How we do it.

CAP approaches each project with a specific goal in mind, to handle your immediate air permit compliance needs and set you up on a solid footing going forward. Look over "Our Process" for a better understanding on how we achieve that.

 

An effective environmental management system should strive for an environment of zero tolerance for noncompliance.  Yet if any noncompliance events occur there should be SOPs in place to promptly address the matter and reduce the likelihood of future reoccurrences.

Our Process

1.  Address any time sensitive compliance needs; this may include completing a compliance task coming soon due or responding to a NOV.

a.  If your company was given an NOV we can investigate if a fine reduction may be in order.  After that is determined we will write a plan to remedy what caused the NOV.

2.  Once the time sensitive tasks are completed we will do a thorough review of any existing relevant permits at the facility to ensure that they accurately represent facility operations and that reporting and recordkeeping levels are set at their appropriate levels.  All emission units, points, sources, and processes must be represented in the air permit. At this stage we would conduct a site visit if one has not already occurred. At this point we will offer a proposal and schedule to address all permitted compliance tasks. This proposal is the result of a cursory compliance audit or gap analysis.

a.  It is quite possible that elements of permit conditions could be incorrect or the condition may reflect operation from equipment no longer at the facility.

b.  Quite often regulatory citations are incorrect as written.

3.  Write a compliance plan for the facility to minimize the burdens on onsite personnel while also meeting all regulated compliance requirements. 

a.  As an example, if you are a Title V facility, there will be: annual reporting, semi-annual reporting, quarterly reporting (in most states), annual emission statements, greenhouse gas reports (when applicable), permit modifications, permit renewals, malfunction reports, and frequent interaction with government agencies.

i.  We complete the reports, submit a draft to your facility, and then aid in the submittal process.

b.  (If necessary) suggest modifications to the site SOPs. 

c.  (If necessary) implement new staff training.

4.  Provide the facility with a daily recordkeeping EXCEL spreadsheet to track compliance status in real time. If the site is approaching a permitted fuel or hours cap, an alarm will sound.

5.  We usually offer our clients a 'General Services' task to handle any out of scope small issues or any necessary interactions with regulating agencies. 

6.  We strive to keep our clients informed of new or pending regulations and what they may mean for their specific site. 

7. We take great pride in being a trusted resource for regulatory interpertations and implications. If you have a question, call us, we can likely help walk you through it.

8. We are often brought onto a project to get everything back on schedule/budget. Through proper scoping and scheduling, we can offer realistic forecasts for your project. 

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Randy Thompson