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.
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:
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:
The Clean Air Act (CAA) (40 CFR 50-95) and associated amendments require the USEPA to develop and enforce regulations to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health. The CAA Amendments of 1990 extended the breadth of protection for the public and environment by addressing increased reductions in air pollution, including urban air pollution, acid rain, and toxic air emissions. The 1990 Amendments also established a national permits program and an improved enforcement policy to help ensure better compliance with such legislation and resulting regulations.
BBJ Group air emissions professionals support our clients to effectively and efficiently meet emission requirements by sampling outfall, auditing operations, testing stack emissions, and providing information for permits, including: Title V, NSR, NNSR, PSD
In addition, BBJ Group supports clients with Occupational Safety & Health Administration-related evaluations pertaining to indoor air quality, time-averaged decibel levels, and vapor intrusion.
From time-to-time, emission sampling results indicate problems with production processes or treatment systems. When this has occurred, BBJ Group helps clients identify the sources of these problems and recommends cost-effective solutions for upgrades, repairs, or replacements.
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.
Amber Cicotte, CHMM
Andrew Bajorat, CHMM