Successful management of permitting and regulatory compliance matters involves an understanding of the existing environmental regulations, the regulatory structure, and the nature of client operations. Our in-depth knowledge of permit processes, understanding of client needs, interpersonal relations with agency staff, and creative problem-solving skills enhance our permitting and compliance success. EPI recognizes the importance of understanding how environmental regulations apply to various industries and situations. EPI meets the permitting challenge with experience, attention to detail, foresight, and the ability to build and maintain relationships. Our experience in providing regulatory compliance assistance to clients throughout the United States and Canada ranges from a cursory compliance review of an individual facility to full compliance audits of multiple sites in support of a corporate acquisition.

This approach has built credibility and confidence with federal, state, and local regulators and makes review easier and more efficient. EPI has enabled many clients to identify existing and potential areas of non-compliance, understand their associated liabilities, and develop and implement timely, cost-effective compliance strategies.

Selected examples of permitting, regulatory compliance, and audit services EPI personnel have provided clients are presented below.

Project #1: Methane Energy Corporation (MEC) is an exploration and development company working to develop natural gas from coal (NGC) in the Coos Bay Basin region of Oregon. EPI is providing comprehensive environmental management services for MEC. These services include the development of an Environmental Management Plan (EMP) for all aspects of exploration and development. The EMP incorporates a Waste Management Plan, Erosion and Sediment Control Plan, and Spill Prevention and Response Plan. In addition EPI is providing MEC with all necessary permitting, employee training, and monitoring system guidance to ensure efficient, cost-effective environmental compliance in all aspects of NGC exploration and development.

Project #2: The process operations of five specialty chemical manufacturing units were the focus of an environmental compliance audit conducted by EPI. P&ID drawings and other physical plant data were also reviewed to evaluate compliance with SARA Title III – Sections 311, 312, and 313.

Project #3: EPI audited multiple emission sources from a spray coating operation, within the context of numerous batch operations, and a varied product-slate for compliance with the State of Connecticut Hazardous Air Pollutant Regulations. We developed an approach that eliminated an otherwise extensive sampling/testing program for each source and event. We also developed a basic model of the company’s process operations using readily available PC spreadsheet software. Requisite data were extracted from existing facility files and subjected to verification checks. Worst-case scenarios were formulated and multiple cases evaluated to determine compliance or non-compliance.

Project #4: EPI provided support to legal counsel in the course of litigation about responsibility for multi-media contamination at a large chemical manufacturing facility. Because the manufacturer used batch operations, the processes and piping and instrumentation diagrams were reviewed in concert with chemical synthesis data to determine possible sources and methods of release for a large array of chemicals and minor impurities. Interrogatories were prepared for use by legal counsel during depositions.