Services

We build programs for facilities with toxic and flammable substances subject to OSHA Process Safety Management (PSM), EPA Risk Management Plan (RMP), California Accident Release Prevention Program (CalARP), or all three. We work extensively with operations that store and handle anhydrous ammonia and aqueous ammonia solutions, along with other listed toxics and flammables across ag retail and manufacturing, such as pesticide active ingredients and formulation constituents.

Applicability is primarily driven by exceeding a threshold quantity of a listed chemical, but not always. We start with applicability analysis to pin down exactly where you stand, run the off-site consequence analysis in-house with ALOHA, SLAB, SCREEN3, and RMP*Comp, build audit-ready programs you can adopt as-is or tailor to your corporate policies, and stay with you through implementation.

Our PSM and RMP programs have been through EPA compliance audits across Regions 4 through 10 since 2004.

We identify hazards before they become incidents at facilities that store and handle hazardous chemicals — Process Hazard Analyses (PHA) and Job Hazard Analyses (JHA), plus Dust Hazard Analyses (DHA) for grain, feed, fertilizer, and other combustible dusts. Where no program applies but recognized hazards exist — ammonium nitrate storage among them — a hazard assessment is how you show the general duty provisions enforced by OSHA and EPA have been met.

PHAs are a required element under the PSM and RMP that must be revisited at least every 5-years. We run initial studies and revalidations, whether we built the program or someone else did. They tell you where your real exposure is, what to fix first, and the risk you are accepting when you don’t.

Emission sources add up across a site, and not all of them are obvious. Particulate matter from handling grain, fertilizer, and other aggregate materials. Combustion products from dryers, boilers, and heaters. Volatile organic compounds (VOC) and hazardous or toxic air pollutants from processing fuels, liquid fertilizers, crop protection chemicals, and solvent-based formulations. And fugitives — emissions from haul roads, storage piles, and transfer points that never pass through a stack.

Not every source needs a permit, but determining that can be difficult. We handle exemption and applicability determinations up front. From there: major source permitting under New Source Review, PSD, and Title V, and minor and synthetic minor permitting where the thresholds don’t reach — minor source applications can be as involved as major ones. We run screening and refined dispersion modeling in-house with SCREEN3, AERSCREEN, and AERMOD, and support ongoing permit compliance with emissions inventories, reporting, renewals, and modifications.

The Clean Air Act sets the framework, but your permit comes from a state or local agency with its own forms, its own interpretations, and its own list of regulated pollutants. We have worked with those agencies in 20 states.

Both Spill Prevention, Control, and Countermeasure (SPCC) plans and Stormwater Pollution Prevention Plans (SWPPP) focus on protecting waterways from pollutants. SPCC is specific to fuels and oils escaping containers and entering navigable waters, while SWPPP covers pollutants that stormwater runoff picks up when it leaves the property. Same endpoint, different paths — but they may not reach the same facilities.

In general, SPCC is triggered at onshore facilities when the aggregate aboveground oil storage capacity exceeds 1,320 gallons, counting every container of 55 gallons or more — totes, drums, and mobile tanks included. Oil is broader than petroleum: vegetable oils, animal fats, seed and crop oils, used oil, hydraulic and lubricating oils, and certain oil-based mixtures all count.

For SPCC, we start with threshold analysis to confirm whether you’re exempt, qualify to self-certify as a Tier I or Tier II facility, or need a P.E.-certified plan. We develop the plan and coordinate P.E. certification through qualified licensed engineers.

SWPPP coverage is narrower — stormwater permit applicability is determined by SIC codes that designate industrial activities, and facilities with real runoff exposure sometimes fall outside it.

For stormwater permitting, we first determine whether an exclusion applies. When a permit is required, we develop industrial and construction SWPPPs covering site drainage and outfalls, potential pollutant sources, structural and non-structural BMPs, inspection and benchmark monitoring routines, corrective action, and recordkeeping. We also file Notices of Intent (NOI) and obtain permit coverage.

We’ve built and actively maintain more than 200 SPCC plans across 30-plus states.

Emergency Planning and Community Right-to-Know Act (EPCRA) reporting runs on fixed dates. Each year, Tier II is due March 1 and Toxic Release Inventory (TRI) is due July 1 for the prior calendar year.

For most hazardous chemicals, Tier II reporting applies when present at the facility at any one time during the calendar year in quantities that equal or exceed 10,000 pounds, but chemicals on the extremely hazardous substances (EHS) list carry lower thresholds, some far lower. TRI reporting applies to facilities with a covered industrial NAICS code that have 10 or more full-time equivalent employees and a listed chemical above the 25,000-pound threshold for manufacture and process or the 10,000-pound threshold for otherwise use. Some chemicals carry substantially lower thresholds — persistent bioaccumulative toxics are reported at a fraction of those quantities.

We handle applicability and threshold determinations for each reporting program, then complete the filings — Tier II to your state, LEPC, and fire department, and TRI Form A or Form R to EPA. For TRI, we also determine release pathways and quantify releases. When TRI listed chemicals leave your site in a mixture, we prepare the required supplier notifications.

An audit tells you what an inspector would find, before an inspector finds it.

Programs drift. Staff turns over, sites change, and the plan on the shelf stops matching what’s happening in the yard. Our multi-media environmental and OSHA audits, including Responsible Ag audits, document exactly where you stand — and we’ve worked both sides of the audit, in industry and inside the enforcement agencies.

We hold Responsible Ag auditor credentials and have taken facilities through the assessment and the corrective actions that follow.

PSM and RMP require certified compliance audits every three years. We run those on cycle — for programs we built and, as an independent third party, for programs we didn’t. We audit against regulatory requirements, your corporate standards, or both, with extensive experience in EPA and state audits.

Compliance programs come with training and implementation requirements, most of them on set cycles. Knowing what’s due, for whom, and when is its own job — and it usually belongs to someone who already has significant responsibilities.

We deliver training in person and virtually, and we work with you to build the material around your procedures rather than pulling from a generic course. That covers new program rollouts, refreshers when they come due, and the task-level training your programs and permits depend on to maintain compliance.