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I was really pleased to attend The Midwestern States Environmental Consultants Association (MSECA) meeting last week on IDEM Programs and Policies. There was a great lineup of IDEM management speakers, and many relevant topics were discussed. Managers from the Offices of Air, Water, and Land Quality spoke about priorities and challenges. One overriding theme was doing more with less. Environmental agencies are flooded with more programs and regulations to implement and enforce with fewer resources. Competition for experienced workers exacerbates the problem. The average experience of the work force employed continues to decline. On a bright note, I was impressed with the enthusiasm and resolve to continue to make valuable improvements and effect positive change for the environment.
Lead in drinking water was noted as a crisis which has upstaged many other important Office of Water Quality priorities. The WOTUS rule changes and nutrient management were discussed. Be on the lookout to have phosphorus limits of 1 mg/l added to major NPDES permits. Additionally, over the next few years the permit by rule stormwater program will be phased out through the development of a number of general stormwater permits. Entities regulated under 327 IAC 15-5, 15-6, and 15-13, for example, will have to apply for coverage under the new permits, once available.
I was saddened to hear from Keith Baugues, Assistant Commissioner of the Office of Air Quality, that out of 40 permit writers 10 have less than one year of experience. Interpreting the intricacies of Clean Air Act implementation is onerous, and the loss of experienced personnel is not a problem that is easily remedied on a tight budget. The great news in air pollution, however, is that millions of dollars from the Volks Wagon Settlement have been earmarked for diesel NOx reduction in Indiana. This brings opportunities for funding natural gas, propane and electric vehicle/equipment projects.
IDEM is taking an innovative role in managing contaminated Site 0153. Instead of turning the site over to EPA for management within the Superfund Program, IDEM is working with stakeholders and has committed dedicated staff to coordinate the cleanup effort which involves over 200 potentially responsible parties. This solution yields more redevelopment options and local control. Additionally, the underground storage tank (UST) branch is working to address actuarial audit results of the Excess Liability Trust Fund (ELTF). Efforts are aimed at simplifying the claim processing and addressing pay out rates which are significantly higher than similar programs in other states.
MSECA was established to “advance the field of environmental consulting by improving the professional competence of our members through education and dissemination of information related to technical developments, regulations, training, and codes, all pertaining to environmental protection.” This event certainly supported its mission and helped me, a professional engineer licensed in the state, to keep current.
Please feel welcome to contact me at PattyM@SmithManage.com or 502-587-6482 extension 211 with questions or comments regarding environmental permitting and compliance.
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 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.
SMG 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.
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.