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Time Schedule Order (TSO) Permitting
A manufacturing facility discharging storm water under an individual National Pollutant Discharge Elimination System (NPDES) permit was not able to meet effluent limitations set out in the permit. As exceedances continued to occur the facility decided to invest heavily in site modifications to eliminate storm water pollution sources, which was the source of elevated pollutant concentrations. Faced with continued non-compliance the corporate environmental staff turned to ALG for possible solutions.
Streamlining SPCC Across Multiple Business Groups
ALG was contacted by a major warehouse distribution operation to update and streamline their Spill Prevention, Control, and Countermeasure (SPCC) Plans for all facilities across California. Previous plans were out of date, had been prepared inconsistent from one another, and were confusing to use and costly to update. ALG was tasked to prepare a standardized SPCC format that met all EPA requirements, and customize each plan as appropriate to address unique characteristics of each client location.
Technical Advocacy and Expert Witness Services
Technical advocacy and expert witness services often are required to address environmental enforcement or to provide for short term relief from permit terms and/or regulatory requirements. A large integrated manufacturing firm operated a complex industrial source located in California. The facility received several administrative notices of violation from the local air district, and was threatened by civil litigation for alleged exceedances of both its permit terms and conditions as well as EPA and local district prohibitory rules. Additionally, following several information requests under the Clean Air Act (CAA), Section 114 and the Emergency Planning and Community Right to Know Act (EPCRA), the matter was referred by EPA Region 9 to its Criminal Enforcement group for further investigation. The facility required a comprehensive assessment of its compliance status under the CAA, EPCRA, and Title V air permit. Additionally, technical data and analyses had to be communicated not only to EPA and the local air district, but also to the public who voiced concerns in a number of local air district proceedings.
Oil & Gas Producer - CARB Mandatory Rule (MRR) Verification
ALG was contracted to perform verification services to one of the largest crude oil producers in the state of California, encompassing seventeen (17) leases and over eighty (80) steam generating units. Due to the complexity of their operations, this crude oil producer was subject to multiple MRR regulations including Subpart C (General Stationary Fuel Combustion), Subpart W (Petroleum and Natural Gas Systems), and Subpart NN (Suppliers of Natural Gas and Natural Gas Liquids). Verification of an operation of this scope required innovative planning, prudent use of resources, and clear communication with the client in order to meet the third-party verification objectives.
Industrial Energy Efficiency - Energy Star Certification
ALG was contracted by a major manufacturing company in California to verify their Energy Star performance data to be included in the US EPA Energy Star Certification application. Since 2006, the ENERGY STAR Industrial Program has certified manufacturing facilities performing within the top 25% of energy performance for their industry; only 95 US manufacturing plants earned the Energy Star Certification as of this writing. Operation at Energy Star Certification levels reduces a facility’s reliance on electricity and fossil fuels, thus reducing cost, and also significantly reducing air pollution, including toxic emissions and greenhouse gases.
Environmental Management Systems (EMS)
Integration of existing business management systems to support environmental compliance is at the heart of an efficient and effective corporate compliance program. Too often, environmental compliance management systems are separate and distinct from facility operations and management programs. This can lead to costly inefficiencies, lack of shared objectives among business teams, and poor execution/performance of ongoing monitoring, recordkeeping and monitoring tasks. Allowed to continue for many years, such stand-alone programs can become costly to maintain and difficult to justify to management. Rather than purchasing new stand-alone compliance software, industrial, commercial, and manufacturing facilities seek to partner with environmental consultants to customize and adapt their proprietary corporate management systems to assure ongoing environmental compliance.
Proposition 65 - Compliance Implications
A product manufacturer with multiple warehouse and logistics operations in Southern California sought to evaluate their obligations under Proposition 65. Proposition 65 – The Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65) relative to exposures to diesel exhaust from their truck operations. Recent litigation by Proposition 65 “bounty hunters” had centered on exposures to diesel exhaust, and the product manufacturer required a defensible technical analysis to assure that such warnings were – or were not - required. Failure to provide a prior “clear and reasonable warning” could result in a prolonged and expensive litigation.
Utility Provider - HRA and Permitting
ALG was contacted by a public utility with generation capacity located in a remote, alpine location to provide permitting assistance and supporting technical analysis in the construction and operation of a replacement power plant. The project was subject to intense public scrutiny and agency oversight, and the direct involvement of the public utility’s board of directors.
Chemical Facility - Waste Management Optimization Program
A chemical manufacturing facility provides a host of specialty chemical products for commercial, industrial and agricultural clients. The facility is located in close proximity to residences and other sensitive receptors, with increased oversight from both the public and environmental agencies. Our client identified its hazardous waste compliance program as a key performance indicator, and turned to ALG to optimize and refine this program to assure ongoing compliance with both federal and state regulatory programs.
Glass Manufacturing Plant - Hazardous Waste Oversight
A long-time client contacted ALG to assist in managing environmental compliance tasks during a transition in our client’s environmental department. Working with corporate staff, ALG was asked to review and provide necessary oversight over hazardous waste issues, including daily inspections, waste shipments, monitoring and reporting consistent with large quantity generator (LQG) requirements. This assistance was needed in short order, and was to continue until a new environmental manager could be hired and fully integrated into our client’s operations.
Paper Recycling - SPCC Plans
An integrated paper company, with multiple operations in California and throughout the west coast, required updates to their Spill Prevention, Control, and Countermeasure (SPCC) Plans, which were originally put in place in 2002. The SPCC plan for each facility was based on a common template which was customized based on the unique characteristics at each location. However, EPA’s SPCC regulation has undergone multiple revisions and updates since inception and our client requested ALG to review their SPCC plans and perform the necessary updates for compliance. A compressed time schedule was required, and resourceful project design and management were essential to contain costs.
Power Cable Manufacturing - Permitting and Compliance
Legal counsel for a power cable manufacturing facility contacted ALG to provide strategic and technical guidance to secure the planned expansion of the facility. In permitting this new productive capacity, it would also be necessary to correct existing permits. To complicate matters, the project required local agency approvals within a relatively compressed period. ALG was selected based on its technical expertise and working knowledge of local district permitting protocols and requirements.