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Air Permitting & Compliance Services

Since 1995, GT has provided air permitting and compliance services to industry and government.  These services include air quality modeling, emission inventories, regulatory evaluations, permit negotiations, and enforcement support.  We strongly advocate for our clients’ interests to exceed their goals and expectations.  We have the sophistication to work with Fortune 500 companies and the cost-effectiveness to work with small businesses.

Our Services

  • Title V Permitting
  • Prevention of Significant Deterioration (PSD) Permitting
  • Non-Attainment New Source Review (NNSR) Permitting
  • Minor Source Permitting
  • Air Quality/Air Dispersion Modeling
  • Air Emission Inventories
  • Greenhouse Gas Monitoring Plans & Reporting
  • Risk Management Plans (112r)
  • Startup, Shutdown & Malfunction Plans
  • RACT/BACT/LAER Studies
  • NSPS/NESHAP/MACT Regulatory Assessments
  • Enforcement Support
  • Permit Negotiations
  • Quarterly, Semi-Annual & Annual Compliance Reporting
  • Refrigerant Management Plans
  • Stack Test Programs
  • Facility Inspections & Audits
  • Expert Testimony

Industries We Serve

Air Permitting Assessments

Many air contaminant sources (emission units) are required to obtain installation or construction permits prior to commencing construction. GT routinely conducts air permitting assessments to assist clients with evaluating whether emission units are exempt from permitting and, if not, what type of air permit is required.

Many states offer an extensive list of emission unit activities that are exempt from air permitting requirements. Many of these air permitting exemptions are based on the basic description of the emission unit while others may require de minimis emission calculations to ascertain whether the source is exempt from permitting. Many states offer Permit-by-Rule (PBR) exemptions, Director Exemptions and General Permits to simplify the permitting process and to expedite permit issuance.

Emission units that are not exempt from permitting and are located at non-major facilities are required to obtain an installation permit or construction permit sometimes referred to as a Permit-to-Install (PTI) or Permit-to-Install and Operate (PTIO) prior to commencing construction. Some states have a two-step air permitting process that require facilities to apply for a PTI, then later after operation has commenced, to apply for a Permit-to-Operate (PTO). Normally, PTIs remain in effect for the duration of the air contaminant source or until it is modified. Typically, PTOs and PTIOs must be renewed on a 5 or 10-year cycle.

Emission units that are not exempt from permitting and are located at major facilities are required to obtain an installation permit or construction permit prior to commencing construction. Major facilities or Major Stationary Sources are facilities with the potential-to-emit (PTE) greater than or equal to 100 tons/yr of a regulated air pollutant; 10 tons/yr of any individual hazardous air pollutant (HAP); or 25 tons/yr of all combined HAPs. Major facilities are also required to obtain a Title V operating permit. Title V operating permits contain the permit terms and conditions for all significant and insignificant emissions units at a major facility. Title V operating permits must be renewed every 5-years.

Explore our Air Permitting & Compliance Services

Facility-Wide Air Emissions Inventory

All facilities regardless of their size should maintain an up to date facility-wide air emissions inventory. Facility-wide air emissions inventories should include detailed uncontrolled and controlled PTE calculations on a lbs/hr and tons/yr basis. Facility-wide air emission inventories help facilities track their major source status. Major facilities or major stationary sources are required to obtain a Title V operating permit and may also be required to evaluate Major New Source Review (Major NSR) permitting requirements such as the Prevention of Significant Deterioration (PSD) and Non-Attainment New Source Review (NNSR) when modifying existing emission units and/or adding new emission units. Facility-wide air emission inventories are also helpful when preparing air permit applications and when preparing air fee emission reports.

Air Permit Applications
GT routinely assists clients with preparing air permit applications and reviewing and negotiating permit terms and conditions.

Some states, like Ohio, offer web-based air permitting systems where air permit applications can be submitted electronically without the need to submit hardcopy air permit applications while others still require the submission of one or more hardcopy application packages. Air permit application packages generally include state specific application forms; emission calculations; process data; process flow diagrams; control equipment specifications; egress point information; Best Available Technology (BAT) Studies; and, sometimes, air quality modeling for air toxics and criteria pollutants (NOx, SO2, VOC, CO, PM, PM10, PM2.5 and Lead).

PTIs and PTIOs must be obtained prior to commencing construction. Depending on the complexity of the project, it may take consultants several months to prepare very complex air permit application packages that trigger PSD, NNSR and/or air quality modeling requirements. Also, depending on the complexity of the project, some permit applications packages may take up to 6 months for the state agencies to issue a final permit. Typically, GT can prepare routine air permit application packages in 1-2 weeks and the state agencies can issue those final permits in 2-3 months. As a general rule of thumb, facilities should plan to submit air permit application packages at least 6-months prior to commencing construction.

PSD & NNSR Permitting Requirements

GT has significant experience with preparing Prevention of Significant Deterioration (PSD) and Non-Attainment New Source Review (NNSR) permit application packages for steel plants and coal fired baseload power plants as well as numerous other chemical and general manufacturing facilities.  The initial goal of any PSD and/or NNSR permitting project is to figure out how to avoid these permitting requirements in the first place.  GT has significant experience with assisting our clients with avoiding these onerous permitting requirements.

The Prevention of Significant Deterioration (PSD) and Non-Attainment New Source Review (NNSR) permits are special types of installation or construction air permits for major sources of criteria pollutants.  Facilities that are one of the 28 source categories listed in 40 CFR 52.21 are major if they have potential emissions of one or more criteria pollutants in excess of 100 tons/yr.  All other facilities are major if they have potential emissions of one or more criteria pollutants in excess of 250 tons/yr.

Major facilities or major stationary sources in attainment areas of the National Ambient Air Quality Standards (NAAQS) should evaluate the applicability of the PSD permitting requirements each time they install a new air contaminant source or modify an existing air contaminant source.  Projects in an attainment area that result in an increase in emissions of greater than 40 tons of NOx, SO2 or VOC; 100 tons of CO; 15 tons of PM10; 10 tons of PM2.5 or 0.6 tons of lead must submit an air permit application package that includes a BACT Study, Air Quality Modeling and an Additional Impacts Analysis.

Facilities located in a non-attainment area are major if they have potential emissions greater than 100 tons/yr for a pollutant for which they are non-attainment.  Major facilities or major stationary sources should evaluate the applicability of the NNSR permitting requirements each time they install a new air contaminant source or modify an existing air contaminant source.  Projects in a non-attainment area that result in an increase in emissions of a pollutant for which the area is non-attainment of greater than 40 tons of NOx, SO2 or VOC; 100 tons of CO; 15 tons of PM10; 10 tons of PM2.5 or 0.6 tons of lead must submit an air permit application package that includes a LAER Study, Air Quality Modeling and obtain emissions offsets.

Air Quality Modeling

GT has significant experience with running US EPA approved air quality dispersion models such as AERMOD, AERSCREEN, SCREEN3 and CALPUFF.  AERMOD, AERSCREEN and SCREEN3 are all short-range transport models designed to evaluate receptors up to 50-km from the project site.  CALPUFF is a long-range transport model designed to evaluate receptors beyond 50-km and up to 300-km from the project site.

 Most facilities conduct air quality modeling in support of an air permit application.  However, sometimes facilities conduct air quality modeling to: (1) evaluate whether a permit modification has been triggered due to a change in dispersion characteristics; (2) optimize stack heights and stack location; (3) respond to state agency complaints about odors; or (4) locate the optimum location of an ambient monitor.

 SCREEN3 and AERSCREEN are often used, as their names suggest, as a screening tool to determine whether more sophisticated models such as AERMOD must be run.  Typically, SCREEN3 and AERSCREEN overestimate offsite concentrations as compared to AERMOD.  If SCREEN3 or AERSCREEN predict offsite concentrations above the required levels, then just switching to AERMOD may resolve the problem.

 SCREEN3 is the predecessor to AERSCREEN and is based on the ISCST modeling algorithms.  SCREEN3 requires much less information than AERSCREEN and, as a result, produces much less accurate and, often times, higher offsite concentrations.  AERSCREEN is based on the AERMOD modeling algorithms and normally predicts offsite concentrations that are higher than AERMOD but lower than SCREEN3.  SCREEN3 is no longer accepted by US EPA and state agencies for PSD and NNSR air quality modeling projects but still used in some states for minor source air permitting projects and air toxic modeling.  AERMOD is typically the preferred model for PSD and NNSR projects and for complex modeling projects that involve multiple stacks, multiple buildings, complex terrain or where less conservative offsite concentrations are required.

 AERMOD is a short-range transport model designed to evaluate receptors up to 50-km from the project site.  AERMOD typically requires terrain height data covering an area up to 50-km from the project site and 5-years of meteorological data.  AERMOD is typically used in PSD projects to evaluate the maximum offsite concentrations versus the National Ambient Air Quality Standards (NAAQS), PSD Class II Significant Impact Levels (SILs) and PSD Class II Increments.  Class II areas are all areas of the United States that are not Class I areas.  Class I areas include a specific list of national parks over 6,000 acres and national wilderness areas and national memorial parks over 5,000 acres.  AERMOD is also used in NNSR projects to verify that the project and proposed offsets will result in a net air quality improvement.

 CALPUFF is a long-range transport model designed to evaluate receptors beyond 50-km and up to 300-km from the project site.  CALPUFF typically requires terrain height data covering an area up to 300-km from the site and 3-years of meteorological data.  CALPUFF is typically used in PSD projects to evaluate the maximum offsite concentrations versus the PSD Class I Increments and to conduct Class I Visibility and Sulfur and Nitrogen Deposition Analyses.  PSD Class I modeling analyses should be conducted in accordance with the Federal Land Managers’ Air Quality Related Values Work Group (FLAG) Phase I Report -Revised 2010 (FLAG 2010) guidance document and in close cooperation with the Federal Land Managers (FLM) and state agency air quality modeling experts.

RACT/BAT/BACT/LAER Studies

Some air permit application packages require the preparation of Best Available Technology (BAT), Reasonably Available Control Technology (RACT), Best Available Control Technology (BACT), and/or Lowest Achievable Emission Rate (LAER) Studies. 

 GT has extensive experience with the preparation of RACT/BAT/BACT/LAER Studies and associated cost-effectiveness evaluations.

 BAT/RACT Studies are sometimes required for large air contaminant source projects that do not trigger PSD or NNSR.  Typically, BAT is defined as the most cost-effective and technically feasible control technique available for each source category.  BAT must be at least as stringent as an applicable state rule or federal rule such as a New Source Performance Standard (NSPS), National Emission Standard for Hazardous Air Pollutants (NESHAPs) or Maximum Achievable Control Technology (MACT).

 BACT Studies are required for projects that trigger PSD permitting requirements.  BACT is typically equal to or more stringent than BAT or RACT.  BACT Studies are conducted following a rigorous 5-step top down analysis.  Step 1 involves identifying all of the available control technologies.  Step 2 involve eliminating all of the technically infeasible options.  Step 3 involves ranking the remaining technologies in order from most to lease effective.  Step 4 involves eliminating any technologies that are not cost effective.  Step 5 involves the selection of BACT.  Guidance on the preparation of a BACT Study can be found in the Draft October 1990 New Source Review (NSR) Workshop Manual and the August 2017 New Source Review (NSR) Manual published by the Air & Waste Management Association.

 LAER Studies are required for projects that trigger NNSR permitting requirements.  LAER is the most stringent emission limitation derived from: (1) the most stringent emission limitation contained in the implementation plan of any state for such class or category of source unless the proposed stationary source demonstrates that the limit is unachievable; or (2) the most stringent emission limitation achieved in practice by such class or category of source.  LAER is typically equal to or more stringent than BACT.

Air Regulatory Assessments

Any time a new air contaminant source is installed, or an existing air contaminant source is modified, facilities should evaluate which, if any, state and federal rules may be triggered.  GT has extensive experience with conducting regulatory assessments of state and federal rules such as the New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPs), Maximum Achievable Control Technology (MACT) Standards, and Generally Available Control Technologies (GACT) Standards.

NSPS are found in 40 CFR Part 60; NESHAPs are found in 40 CFR Part 61; and MACT and GACT Standards are found in 40 CFR Part 63.  NSPS regulate criteria pollutants.  NESHAP, MACT and GACT standards regulate HAPs.  MACT Standards only apply to facilities that are major for HAPs while GACT Standards apply to facilities that are non-major for HAPs (area sources of HAPs).

The requirements of a NSPS are triggered by installing a new air contaminant source that is covered by the NSPS or by modifying an existing air contaminant source that is currently not regulated by the NSPS because it was installed prior to the effective date of the standard.  A modification under the NSPS is triggered when the maximum hourly emissions are increased.

The requirements of a MACT or GACT Standards regulate new and existing affected sources.  Existing affected sources are those that are not new affected sources.  New affected sources are those that were installed after the promulgation date of the standard.  The requirements for new affected sources are more stringent than for existing affected sources.  Existing affected sources that undergo reconstruction need to comply with the new affected source requirements upon startup.

Title V Permitting

GT has extensive experience with preparing Title V permit applications and reviewing and negotiating Title V permit terms and conditions.

Facilities with potential emissions greater than or equal to: 100 ton/yr of a regulated air pollutant (e.g., NOx, SO2, VOC, CO, PM10, PM2.5 and Lead); 10 ton/yr of an individual HAP; or 25 tons/yr of all combined HAPs must obtain a Title V operating permit. 

The federal Title V permitting requirements are found in 40 CFR 70 and Ohio’s Title V permitting requirements are found in OAC Rule 3745-77.  Title V permits are designed to consolidate all installation and construction permits at major sources under one operating permit.  Title V permits are not supposed to add any new substantive requirements.  Title V permits only include permit terms and conditions for significant emission units.  Insignificant emission units are typically just listed in the Title V permit.  Title V permits must be renewed every 5-years.

Air Permit Reports

Title V permits and many installation and construction permits require quarterly, semi-annual, and annual reporting.  Title V permits, at a minimum, require facilities to submit quarterly and semi-annual deviation reports.  Quarterly Title V deviation reports identify deviations of emission limitations, operational restrictions and control device operating parameters.  Semi-annual Title V deviation reports identify deviations of monitoring, recordkeeping, reporting and testing requirements.  Title V Annual Compliance Certifications summarize the quarterly and semi-annual deviation reports and identify any other deviations not previously reported.  Most permits also require facilities to periodically report emissions, production data and/or control device operating parameter data.  GT routinely assists our clients with preparing these reports which frees up the environmental manager’s time to focus on other important responsibilities.

Permit Negotiations

Title V permits, synthetic minor permits, and PSD/NNSR permits normally require a 30-day public comment period.  During this public comment period permit applicants and the public can comment on the terms and conditions of draft permits.  Air permits for true minor facilities likely won’t include an official draft comment period, however, regulatory agencies normally offer the facility an opportunity to review the permit before it is issued final.  It is important that facility’s review their draft permits thoroughly to make sure they are maximizing the facility’s operational flexibility and limiting the facility’s liability.  Typically, GT will be far more up to speed with changes in agency standard permit terms and conditions and in agency permitting policy than most industrial facilities.  Engaging GT to review your draft permits will ensure that you are getting the best permit possible.  Also, submitting written comments on draft permits will provide a solid foundation should the facility decide to appeal the final air permit.

 

Enforcement Support

GT often works in conjunction with environmental attorneys on assisting facilities with responding to Notices of Violation (NOV) or US EPA 114 requests.  GT has the technical and regulatory experience necessary to assist attorneys with responding to NOVs and 114 requests.  GT has the technical experience necessary to review facility records before they are submitted to the regulatory agency to make sure the facility’s records are not going to make matters worse.  GT has the regulatory and enforcement support experience necessary to be able to ascertain the basis of the agency’s questions so that technical and legal arguments can be formulated in advance of the regulatory agencies.

Expert Testimony

GT has the technical, permitting, and regulatory expertise to provide Expert Report and Testimony services to environmental attorneys on air permitting and regulatory compliance matters.

 

Stack Testing Programs

GT does not offer stack testing or emissions measurement services.  However, we do assist clients with: (1) reviewing stack test reports; (2) developing stack testing programs that meet our client’s goals; and (3) managing and witnessing stack test programs.  GT has the stack testing experience necessary to assist clients with selecting the proper test methods; stack test durations and stack testing conditions necessary to meet our clients expectations.

Greenhouse Gas Reporting Rule

GT routinely assists clients with preparing Greenhouse Gas (GHG) reports under the Greenhouse Gas Reporting Rule found in 40 CFR 98.

The following facilities must submit annual Greenhouse Gas (GHG) reports regardless of their actual annual CO2e emissions: 

Electricity generation

Petrochemical production

Adipic acid production

Petroleum refineries

Aluminum production

Phosphoric acid production

Ammonia manufacturing

Silicon carbide production

Cement production

Soda ash production

HCFC-22 production

Titanium dioxide production

HFC-23 destruction processes

Municipal solid waste landfills

Lime manufacturing

Manure management systems

Nitric acid production

 

 The following facilities must submit annual GHG reports if the facility emits more than 25,000 metric tons of CO2e:

Ferroalloy production

Lead production

Glass production

Pulp and paper manufacturing

Hydrogen production

Zinc production

Iron and steel production

 

 Suppliers that provide products listed below must submit annual GHG reports:

Coal-to-liquids suppliers

Industrial GHG suppliers

Petroleum product suppliers

Carbon dioxide suppliers

Natural gas and natural gas liquids suppliers

 

 All other facilities that emit greater than 25,000 metric tons of CO2e and have aggregate maximum rated heat input capacity of stationary fuel combustion units at the facility greater than 30 MMBtu/hr must submit annual GHG reports.

CO2e emissions must be calculated following the procedures outlined in the rule.  Annual GHG reports are due by March 31st of each year and must be submitted through US EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) available through US EPA’s Central Data Exchange (CDX) electronic reporting website.

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Risk Management Plans

In response to the 1984 Bhopal, India methyl isocyanate chemical accident that killed over 2,200 people, Congress incorporated Section 112(r) into the 1990 Clean Air Act Amendments requiring US EPA to develop regulations that prevent and facilitate emergency response to chemical accidents at facilities that use certain hazardous substances.  The Chemical Accident Prevention Provisions which included the Risk Management Plan requirements were published in the Federal Register on June 20, 1996.  The federal Chemical Accident Prevention Provisions can be found in 40 CFR 68 and Ohio’s Chemical Accident Prevention Provisions can be found in OAC Rule 3745-104.

The RMP program contains a list of 77 acutely toxic chemicals with thresholds ranging from 500 – 20,000 pounds and 63 flammable gases and volatile flammable liquids with thresholds of 10,000 pounds.  An owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process must submit a Risk Management Plan (RMP).  There are three degrees of plan complexity identified as Program 1, 2 and 3 with program 1 being the least complex and 3 being the most complex.

To qualify for a Program 1 plan, the facility must meet each of the following criteria:

1. The process has not had an accidental release of a regulated substance where exposure to the substance, its reaction products, overpressure generated by an explosion involving the substance, or radiant heat generated by a fire involving the substance led to any of the following: (a) death; (b) injury; or (c) response or restoration activities for an exposure of an environmental receptor.

  1. The distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor.
  1. Emergency response procedures have been coordinated between the stationary source and local emergency planning and response organizations.

To qualify for a Program 2 plan, the facility does not meet the criteria of a Program 1 or 3 Plan.

To qualify for a Program 3 plan, either of the following criteria is met:

  1. The process is in NAICS code 32211, 32411, 32511,325181, 325188, 325192, 325199, 325211, 325311, or 32532; or
  1. The process is subject to the OSHA Process Safety Management Standard found in 29 CFR 1910.119.

Program 1 plans must include the following:

  1. Executive Summary as required by 40 CFR 68.155
  2. Registration as required by 40 CFR 160
  3. Offsite consequence analysis as required by 40 CFR 68.165
  4. 5-year accident history as required by 40 CFR 68.168
  5. Certification as required by 40 CFR 68.185
  6. Emergency response program and exercises as required by 40 CFR 68.180

Program 2 plans must include the following:

  1. Executive Summary as required by 40 CFR 68.155
  2. Registration as required by 40 CFR 160
  3. Offsite consequence analysis as required by 40 CFR 68.165
  4. 5-year accident history as required by 40 CFR 68.168
  5. Certification as required by 40 CFR 68.185
  6. Emergency response program and exercises as required by 40 CFR 68.180
  7. Prevention program as required by 40 CFR 68.170

Program 3 plans must include the following:

  1. Executive Summary as required by 40 CFR 68.155
  2. Registration as required by 40 CFR 160
  3. Offsite consequence analysis as required by 40 CFR 68.165
  4. 5-year accident history as required by 40 CFR 68.168
  5. Certification as required by 40 CFR 68.185
  6. Emergency response program and exercises as required by 40 CFR 68.180
  7. Prevention program as required by 40 CFR 68.175

RMP must be reviewed, updated and submitted at least every 5 years.  RMP must be submitted electronically to US EPA’s RMP*eSubmit available through US EPA’s Central Data Exchange (CDX) electronic reporting website and a hardcopy or electronic copy on compact disk must also be sent to Ohio EPA.

Contact GT if you need assistance with preparing, reviewing or updating your RMP.

GT Environmental Provides Facility Plans, Compliance Assessments and Audits

Startup, Shutdown and Malfunction Plans (SSMP)

40 CFR 63.6(e)(3) requires facilities subject to a Maximum Achievable Control Technology (MACT) standard to prepare a Startup, Shutdown and Malfunction Plan (SSMP).  The SSMP must describe, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard.  The purpose of the SSMP is to: (1) ensure that, at all times, regulated process(es) including air pollution control and monitoring equipment are operated and maintained in a manner to minimize emissions and (2) ensure that the facility is prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize emissions.

Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.

Under the SSMP, the facility must maintain records that indicate whether the actions taken during each startup, shutdown or malfunction event were consistent with the SSMP.  If the records indicate the actions taken were inconsistent with the SSMP then the facility must notify the agency either verbally or in writing within 2 working days and must submit a letter report within 7 working days in accordance with §63.10(d)(5).

The facility is not required to submit the SSMP to the agency but must make the plan available at all times for review and copying by the agency.  The facility may update the SSMP without prior approval from the agency.  The facility must retain copies of all versions of the SSMP for a period of at least 5 years.  Upon written request, the facility must provide a copy of the SSMP to the agency.

Refrigerant Management Rule Compliance

The purpose of this rule is to reduce emissions of Class I and Class II refrigerants and their non-exempt substitutes to the lowest achievable level by maximizing the recapture and recycling of such refrigerants during the maintenance, service, repair, and disposal of appliances and restricting the sale of refrigerants consisting in whole or in part of a Class I or Class II ozone-depleting substance or their non-exempt substitutes.

This rule applies to any person maintaining, servicing, or repairing appliances containing Class I, Class II or non-exempt substitute refrigerants. This subpart also applies to persons disposing of such appliances (including small appliances and motor vehicle air conditioners), refrigerant reclaimers, technician certifying programs, appliance owners and operators, manufacturers of appliances, manufacturers of recovery and/or recycling equipment, approved recovery and/or recycling equipment testing organizations, and persons buying, selling, or offering to sell Class I, Class II, or non-exempt substitute refrigerants.

This rule prohibits any person maintaining, servicing, repairing, or disposing of an appliance or industrial process refrigeration from knowingly venting or otherwise releasing into the environment any refrigerant from such appliances.  This rule also regulates the disposal of appliances containing Class I, Class II, and non-exempt substitute refrigerants.

Facilities that use their own employees to maintain their refrigerant systems are subject to all of the requirements of this rule while those who use outside contractors have limited requirements under this rule.  Facilities that utilize outside contractors must ensure that each technician is properly certified to maintain the equipment being serviced.

All technicians that maintain, service, repair or dispose of appliances containing Class I, Class II, or non-exempt substitute refrigerants must pass a certification exam offered by an approved technician certification program.  Below are the different levels of certification:

  1. Type I Technician – Small Appliances (≤5 lbs)
  2. Type II Technician – Medium-, High-, or Very High-pressure appliances
  3. Type III Technician – Low-pressure appliances
  4. Universal Technician – Technician that services Type I, II and III appliances.

 

Due Diligence/Environmental Inspections & Audits

GT conducts environmental audits for the following reasons:

  1. In preparation of a facility purchase or refinance (Due Diligence);
  2. Third-party internal audits;
  3. Change in company ownership or management; and
  4. Follow-up to the identification of a potential environmental violation.

Often buyers of an industrial facility will conduct an environmental compliance audit in addition to a Phase 1 Environmental Site Assessment (ESA) prior to purchasing a new industrial facility.  A Phase 1 ESA only focuses on the identification of soil or groundwater contamination resulting from past or present petroleum or chemical spills.  Phase 1 ESAs do not evaluate the industrial facility’s compliance with air permitting and regulatory compliance; stormwater and wastewater permitting and compliance; and hazardous waste management requirements. 

A full Environmental Due Diligence Audit should include a Phase 1 ESA and a multi-media environmental permitting and compliance audit.  A multi-media environmental permitting and compliance audit will involve a site visit where the auditor will be looking for unpermitted air and stormwater/wastewater discharges; review of a facility’s air and stormwater/wastewater permits; review of a facility’s monitoring, recordkeeping and reporting requirements; review of state and federal regulatory requirements; and a review of the facility’s hazardous waste management requirements.  A full Environmental Due Diligence Audit that includes a Phase 1 ESA and a multi-media environmental permitting and compliance audit will provide the buyer with the information necessary to evaluate the potential environmental risks and whether funds should be set aside by the seller to cover environmental issues that were caused under the sellers watch.

Many companies have an internal auditing process.  On occasions, companies may also include third-party internal audits as a means of verifying the thoroughness and effectiveness of the company’s internal auditing process.  Often third-party auditors (consulting firms) are engaged by attorneys representing the company.

Often companies will request a multi-media environmental audit following the change in facility ownership or management as a means of establishing an environmental baseline.  After establishing the environmental baseline, the company can focus its efforts on areas of higher risk or areas of perceived weakness.

Often companies will engage GT to conduct a multi-media audit after discovering a potential violation but before reporting the violation to the appropriate regulatory agency.  This is often done to take advantage of the state or federal audit privileged requirements or because the company feels the reporting of the original violation will cause the regulatory agencies to investigate other areas of potential non-compliance.  Self-identifying and reporting environmental non-compliance often results in more favorable treatment by the regulatory agencies.

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