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| Hazardous Waste and Materials Management |
| Regulatory Compliance and Permit Acquisition Complex legislation makes regulatory compliance a costly and time-consuming necessity. Enviroscientists' team of professionals conducts site audits to determine whether or not a facility is in compliance with current regulations and existing permits. Our qualified professionals are experienced in both industrial process and environmental regulations. Knowledge of regulations and regulatory processes allows us to assist our clients in obtaining necessary permits and developing hazardous material inventory systems. Enviroscientists has successfully provided comprehensive permit acquisition services for multiple existing and proposed resource development and industrial facilities throughout the western United States. Toxics Release Inventory Evaluation and Compliance The Toxics Release Inventory (TRI) program was implemented in 1986 under Section 313 of the Emergency Planning and Community Right-To-Know (EPCRA) program. This TRI program was originally designed for the manufacturing industry (SIC 20-39). The metal mining industry (SIC 10) is part of a group of industries that has recently been added to the TRI program and that must now file reports. These reports, in the form of TRI Form Rs, are submitted to the EPA and appropriate state agencies on July 1 for the previous reporting year. The four criteria that a facility must meet to file a TRI a Form R are as follows:
Enviroscientists has the expertise to identify and prepare all information needed to complete Form Rs. Enviroscientists has also conducted workshops to train company personnel in the identification of TRI chemicals and data compilation needed for the required Form Rs. Risk Management Plans Under the U.S. Environmental Protection Agency's (EPA's) chemical accident prevention rules (40 CFR Part 68), facilities that handle, manufacture, use, or store any specifically listed toxic or flammable substances in quantities above the specified threshold quantity in a process are required to develop and implement a Risk Management Program. However, many facilities are subject to the Risk Management Program requirements only because they handle, use, or store propane (or other listed flammable hydrocarbon fuels, such as butane, ethane, propylene, or methane) in a process (e.g., a single tank or several interconnected tanks) in quantities above the applicable listed threshold. If these facilities are isolated from off-site public receptors (houses, schools, businesses, etc.) and have not had a serious accident in the last five years, they are likely to be subject only to the basic Program 1 requirements of the Risk Management Program. Enviroscientists can provide a manual with questionnaires and forms, as well as referenced information attachments that are specifically designed to help facilities comply with the requirements of the Risk Management Programs. This manual guides the information collection process and data analysis necessary to determine whether each facility has any process which may be subject to the Risk Management Program (due to presence of a regulated substance [whether hydrocarbon fuel or any other regulated substance] above the current threshold quantity); and to determine whether all processes subject to the Risk Management Program are eligible for the basic Program 1. Enviroscientists would then use the information generated from the questionnaires to prepare the Risk Management Plan for the facility. |
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