Environmental permitting and compliance
GPS provides a full range of environmental permitting and compliance auditing services for new or modified petroleum refineries, petrochemical and EP facilities. These services include environmental compliance audits; evaluation, design, and implementation of environmental management systems; regulations tracking and local, state, and federal permitting. GPS professionals have extensive permitting experience in solid and hazardous waste issues, air quality, and water quality.
Solid and Hazardous Waste Permitting
GPS professionals have performed numerous projects related to hazardous waste management for refineries, petrochemical and EP facilities under Subtitle C of RCRA and state requirements.
Typical solid and hazardous waste permitting services include:
- Development of written plans, specifications procedures, and design drawings including contingency plans, new site and existing site expansion plans, and spill prevention control and countermeasures (SPCC) plans.
- Performance of environmental impact and risk assessments.
- Development and evaluation of health and safety plans.
- Performance of remedial investigations/ feasibility studies.
- Response to regulatory comment and review.
- Development and implementation of remedial measures for contamination abatement.
- Preparation of RCRA Part A and B permit applications.
- Performance of PCRA facility investigations (RFIs), including development and implementation of work plans.
- Preparation of sampling plans to characterize hazardous/non-hazardous waste sites.
- Performance of compliance investigations of waste treatment, storage, and disposal facilities.
GPS has provided RCRA permit negotiation services for numerous clients. These services include providing technical and administrative support to clients in the process of commenting on negotiating RCRA B permits, and RCRA Corrective Action Permits.
GPS has been highly successful in negotiating with regulatory agencies to reduce the facility investigations, Corrective Measures studies, and site cleanup requirements initially included in regulatory documents. These efforts have resulted in considerable cost savings to our clients.
Environmental Compliance Auditing Services
GPS also provides a full range of environmental auditing services and permit maintenance services:
- Review of in-house documentation and other materials, including existing permit applications, waste analysis plans, personnel training plans, contingency plans, and closure plans. These materials are reviewed to evaluate their compliance with appropriate regulations. If the materials do not comply with regulations, or if they do not exist, GPS can amend or prepare these materials.
- Conducting site visits of facilities to evaluate their design and to assess current operating practices that relate to the regulatory status and permittablility of the facilities. Recommendations for upgrading designs, equipment, and/or waste management practices are also made.
- Preparation of waste characterization, classification, and treatability studies.
- Prepare and implementation of closure plans, certification of closure, and preparation and implementation of closure and post closure monitoring programs.
- Preparation and implementation of ground water quality assessment programs.
GPS’s response to the increase in environmental regulations for petroleum and petrochemical facilities has been to developed an environmental audit program to assist clients in meeting federal, state, and local standards. This program provides protocols, checklists, and auditing programs for key compliance areas including:
- Oil spill contingency planning
- Risk Management and Prevention Programs (RMPP)
- Used oil disposal/recycling
- Solid and hazardous waste generation
- Solid and hazardous waste treatment, storage, and disposal
- Wastewater discharge and pretreatment
- Stormwater management plans
- Underground storage tank management
- Injection wells and enhanced recovery systems