violations• Container incompatibility. • Containment drain valves left open.• Poor integrity of tanks.• No or inoperative overfill device(s) and/or no inspection
of the device(s).• Improper maintenance and inspection of containment
structures.• Inadequate recordkeeping.• No update to the plan with change of facility personnel,
material storage or plant operations.• Not permanently closing containers.• No records of training.
ADEM Enforcement Strategy
• Less Formal Actions– Discussion during Inspection– Telephone Call– Warning Letter– Notice of Violation (NOV)
McAbee Amendments
• Public Notices Required–Consent Orders–Administrative Orders–Litigation
Actions to Achieve and Maintain Compliance
• Read Permits– Draft and Final
• Monitor Water and Air Permit Limits– Independent Compliance Audit
• Local, State and Federal Rule Changes– ADEM Website
• Keep Paperwork in Order– Working Copy of Permits
Actions - Continued
• Know your permit expiration dates.• Keep a compliance calendar on your
computer or smart phone.• Know the various regulatory personnel.• Maintain Production Equipment.• Maintain Pollution Control Systems.• Remember Facility Appearance Counts.
OUR TEAM IS SAFETTL has an EMR of 0.85 and an OSHA incident rate of .59 (Industry Standard for our NAICS is .70).
OUR TEAM IS EXPERIENCEDOur team members are experienced in providing services to the Analytical Lab Testing, Construction Materials Testing, Industrial, Energy, Transportation, Geotechnical Engineering, Environmental Consulting and Civil Engineering Design markets.
OUR TEAM IS RESPECTFULTTL professionals are good stewards of the trust, resources and desires of our clients.
OUR TEAM IS RESPONSIVEWe have offices in Alabama, Georgia, Tennessee and Texas and can assemble teams to respond to the needs of our clients anywhere in the U.S.
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