EME can offer environmental, regulatory, and health and safety specialists that are familiar with RCRA, CERCLA, CWA, NCP, OSHA, NIOSH, EPRCA, and ergonomics. Since EME’s compliance staff is comprised of associates that came from industry, management and consulting; they understand the delicate balance between regulatory compliance, budgets, manufacturing processes, deadlines, and most importantly, managements focus on their bottom line and their desire to creatively limit their environmental liability. EME’s staff have overseen, managed and completed compliance audits at numerous industrial facilities throughout the United States. Our regulatory compliance specialists have over 20 years of experience working with applicable national, state and local regulations. As a result, our staff members careers have progressed as the very laws they work under were created and our compliance staff has been instrumental in establishing the standards-of-practice associated with their implementation.
EME’s staff has varied experience performing Stormwater Pollution Prevention Plans (SWPPP). Every project is slightly different. So EME’s compliance specialists and engineers use their experience to tailor our SWPPPs to meet our client’s needs and their situation. Part of the complexity involved in SWPPP regulations stems from the difficulty involved in using a general set of rules to cover a wide variety of specific cases. To help keep the details in perspective, our SWPPPs are developed with the following general principles in mind.
- Identify the possible sources of pollutants, including sediment, on the site
- Describe how stormwater could transport these materials
- Describe the control measures taken to keep these materials out of stormwater
- Set up a procedure for monitoring the effectiveness of the control measures
- Specify what steps are to be taken in case problems are discovered
EME’s staff has also prepared numerous Spill Prevention, Control and Countermeasure (SPCC) Plans in compliance with the EPA’s July 2002 amendment to the Oil Pollution Prevention regulation at Title 40 of the Code of Federal Regulations, Part 112, (40 CFR 112). This regulation incorporated revisions proposed in 1991, 1993, and 1997. Subparts A through C of the Oil Pollution Prevention regulation which are often referred to as the “SPCC Rule” because they describe the requirements for certain Facilities to prepare, amend and implement SPCC Plans. Again, EME’s compliance professionals have developed these types of plans for commercial and industrial clients such as, metal forging and waste management facilities and even the oil industry. Each plan is uniquely tailored to address the specific type of facility and its operations. Our expertise in characterizing the needs of our client’s facilities relative to the SPCC regulations is the value that we bring to our clients. Related to SPCC planning, EME’s compliance and engineering staff have also been involved in Best Management Practices (BMPs) for release prevention and developing effective material management practices and Release Reporting Policies for corporations. Relative to these types of plans, EME’s professionals have worked for Mercedes Benz, Dollar Car Rentals, HCA, McDonald Douglas and others.
EME’s compliance specialists focus on providing our clients with the information they need and helping them develop practical solutions that are designed to minimize their cost burden and liability. Specifically, EME’s specialists have performed regulatory assessments that address issues such as:
- Air Emissions sources
- Clean Water
- DOT Hazmat Compliance
- Emergency Planning and Community Right-to-Know Act Reporting Requirements
- Materials Handling
- Pesticides
- Solid, Hazardous and Special Waste
- Spill Prevention, Control and Countermeasure Plans
- Stormwater Pollution Prevention Plans
- Toxic Substance Control
- Underground Storage Tanks
- Waste Disposal
- Water Discharges
Some of the Compliance Projects EME has worked on include:
Aluminum Factories
EME staff was responsible for the evaluation of air emissions from stationary sources at 11 aluminum industry manufacturing facilities around the US; development of a program to achieve compliance, and subsequent liaison/negotiation of permit modifications and compliance schedules with regulatory officials in five states; development and implementation of an energy conservation/co-generation program for the company’s aluminum extrusion facility located in Dolton, Illinois. This project involved the use of two 550 kW natural gas powered stand-by generators to co-generate electricity during specific periods thereby reducing the total facility electrical costs. Due to its location in a non-attainment area, implementation required negotiation of air emission factors for noncontiguous operation of stationary internal combustion engines to support modification of the facility’s existing air emission permit and negotiation of a revised electric service agreement. Successfully negotiated state operating permits for air emission sources at three industrial facilities located in two states in lieu of regulation and permitting under Title V of the Clean Air Act.
RI/FS and RD/RA activities at a USEPA Superfund Site
EME staff was responsible establishing the technical and regulatory direction of RI/FS and RD/RA activities at a USEPA Superfund Site; functioned as the primary point of contact with the representatives of the Commonwealth of Kentucky, the USEPA RPM, USEPA Region IV CERCLA staff, and adjacent landowners; preparation of the Administrative Record; negotiation of the Record of Decision.
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