Environmental Compliance

CTI has over 30 years of experience working closely with our clients and regulators to manage all aspects of environmental protection and compliance. Whether it is a specific permit application, waste disposal program, or a full Environmental Management System (EMS), our staff of engineers is available to assist with any aspect of air, land, and water protection and compliance.

Air Quality Permitting
Environmental Compliance Audits
Environmental Management Systems
ISO 14001 Consulting
Phase I & II Environmental Site Assessments
RCRA Compliance
SARA Title III – Tier II / Form R
Spill Prevention Control and Countermeasures (SPCC)
Stormwater Permitting
Wastewater Permitting and Compliance

Air Quality Permitting

All facilities that release air emissions are required to comply with air quality permitting requirements. Having an up-to-date air permit and remaining in compliance with the permit, including sampling and recordkeeping obligations is of great importance where air emissions exist. CTI has extensive experience assisting industrial facilities in complying with these comprehensive air quality regulations. Our staff consists of qualified engineers that can help determine what actions are needed in order to obtain and maintain regulatory compliance. CTI’s staff is experienced in communicating with state and federal regulatory agencies, supervising stack and emission test, preparing all required permit applications, and compiling site specific recordkeeping programs that are suitable with each client’s personal needs.
Specifically, CTI can assist with:

  • Air Permit Applications
  • Emission Inventory and Recordkeeping
  • Title V Permitting
  • Prevention of Significant Deterioration (PSD) Permitting
  • MACT/ Area Source Analysis
  • PCWP MACT Information Collection Request
  • Plume Dispersion Modeling
  • Air Emission Testing and Monitoring
  • Air Pollution Control Design

For more information about Boiler MACT/GACT Compliance, click here.

Environmental Compliance Audits

CTI has assisted hundreds of companies in achieving regulatory compliance by conducting Environmental Compliance Audits. Environmental Compliance Audits are used to evaluate a facility’s compliance with all local, state, and federal regulatory agencies. These audits entail a review of current permits the facility may have, as well as a walkthrough of the facility grounds and activities in order to determine if further permitting may be required and if the current permit conditions are being maintained. The audit is a perfect tool for determining a facility’s environmental compliance. CTI’s staff is able to take the information gathered from the records and permit reviews, along with the findings from the walkthrough, and utilize over 30 years of regulatory knowledge and experience, and prioritize those items that are needed to bring the facility into full compliance with all environmental regulations.

Environmental Management Systems

An environmental management system (EMS) refers to the management of an organization’s environmental programs in a comprehensive, systematic, planned and documented manner. It includes the organizational structure, planning and resources for developing, implementing and maintaining policies for environmental protection. A properly implemented EMS can provide many benefits to a company, including:

  • Ensuring compliance with regulatory requirements
  • Minimizing risk
  • Improving corporate image
  • Meeting customer demands
  • Provides a systematic way of managing an organization’s environmental affairs
  • Gives order and consistency for organizations to address environmental concerns through the allocation of resources, assignment of responsibility, and ongoing evaluation of practices, procedures, and processes

With decades of experience in regulatory issues and the design and implementation of effective EMSs, CTI regularly assists clients with EMS services. This experience and expertise mixed with the knowledge of our management system experts, CTI ensures a successful and cost-effective EMS implementation for our clients.

ISO 14001 Consulting

CTI has developed and implemented many environmental management systems for clients that have strived to meet the International Organization for Standards (ISO) 14001 standard on environmental management. Our services in this regard include initial plan development, training and recordkeeping support, and the use of our certified internal auditors on staff to ensure that ISO 14001 certification can be attained and maintained.

Specifically, CTI can:

  • Assist you in developing the written programs, policies, and forms that comprise your management system.
  • Work with your staff to implement the management system.
  • Audit your management system and its implementation.
  • Aspects and Impacts Analysis

Phase I & II Environmental Site Assessments

The purpose of Phase I & II Environmental Site Assessments is to assess past and present land use practices, site operations and conditions, and to identify the potential presence of hazardous substances and soil and/or groundwater contaminants on site.

CTI has conducted Phase I Environmental Site Assessments for properties and facilities in a variety of industries in dozens of states. Many of these Phase I assessments involved sites with industrial activity and contaminated sites requiring expert environmental knowledge to properly assess the site. CTI’s environmental site assessments are conducted and prepared in conformance with American Society for Testing and Materials (ASTM) practice E1527-13 and with 40 CFR Part 312 Standards and Practices for All Appropriate Inquiries.

Our assessments are more than just repots and checklist completed by junior personnel. We provide our clients with detailed information on the environmental status of the facility or property so that rational judgments can be made by owners as to the environmental risks that are inherent in any loan and property procurement.

Phase I Services

  • Perform visual assessment of property
  • Review of chain-of-title information
  • Review historical records
  • Review of public records
  • Perform environmental risk assessment of properties within ASTM radii

Phase II Services (if warranted)

  • Surface and/or subsurface sampling
  • Verification of the existence/absence of contamination
  • Environmental laboratory analysis of samples
  • Documentation of assessment conditions
  • Recommendation of remediation, if warranted

RCRA Compliance

Under the Resource Conservation and Recovery Act (RCRA), the USEPA has established regulations that define how hazardous and non-hazardous waste is handled, recycled, and disposed of. CTI is available to assist your facility in identifying the types of wastes generated and the options for waste reduction, recycling, and management. We are also available to assist you obtain permits, prepare plans and SOPs, and close end-of-life hazardous waste management units (e.g. drip pads, tanks systems).

CTI can assist your facility with all responsibilities related to managing hazardous and non-hazardous wastes, including:

  • Contingency Plan Preparation
  • Employee Training for Hazardous and Universal Waste
  • Hazardous Waste Biennial Reporting
  • Hazardous Waste Generator Status Evaluation and Inspection
  • Permitting Treatment, Storage and Disposal Facilities (TSDF)
  • Private Industry Landfill Permitting
  • Waste Analysis and Characterization
  • Waste Management and Minimization Plans
  • Waste Management Unit and Facility Closure

SARA Title III – Tier II / Form R

The Superfund Amendments and Reauthorization Act (SARA) Title III reporting law requires facilities with 10 or more full-time employees to report annually the storage (Sections 302, 303, 311, and 312) and release (Section 313) of reportable materials that exceed certain thresholds. Forms must be submitted each year to local, state, and federal agencies, indicating the amounts of these reportable chemicals that your facility uses and stores. CTI can provide all of the necessary SARA reporting for your facility. We are capable of determining which requirements apply to your facility and completing all necessary reporting.

Spill Prevention Control and Countermeasures (SPCC)

The USEPA, under the authority of the Oil Pollution Act (OPA), requires facilities that have the capacity to store over 1,320 gallons of petroleum products and/or oil (including vegetable oils and fats) to prepare and implement a Spill Prevention Control and Countermeasures (SPCC) Plan. The SPCC Plan documents the oil storage capacities at your facility, where spills would discharge, what physical controls are in place to prevent a discharge, and what procedures the facility has to respond to an oil spill. SPCC plans for moderate to large facilities (those with capacities greater than 10,000 gallons) must be prepared by a licensed professional engineer, and all SPCC Plans must be reviewed every 5 years, or whenever there is a change in the facility design, construction, operation, or maintenance that affects its potential for a spill.

We are available to assist in the development, preparation, and implementation of an effective Spill Prevention Control and Countermeasures (SPCC) Plan for you facility, including providing engineering of secondary containment systems. Along with the development of an SPCC plan, we can provide Spill Response training, along with conducting spill drills for your employees.

Stormwater Permitting

CTI is able to provide assistance with multiple facets of National Pollutant Discharge Elimination System (NPDES) stormwater permitting services with all industrial activity in a cost-effective and timely manner. Our services in this area includes assisting with industrial stormwater permitting and design, and preparing Stormwater Pollution Prevention Plans (SWP3) and Best Management Practices (BMPs) Plans. CTI’s services extend beyond the initial preparation of the SWP3; in order to decrease the burden on a facility’s time and energy, we can perform required storwmater inspections, assist with and manage stormwater testing procedures, respond to Notice of Violations (NOVs), prepare Notices of Intent (NOIs), and much more.

Smoke & Dye Testing (Georgia)

Permittees under the Georgia Industrial Storm Water General Permit must document, on the annual report, that they have evaluated for the presence of non-storm water discharges annually and that all unauthorized discharges have been eliminated. If there are any floor drains in the production area and/or sinks that are not in the bathroom, kitchen, breakroom, etc., further evaluation is required.

The evaluation includes:

  • Locating potential connections to your storm water system.
  • Verification that floor drains and connections go to municipal sewer.

The above needs to be verified from as-built drawings and/or by conducting a smoke and dye test at least once during the term of the permit. The smoke and dye test must be conducted to evaluate for the presence of non-storm water discharges into the storm sewer system from all floor drains, and from all sinks in industrial areas excluding eyewash stations that were installed prior to 1/1/2006. Facilities must document, in the annual report, the date of the last smoke, dye or equivalent test, or why this test is not applicable to the facility.

Wastewater Permitting and Compliance

A number of industrial processes directly and indirectly generate wastewater that must be handled in accordance with the USEPA Clean Water Act (CWA), as well as state and local standards. We are available to evaluate your facility’s current sources of wastewater to determine if an industrial pretreatment, National Pollutant Discharge Elimination System (NPDES), or land application permit is required. CTI can provide services including compliance sampling and analysis, design and selection of wastewater treatment systems, preparation of wastewater and NPDES discharge permit applications, and treatability studies to determine treatment requirements.