Because RCP has a comprehensive understanding of the regulatory process, we can keep your project on track by helping secure the permits you need, in the time frame you need them. We'll also work to get the fairest possible terms and conditions, and to minimize the impact of special permit limitations.

Air Permitting: Whether your facility is simple or complex, RCP can take care of all your air permitting needs. Our services include:

• Initial permitting analysis and strategy
• Permit application and follow-up
• Permit compliance systems and training
• Reporting and recordkeeping

Initial permitting analysis and strategy
The facility design phase can be the most critical time to begin working the air permit issues. What regulations will apply to this facility, and what are the critical emissions "trigger" levels that could cause this facility to be regulated more severely? What emissions can be expected from this facility as currently designed, and what control alternatives are available? What is the accepted Best Available Control Technology for this process? Are there special restrictions associated with the proposed facility location that would not apply at an alternative location? What is the permitting history of this site, and what grandfather conditions may currently exist (or be in jeopardy)? RCP can help you work through these and other issues at this critical stage of your project's life . . . before the major dollars are spent.

Permit application and follow up
In most cases, the facility construction cannot begin until the air permit is approved. Once the facility design is established and operating plans have been developed, the permit approval frequently becomes THE critical path item for the project. RCP's experts can work in conjunction with your facility design and operations teams, to have a high quality air permit application ready to go ASAP after the critical operating parameters have been established. Our air permitting professionals are skilled at taking the complex calculations involved in air permit applications, and presenting them in a logical and orderly fashion. This clarifies the calculation methodologies used in the application, and enables the regulatory agencies to review the application more quickly and with fewer questions. We steward the application through the regulatory agencies, to ensure that their needs are met and that the application doesn't get bogged down during the review process. The net result is a permit for your facility in the least possible amount of time.

Permit compliance systems and training
Modern permits require that the company management "certify" that they are operating in compliance with the permit conditions. An air permit is a complex document, incorporating a myriad of other requirements "by reference." How does a manager know that the facility is actually in compliance with these requirements? By developing a comprehensive permit compliance system, and training their employees on how to use it.

Reporting and recordkeeping
RCP is skilled at developing compliance guidance documents that explain all the associated requirements in layman's terms. This includes issues such as reporting and recordkeeping, incident reporting, special reporting requirements, equipment inspection requirements and schedules, personal and group responsibilities, and documentation systems. We provide standard forms that address all of the reporting and documentation requirements, and give you an organized file system to maintain this critical documentation. The final system is easy to understand, easy to use, and easy to maintain.

Wastewater Permitting

Whether your facility is simple or complex, RCP can take care of all your wastewater permitting needs. Our services include:

• Initial permitting analysis and strategy
• State Requirements for NPDES
• Preapplication and Negotiation Assistance

Initial permitting analysis and strategy
National Pollution Discharge Elimination System (NPDES) permits are required by the EPA or authorized state agency for surface water discharges. NPDES permit renewals, required every five years, can be a major effort in data accumulation and addressing new issues. RCP experience can assist you during the permitting/permitting renewal process to develop an effective permitting strategy.

State Requirements for NPDES
Many States have been delegated authority to administer water permitting, i.e. the National Pollutant Discharge Elimination System (NPDES) program. NPDES is a federal regulatory program to control discharges of pollutants to surface waters of the United States.

The TCEQ's Texas Pollutant Discharge Elimination System (TPDES) program now has federal regulatory authority over discharges of pollutants to Texas surface water, with the exception of discharges associated with oil, gas, and geothermal exploration and development activities, which are regulated by the Railroad Commission of Texas.

Preapplication and Negotiation Assistance
RCP can also assist with the Wastewater Permitting Section pre-application meetings and requirements prior to submitting your permit application or modification and negotiations of permit conditions with a regulating agency.

Storm Water Pollution Prevention

Storm Water Permitting

Whether your facility is simple or complex, RCP can take care of all your storm water permitting needs. Our services include:

• Federal Permitting and Plan Development
• State General Permits
• Army Corps of Engineers Nationwide / District Permitting

Federal Permitting and Plan Development
RCP can assist you with your storm water permitting and Storm Water Pollution Prevention Plan (SWPPP) development.

Permitting for General State Permits
RCP can assist with the permitting process within each individual state. RCP has the expertise to navigate through the application process. RCP is extremely knowledgeable with the permitting process in the States of Louisiana and Texas, which has been of value to many Gulf Coast operators.

For facilities in Texas, RCP can also assist with:

• Texas permitting for TPDES Wastewater General Permit No. TXR050000
  RCP can provide assistance with permitting and meeting the requirements -whether your facility is applying for a new permit, modifying an existing one, or addressing compliance issues.



• Texas permitting for TEPDS General Permit Number TXGR340000
  If your Standard Industrial Classification (SIC) code is 5171 (Petroleum Bulk Stations and Terminals), RCP can provide assistance with your TPDES General Permit No. TXG340000 - Discharges from Petroleum Bulk Stations and Terminals, which authorizes the discharge of wastewater and contact storm water discharges from your facility.
  
  Texas permitting for TEPDS General Permit Number TXGR670000
  RCP professionals can also provide you with assistance with the Texas Pollutant Discharge Elimination System (TPDES) General Permit No. TXG670000 to discharge hydrostatic test water into or adjacent to water in the state.
  
  The purpose of this general permit is to regulate the discharge of water resulting from the hydrostatic testing of new or used pipelines, tanks, and other vessels used in pipeline transportation, storage, or otherwise containment of raw materials or products. Fill water used in hydrostatic testing may come from rivers, streams, lakes, ponds, wells, and municipal water supplies. The general permit also authorizes discharges resulting from the flushing of water supply lines or tanks for disinfection purposes.