Environmental & Compliance

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Permitting & Audits

Seneca can lend our environmental compliance expertise to helping your industrial operation understand the variety of permits and prepare for the variety of audits required.

Air Quality

• Air Source Construction Permitting: Required prior to the construction of an air pollution source.
• Title V Permitting: An air pollution source is considered “Major Source” if the facility has the potential to emit (PTE) >100 tons of criteria pollutants or emissions of a single HAP greater than 10 tons or combined HAPS greater than 25 tons.
• Emission Inventory Questionnaires (EIQ): Emissions are reported through the EIQ from a facility that has a Title V Permit yearly and their permit fees are calculated from the emissions reported. Minor sources have to conduct an EIQ every 3 years to report their emissions from the prior year. No fees are associated with the Minor Source EIQ.

SPCC

• Spill Prevention Control and Countermeasure Plan (SPCC): If a facility is storing product in an AST greater than 1,320 gallons or in an UST greater than 42,000 gallons of oil it is required to have a plan.

Water Quality

• Industrial Pretreatment Agreement: Required by a facility if planning on using a city’s Public Owned Treatment Works (POTW).
• NPDES (domestic wastewater) Permitting: Required by a facility if the facility disposes of domestic wastewater in a county-approved septic system.
• NPDES (stormwater) Permitting: General permitting covers common conditions associated with discharge of industrial wastewater.
• Stormwater Pollution Prevention Plan (SW3P): If an industrial facility is within one of the 11 categories of stormwater discharges associated with industrial activity that discharge or have the potential to discharge stormwater to a municipal separate storm sewer system (MS4) or directly to waters of the United States, it requires authorization under a NPDES industrial stormwater permit. Operators of construction sites one acre or larger (including smaller sites that are part of a larger common plan of development) are required to obtain authorization to discharge stormwater under an NPDES construction stormwater permit.
• NPDES (wastewater) Permitting: Required if a facility plans to discharge wastewater to a stream or by land application.

Emergency Planning and Community Right To Know (EPCRA)

• Emergency Planning and Response Reporting (Tier 2): Facilities that have MSDSs for chemicals held above certain quantities are required to submit either copies of their MSDSs or a list of MSDS chemicals to SERC, LEPC and their local fire department. Facilities that need to report under EPCRA section 311 must also submit an annual inventory report for the same chemicals. This inventory report (Tier 2) must be submitted the SERC, LEPC and local fire department by March 1 of each year.
• Toxic Release Reporting (Form R): A plant, factory or other facility is subject to the provisions of Section 313 if it:
  • is included in a covered Standard Industrial Classification (SIC) code;
  • has 10 or more full-time employees (or the equivalent of 20,000 hours per year); and
  • manufactures, imports, processes or otherwise uses any of the EPCRA section 313 chemicals in amounts greater than the “threshold” quantities.
• Storage Tank Permitting/Registration: Several plans, permits and/or notifications are needed prior to installation of above ground or underground storage tanks.

Audits

• Environmental Compliance Audits: These are used to identify and correct discrepancies before they result in violations. These programs also demonstrate an organization's commitment to environmental compliance. These audits can be performed in conjunction with Health and Safety Audits.

Miscellaneous

• Waste Characterization / Lab Packs: Unknown waste must be characterized so that it can be disposed of properly.
• Emergency Management Plans: These encompass all hazards and related planning areas including emergency and disaster planning and preparedness, hazard identification and mitigation, emergency response, disaster recovery, business continuity and resumption, crisis management, continuity of operations and related areas.
• Hazardous Waste Storage, Disposal or Treatment: Permits are required if a facility plans on treating, storing and/or disposing of hazardous waste.