EHS REPORTING

Environmental regulations are constantly evolving and becoming more stringent and complicated. While staying on top of the latest regulations and permit requirements can be difficult, failure to do so can result in fines, penalties, or lost revenue from interrupted business. In addition, businesses receiving large fines and penalties can also suffer from poor public perception.

BBJ Group helps clients identify the necessary environmental permits during pre-acquisition due diligence and can also provide Opinions of Cost for bringing the operations into compliance. Post-acquisition, BBJ Group can implement the permit requirements and assist clients with documenting permit compliance.  Our experience working with regulators and plant personnel helps us get permit applications and modifications approved efficiently.

WATER AND STORMWATER PERMITTING AND REPORTING SERVICES

The NPDES Program (40 CFR 122) was established by the Federal Water Pollution Control Act (FWPCA) Amendments of 1972. Under NPDES, all facilities which discharge pollutants from any point source into waters of the United States are required to obtain a permit. In order to minimize the impact of stormwater discharges from industrial facilities, the NPDES program includes an industrial storm water permitting component that covers 29 industrial sectors that require authorization under an industrial stormwater permit for stormwater discharges.

For some facilities, stormwater discharge events and/or discharges to sanitary sewer systems (which are regulated under NPDES via the permit applicable to the local POTW), sampling may be required.

BBJ Group professionals:

• coordinate sampling events,
• prepare a summary report of activities and data,
• submit the reports, as needed, to local and/or state agencies.

Although a SWPPP is not required for facilities which maintain a Certificate for No Exposure, facilities which are covered under an individual or general stormwater permit require a SWPPP to address operations with potential to impact stormwater discharges. BBJ Group professionals review the SWPPP when operational changes are proposed to determine if operational changes require updates to the SWPPP.

BBJ environmental consultants typically perform the following steps to determine water and stormwater permit needs:

• Review oil storage management practices and determine the applicability of a Spill Prevention, Control, and Countermeasures (SPCC) Plan and/or Facility Response Plan (FRP);
• Perform a general review of available SPCC Plans to identify major deficiencies and to determine whether or not the SPCC Plan appears to be current;
• Review existing waste-water discharges and determine applicability of a National Pollutant Discharge Elimination System (NPDES) Permit and/or a Storm Water Pollution Prevention Plan (SWPPP); and
• Perform a general review of available NPDES Permits and SWPPPs to identify major deficiencies and to determine whether or not the SWPPP appears to be current.

SOLID AND HAZARDOUS WASTE PERMITTING

Subtitle C of RCRA (Title 40 of the Code of Federal Regulation [40 CFR] Sections 261, 262, 264, 265, 266, 273 and 279) established a system for controlling hazardous waste, universal waste, and used oil, from generation to disposal. Operators must demonstrate they have adequately determined if the product is hazardous waste prior to transporting off site for disposal. If the product is considered hazardous waste, facility operators are further required to verify that the waste is managed, disposed, and/or recycled properly.

BBJ Group professionals review current processes and/or operations associated with the generation of waste materials, relevant facility permits, laboratory analytical results of waste product, and quantities of waste generated.

Based on the information provided, BBJ Group will determine the appropriate management, transport, disposal and recycling practices for the waste material. Annual and/or biennial reporting is required, based on generator size and state-specific hazardous waste tracking requirements.