The Clean Air Act (CAA) of 1970 is a federal law under which the U.S. Environmental Protection Agency sets limits on specific air pollutants, including limitations on how much can be in the air anywhere in the United States. Although the CAA is a federal law, it obligates states to do much of the work to meet its requirements. In Michigan, the Department of Environment, Great Lakes, and Energy takes the lead in carrying out the CAA, along with support from tribes and local governments.
Envirologic's Compliance Group assists our clients by determining what regulatory requirements are applicable to their facilities and then helping them to prepare the necessary documentation, permits, plans, etc., to comply with requirements. This profile examines two projects where our Compliance Group has provided services; one project focuses on a new facility where an air use permit was necessary, while the other discusses a facility that received a violation notice for not complying with air quality regulations.
Envirologic provided air emission compliance services to a Michigan manufacturer that produces body panels for recreational vehicles. The manufacturer anticipated a significant increase in production. Their existing air use permit specified certain limits, which needed to be increased to accommodate the new production. Envirologic was contracted to determine the associated regulatory requirements, prepare a new permit application, and update their recordkeeping system to be consistent with their new permit.
Envirologic has a long history of providing air quality compliance services as needed to a Michigan paper converter that manufacturers bags, wraps, and other food packaging products. Over the years, our services have included evaluating their facility's air emissions, determining the applicability of various environmental regulations, developing and implementing tailored compliance programs, assisting with air emissions recordkeeping, and responding to regulatory inquiries on the client's behalf.
In 2019, the Air Quality Division of the Michigan Department of Environment, Great Lakes, and Energy (EGLE) inspected the facility. During the inspection, EGLE issued a violation notice due to the lack of various required records.
The client retained Envirologic once again to prepare and implement a plan to correct the violation and present information to EGLE that showed the client's compliance with air quality regulations. Envirologic conducted a facility inspection to determine current on-site operations and reviewed the facility's previous three years of data for monthly production and material use. This data was then used to populate the client's existing recordkeeping system. From this data, Envirologic determined that monthly emissions met the Rule 290 exemption limits and submitted the resulting records to EGLE. The facility is now in compliance.