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Permitting @ RCP
Mother may I?
Children's game, also played by major corporations
If Moses crossed the Red Sea today, he would have to get a permit first (think of the environmental impacts!). And it would have to be done right before it would be approved!
Your facility faces similar challenges. Agencies have come to expect a high degree of professionalism in the permit applications that they receive. Give them less, and expect delays, rework, and strict permit conditions (after all, if the permit application is careless, what will they expect from the facility operation?).
RCP's professionals have the technical expertise to perform all the necessary calculations to the agencies' exacting standards, and the regulatory expertise to ensure that all the i's are dotted and t's are crossed before the application hits the agency's doorstep. And our support staff knows how to make them look GOOD.
So how can RCP partner with me?
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.
Success Story: Initial Air Permitting Analysis and Strategy
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.
Air emissions calculations
RCP's expertise with air emissions calculations extends onto the OCS as well. The MMS is continuing to expand the amount of air emissions data that they require from OCS operators, especially in the Breton Sound area. Let RCP keep track of the appropriate data, perform the supporting calculations, and handle reporting to the MMS as needed.
Title V Air Permit Compliance Manuals
Title V air permits are complex documents that contain many indirect requirements through references to industry specifications, other regulations, even the permit application itself. Many times, the personnel who are responsible for permit compliance do not have these documents available and / or do not have time to thoroughly review and understand them. Meanwhile, the issuing agency requires company management to sign certification statements that the facility is in compliance with all the applicable requirements. How does a company ensure that these complex and overlapping requirements are clearly understood, and that the programs in place are addressing all the requirements?
RCP can develop a permit compliance manual that considers all of the applicable requirements from all applicable sources and presents the information in an organized and logical fashion. Facility personnel save time because they know exactly what to do and when to do it. Regulatory specialists will have a concise reference manual that explains the requirements applicable to each facility, with regulatory citations, rule excerpts, and permit application summary data. Appropriate data will be gathered all year long, so end of year reporting will be easier. And management personnel can base their certification statements upon a clearly defined program with clearly defined requirements.
Success Story: Title V Air Permit Site Compliance Manual
Wastewater Permitting
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.
The state of Texas assumed the authority to administer the National Pollutant Discharge Elimination System (NPDES) program in Texas on Sept. 14, 1998. 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.
RCP can also assist you with the TCEQ Wastewater Permitting Section pre-application meeting and requirements prior to submitting your permit application or modification and negotiations of permit conditions with regulating agency.
Storm Water Permitting
EPA states that wastewater discharges (includes storm water) from industrial sources are generated by runoff from land and impervious areas such as paved streets, parking lots, and building rooftops during rainfall and snow events often contain pollutants at levels that could affect the quality of receiving waters.
The NPDES permit program establishes specific requirements for discharges from industrial sources. Depending on the type of industrial or commercial facility you operate, more than one NPDES program may apply. For example, the storm water that runs off from the property of an industrial facility or from a construction site may require an NPDES permit under the storm water program. An industrial facility may also discharge wastewater to a municipal sewer system and be covered under the NPDES pretreatment program. The industrial facility may also discharge wastewater directly to a surface water and require an individual or general NPDES permit. Finally, many industrial facilities, whether they discharge directly to a surface water or to a municipal sewer system, are covered by effluent limitation guidelines and standards.
To limit pollutants in storm water discharges from industrial facilities, the NPDES Phase I Storm Water Program includes an industrial storm water permitting component. Operators of industrial facilities included in one of the 11 categories of "storm water discharges associated with industrial activity" (40 CFR 122.26 (b)(14)(i)-(xi)) that discharge storm water to a municipal separate storm sewer system (MS4) or directly to waters of the United States require authorization under a NPDES industrial storm water permit. If an industrial facility has a Standard Industrial Classification (SIC) code or meets the narrative description listed in the 11 categories, the facility operator must determine if the facility is eligible for coverage under a general or an individual NPDES industrial storm water permit. In some cases, a facility operator may be eligible for a conditional/temporary exclusion from permitting requirements.
RCP can assist you with your storm water permitting and Storm Water Pollution Prevention Plan (SWPPP) development.
For facilities in Texas, RCP can also assist you with the TPDES Wastewater General Permit (TPDES General Permit No. TXR050000) and meeting the requirements, whether your facility is applying for a new permit, modifying an existing one, or addressing compliance issues.
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.
RCP professionals can also provide you with assistance with the upcoming Texas Pollutant Discharge Elimination System (TPDES) General Permit No. TXG670000 to discharge hydrostatic test water into or adjacent to water in the state which was published in the Texas Register on July 18, 2003. Also see the general permit’s fact sheet (PDF).
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.
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