Environmental Programs

REGULATORY CONSULTANTS

STC personnel maintain up-to-date information on regulatory requirements and constantly track changing air quality requirements that have a major impact on existing sources of air emissions as well as new or modified sources.  We keep abreast of activities at the federal, state, and local levels.  Clients are provided information on applicability of technology control standards, such as New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT), as well as current permitting requirements and policies. Our experienced staff is familiar with the regulatory process and understand how to negotiate with regulatory personnel. STC’s principals have more than 25 years of experience in dealing with state environmental agencies and have been responsible for regulatory development and interpretation.

TIER II REPORTS

STC is available for Tier II preparation and submittal.

40 CFR Sections 355-372 requires facilities that have chemicals that require MSDS's, and that store more than the EPCRA threshold quantity for any of these chemicals to submit a list of these chemicals, or copies of their MSDS's to the SERC, LEPC, and local fire department.  This requirement is now met by submitting a Tier II Emergency and Hazardous Chemical Inventory Form for the applicable chemicals within 90 days of exceeding the threshold for that chemical.

Facilities covered by Section 311 must, under Section 312, submit annually an emergency and hazardous chemical inventory form,  called the Tier II form, for all applicable chemicals, to the LEPC, the SERC, and the local fire department.   Tier II forms provide the following information for each substance:

• The chemical name or the common name as indicated on the MSDS;
  

• An estimate (in ranges) of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount;
  

• A brief description of the hazards and manner of storage of the chemical;
  

• The location of the chemical at the facility; and
  

• An indication of whether the owner elects to withhold location information from disclosure to the public.
  

This is an annual report, due March 1, and covers the activity of the past calendar year.

FORM R REPORTS

STC is also available for Form R preparation and submittal.

EPCRA Section 304 (Emergency Planning and Community Right to Know Act) requires a facility to notify the SERC and the LEPC in the event of a release exceeding the reportable quantity of a CERCLA hazardous substance or an EPCRA extremely hazardous substance.

Businesses that produce, store, or use "Extremely Hazardous Substances" or CERCLA hazardous chemicals report to federal, state, and local authorities non-permitted releases of any listed chemical above threshold amounts. Release could be into the atmosphere, surface water, or groundwater.

The Form R is the reporting form that must be annually submitted by the owner or operator of a covered facility. The reports are submitted on or before July 1 and cover activities that occurred at the facility during the previous calendar year. 

AIR QUALITY DISPERSION MODELING

STC can perform a variety of dispersion modeling analyses.  Our staff is very experienced and includes a former meteorologist with air dispersion modeling experience.  We stay current with model development and applications.  Typical modeling projects are related to permitting activities, such as PSD and air toxic control programs.  Modeling can also be used as a planning tool to determine ambient air impact and assess compliance in the early stages of project planning.

TITLE V PERMITTING

STC has developed and submitted a number of Title V and synthetic minor permit applications.  Our approach combines individual experience with referral to the EPA White Paper Guidance Documents as needed.

STC’s typical Title V projects are turnkey, including a site visit, development of potential emissions inventory, determination of applicable requirements, documentation of compliance, and preparation of permit applications forms.  With our experience and knowledge of regulatory limits and agency procedures, STC’s support can avoid pitfalls and be an asset to our clients during permit negotiation and issuance.  Relative to new Federal Compliance Monitoring Regulations, our approach is to develop compliance reporting requirements based on existing regulations.

In addition to turnkey Title V permitting, STC will provide support in conducting a review of a Title V application prepared by another party.  This service is customized to suit clients needs and encompasses a technical review of the data and a regulatory review for completeness.  A compliance audit may be integrated with the Title V review.  We can also support clients in negotiation of permit conditions.

ACCIDENTAL RELEASE EVALUATIONS

The 1990 Clean Air Act, Section 112(r), went in effect in 1997.   Better known as EPA’s Risk Management Program (RMP), it requires that every source that stores, handles, processes or produces certain listed hazardous chemicals in quantities above the specified threshold must develop a program for managing the risks associated with the operations. 

One specialized element of the program is to evaluate through dispersion modeling (1) the worst-case release scenario and (2) a more likely significant accidental release for each regulated substance present at the facility.  A five-year accident history must also be provided.  The RMP requires that on-site and off-site consequences be evaluated.

STC has staff who are very familiar with modeling procedures who can aid in your facility’s RMP requirements.

Unlike most environmental regulations, the RMP rules are modeled on an OSHA regulation, “Process Safety Management” (PSM).  Twelve of the fourteen PSM elements are incorporated in RMP.  Unlike most environmental specialty firms, STC has significant experience in PSM audits and program development.  This puts us in a better position to properly cover the safety driven elements of RMP.

PHASE I ENVIRONMENTAL SITE ASSESSMENTS

The purpose of a Phase I Environmental Site Assessment is to identify, to the extent feasible, environmental conditions that could affect the value of the property or represent a liability to the property owner.  The identification of environmental conditions is usually based on reviews of existing data, interviews, and a physical site inspection.

Historical data may be obtained from personal interviews, aerial photographs, city directories, chain-of-title information or insurance maps, are reviewed for information regarding past property use which may suggest a potential for conditions of environmental concern.  Databases and files of state, local and/or federal government agencies are reviewed for regulated facilities within the vicinity and for facilities where incidents of contamination have occurred.

A physical site inspection is conducted to visually determine the environmental conditions of the site and surrounding properties.  The property is inspected for areas visibly contaminated, such as stained soil or surface water or stressed vegetation and for evidence suggesting a potential for contamination, such as underground or above-ground storage tanks or waste storage areas.  Topographic and geologic information which may suggest directions of movement of contaminants on the surface or in the subsurface is obtained during the site inspection and also by use of topographic maps prepared by the United States Geological Survey.

Phase I does not generally involve field sampling, testing, or analysis that would generate new data; however, the scope of activities can be changed to include such tasks.

PHASE II ENVIRONMENTAL SITE ASSESSMENTS 

A Phase II Environmental Site Assessment is usually conducted after a Phase I Environmental Site Assessment has identified environmental conditions that could affect the value of the property or represent a liability to the property owner.

A Phase II can include any of the following: soil sampling and laboratory analysis; groundwater sampling and laboratory analysis; surface water sampling and laboratory analysis; sampling for asbestos-containing materials; sampling for lead-based paint; wetlands identification; source of contaminations identifications; possible receptors (water supply wells, lakes, streams, etc) identification; removal of sources or potential sources of contamination; groundwater movement mapping; assessment of the extent of groundwater contamination and movement; and assessment of the extent of soil contamination.