Environmental Reporting, Auditing, and Permitting

Multi-Media Compliance Audits

Audits are often used by business owners and managers to evaluate where business practices can be streamlined to minimize the time to completion of project tasks and maximum cost savings. Environmental audits can save businesses money on the costs of compliance with environmental regulations and peace of mind knowing that they are completing the required project tasks. BJAAM Environmental, Inc. has over 30 years of experience in forming multi-media environmental compliance audits for industrial operations, including steel, chemical warehousing, and power and mining facilities. Our senior professionals can provide a full range of auditing services, including third-party audits, due diligence audits, or pre-agency audits. We will work with corporate and/or outside counsel to maintain attorney client privilege for project documents. BJAAM is experienced and flexible enough to craft an audit scope and report format to fit your specific project goals.

Ohio:

There are four major Ohio agencies that BJAAM prepares documents for on behalf of our clients, the Bureau of Underground Storage Tank Regulations (BUSTR), the Ohio Petroleum Underground Storage Tank Release Compensation Board (PUSTRCB), the Ohio Department of Natural Resources (ODNR) and the Ohio Environmental Protection Agency (OEPA). Under the Division of the State Fire Marshal, BUSTR oversees the regulation of underground storage tanks (USTs) in Ohio. PUSTRCB reimburses UST clean up costs through the Petroleum Financial Assurance Fund (“the Fund”) for eligible UST owners. Lastly, OEPA, created in 1972, ensures compliance with federal and state environmental laws. BJAAM can successfully prepare the following reports and permit applications for each of the three Ohio agencies.

BUSTR

• Tier 1 Notification
• Tier 1 Investigation
• Tier 1 Delineation
• Extension Requests
• Free Product Recovery (FPR)
• Public Notices for Remediation Action Plans
• Tier 2 Evaluation
• Tier 3 Evaluation
• Closure Assessments
• Closure In Place
• Ground Water Sampling Monitoring Wells
• Interim Response Action (IRA)
• Remedial Action Plan (RAP)
• Non-Compliance
• Suspected Release
• Immediate Corrective Actions
• Voluntary Action Program (VAP) Eligibility Request
• Petroleum Contaminated Soil
• Soil Classification
• Land Use Survey
• Potable Water Well Affidavit
• Class C Determination Request

PUSTRCB

• RAP Cost Pre-Approval
• FPR Cost Pre-Approval
• Eligibility Application
• Hardship Status Application
• Ability to Pay
• Tank Installation Notification
• Tank Inventory
• Tank Removal Notification
• Tank Replacement Notification
• Transfer of Ownership
• Certification Affidavit
• Claim Reimbursement Application
• Remediation System Disposition and Documentation

ODNR

• Environmental Assessment Reports – may include soil and groundwater sampling and/or analysis of site hydrogeochemistry
• Discharge Plans and Reporting
• Remedial Action Plans
• Source Area Removal Reporting

OEPA

• Injection Fluids
• Hazardous Waste Biennial Reporting
• DMR (Discharge Monitoring Report)
• SW3P/SWPPP (Stormwater Pollution Prevention Plan)
• Major Source Operating Permits (Title V of the Clean Air Act)
• Major Source Installation Permits (PSD-Prevention of Significant Deterioration & NSR-New Source Review)
• Minor Source installation and operating permits
• Annual air inventory reports (Title V and Non-Title V of the Clean Air Act)
• Preparation and implementation of a comprehensive Waste Management Plan
• Individual and general NPDES (National Pollutant Discharge Elimination System) wastewater and storm water permitting
• Pretreatment Discharge permits – Component of the NPDES regulation

Pennsylvania:

There are two major Pennsylvania agencies that BJAAM writes documents for on behalf of our clients, the Pennsylvania Department of Environmental Protection (PA DEP) and the Pennsylvania Underground Storage Tank Indemnification Fund (PA USTIF). Formerly called the Department of Environmental Resources, the PA DEP was founded in 1970 by Act 275 and oversees the compliance of federal and state environmental laws. PA USTIF provides reimbursement funds for cleanup of hazardous releases into the environment. BJAAM can successfully prepare the following permits and reports to Pennsylvania environmental agencies.

PA DEP

• Major Source Operating permits (Title V of the Clean Air Act) – also sent to the Allegheny County Health Department (ACHD), Philadelphia Air Management Services (AMS), & EPA Region 3
• Major source installation permits (PSD-Prevention of Significant Deterioration & NSR-New Source Review) – also sent to ACHD, Philadelphia AMS, and EPA Region 3
• Minor Source Installation and operating permits – also sent to ACHD, Philadelphia AMS, & EPA Region 3
• Annual air inventory reports
• Hazardous Waste Biennial Reporting
• PPC (Preparedness, Prevention, and Contingency) Plan
• Chemical Analysis of Waste Preparation – Form 26R
• NPDES (National Pollutant Discharge Elimination System) Permitting
• Pretreatment Discharge Permitting
• Air Quality Requests for Determination
• Preparation and implementation of a comprehensive Waste Management Plan

PA USTIF

• Eligibility reports
• Claim reporting

West Virginia:

There is currently only one state-specific environmental regulation agency that oversees environmental policies and regulations in West Virginia. The West Virginia Department of Environmental Protection (WV DEP) works in conjunction with EPA Region 3 to ensure compliance and the regulation of federal and state environmental laws. BJAAM can prepare the following reports and permit applications for our West Virginia clients.

• Major Source Operating Permits (Title V of the Clean Air Act) – also sent to EPA Region 3
• Major Source Installation Permits (PSD-Prevention of Significant Deterioration & NSR-New Source Review) – also sent to EPA Region 3
• Minor Source Installation and Operating permits – also sent to EPA Region 3
• Hazardous Waste Biennial Reporting
• Annual air inventory reports
• SW3P/SWPPP (Stormwater Pollution Prevention Plan)
• GPP (Generic Groundwater Protection Plan)
• Individual and General NPDES (National Pollutant Discharge Elimination System) stormwater and wastewater permitting
• Pretreatment discharge permits

Federal:

State agencies, such as Ohio EPA or Pennsylvania DEP, enforce many environmental laws and reporting requirements dictated by federal regulation. However, there are a few reports and permits that must be submitted directly to the United States Environmental Protection Agency (U.S. EPA). The following reports, plans, and permits can be prepared by BJAAM and sent to the federal government on the behalf of our clients.

U.S. EPA

• NESHAP (National Emissions Standards for Hazardous Air Pollutants) Threshold Determinations and Reporting
• Greenhouse gas tracking and annual reporting (GHGRP-Greenhouse Gas Reporting Program)
• NPDES (National Pollutant Discharge Elimination System) discharge monitoring report
• TSCA (Toxic Substances Control Act) CDR (Chemical Data Reporting)
• RCRA (Resource Conservation and Recovery Act) Contingency Plan Preparation – to be kept at the facility and sent to state and local emergency services
• SPCC (Spill Prevention, Control, and Countermeasure Plan)
• EPCRA (Emergency Planning and Community Right to Know) Reporting
• SARA Section 302 extremely hazardous substance (EHS) notification
• SARA Section 304 EHS release notification
• SARA Section 311/312 inventory reporting (Tier I and Tier II)
• SARA Section 313 release reporting (Form R)