Compliance Auditing - Compliance with environmental regulations can be a challenge both to achieve and uphold. Prism provides environmental regulatory compliance audit services to assist clients in managing regulatory issues on the federal, state, and local levels. Our trained and experienced staff assists clients with environmental concerns related to the Clean Water Act (CWA); Clean Air Act (CAA); Resource Conservation and Recovery Act (RCRA); Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Superfund Amendments and Reauthorization Act (SARA); and the Toxic Substances Control Act (TSCA).

Compliance Management - Many federal and state compliance programs require some form of periodic or ongoing recordkeeping, maintenance, and reporting obligations. Prism provides compliance assistance associated with programs typically requiring compliance management include the implementation of the CWA, CAA, RCRA, and SARA.

Pollution Prevention Programs - Facilities which utilize or store oils in certain quantities or other potentially polluting materials which have the potential to affect surface waters are required to develop Pollution Incident Prevention Plans (PIPP) or Spill Containment, Control, and Countermeasures (SPCC) Plans. Elements of the PIPP (or SPCC Plan) address routine handling and storage practices which could potentially result in losses or spills that may endanger the public health or environment, thus exposing the facility to potential costs and liabilities associated with such spills.

Air Quality Services -

Air Use Permitting - A Permit-to-Install is required for permitable source equipment or operations. However, not all processes require air permits. The performance of an appropriate determination of need can evaluate the applicability of various allowable exemptions.

 

Annual Air Emissions Reporting - The Michigan Air Emissions Reporting System (MAERS) requires facilities to group their equipment by emission units and submit their emissions estimates.

 

Air Emissions Inventories (AEIs) - Performance of a noninvasive (no sampling) AEI will determine whether a facility can opt out of the Title V program. AEIs can also provide information necessary for completion of annual reporting requirements under MAERS.

Title V Permitting - Development of renewable operating permits (ROPs) for compliance under the Title V program. Although not suitable for many sources, ROPs can streamline a facility=s applicable air permitting and reporting obligations.

Risk Management Planning - A facility which meets the definition of a stationary source that has one or more processes and utilizes one or more listed regulated substance is required to develop and implement a Risk Management Plan (RMP). Facilities must determine their exemption status or which of the three RMP programs they must implement.

National Pollutant Discharge Elimination System (NPDES) Permitting -

Industrial Stormwater Pollution Prevention Plans (SWPPPs) - A SWPPP is required to be developed, implemented, and maintained by a very broad spectrum of regulated facilities. However, not all regulated facilities are required to develop a SWPPP. Category "xi" dischargers that do not have material or equipment exposed to stormwater are not subject to the SWPPP requirement. Facilities which are, however, subject to the stormwater permitting requirements must have a Certified Stormwater Operator design and maintain the facility"s site-specific Stormwater Pollution Prevention Program.

 

Certified Stormwater Operator (CSO) - Many facilities desire to outsource the implementation and management of their Stormwater Pollution Prevention Program In these instances, a Prism CSO can be subcontracted to perform and administer the activities required.

 

Municipal (Phase II) Stormwater Management Programs - Under current permitting requirements, all regulated small municipal separate storm sewer systems (MS4s) must establish a stormwater discharge control program that meets the requirements of six minimum control measures. These minimum control measures include public education and outreach on stormwater impacts, public involvement/participation, illicit discharge detection and elimination, construction site stormwater runoff control, post-construction stormwater management in new development and redevelopment, and pollution prevention/good housekeeping for municipal operations, performed in the most efficient way to minimize contamination of stormwater discharges. Currently, two applicable permitting options are available. Although different in their approach, fulfillment of the conditions of either permit will satisfy the six minimum requirements presented previously. These permits are valid only when complimented with an appropriately signed and dated Certificate of Coverage issued by the governing agency. The two permit options available to small MS4s are commonly referred to as "general permits" and "individual permits". The individual permit is also known as a "jurisdictional permit".

Emergency Planning and Community Right-to-Know - Prism can assist with the various programs under Title III of SARA including emergency planning, emergency notification for releases, hazardous chemical reporting, and toxic chemical reporting (Form R).