We manage energy project development, environmental permitting, remediation and compliance, insustrial hygiene, health & safety, auditing, environmental management, government relations. We solve your problems in all of these areas. We move quickly and dig deeply to reach your goals. We work wherever you are.
How can SMG help you?
SMG POV
I was informed at the KY Environmental Conference last week that Emission Inventory letters were being mailed. Due to some staff changes at DAQ, the deadline for the EIS has been extended this year until March 13th. If you are a DAQ permittee, be on the lookout for your letter with instructions to complete the electronic submittal.
The Division has had some personnel changes. Andrea Keatley has moved from Source Testing supervisor to the Division of Water, Water Quality section. The new EIS supervisor is Margaret Hunter. Kevin Flowers is retiring at the end of February. Jarrod Bell will temporarily fill in and has moved to a Director’s office position. Natasha Parker has replaced Jarrod Bell in the Frankfort regional office. Contact information is available at http://air.ky.gov/Pages/StaffDirectory.aspx.
New air permit application forms are expected to be filed in April. There is a formal review process which will take several months. The forms may be approved by October and will be posted on the DAQ website.
To stay up to date with regulatory changes, subscribe to DOW’s Regwatch from this link: https://secure.kentucky.gov/Regwatch/.
If you need assistance with the emissions inventory submittal, feel welcome to contact me at 502-587-6482 x211 or at pattym@smithmanage.com.
FEATURED PROJECT
PROBLEM
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG'S APPROACH
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
MG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
RESULTS
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.