Environmental Compliance

Facilities with equipment creating air pollution may need to file for an air permit or registration from the Agency. Our engineers and environmental professionals are experienced with modifying existing permits and permitting new greenfield facilities through the New Source Review process. Past projects completed by our team include projects related to nearly all the NESHAP and NSPS regulations.

Our background includes emission estimations for criteria pollutants, HAPs, CO2e and other individual pollutants of concern where needed. We have estimated emissions for permitting, reporting, disclosure projects and other internal reporting purposes. Our services include routine estimations required by permit or rule that need to be reported or maintained on site.

Our services include preparing and filing routine reports required by permit or by rule, such as quarterly, annual emission, NSPS and NESHAP reports. We are experienced with various state, federal and disclosure reporting software in the United States, Canada and Mexico.

Whether your organization, customer or other entity requires carbon to be estimated and disclosed, our experience with various methods and reporting platforms will allow us to help accurately disclose CO2e for the organization and it's facilities.

Our network of stack testing companies allows us to connect you with a tester in your region that is available. We guide the facility through the stack testing process including preparing the facility and exhaust outlets, filing notifications, test day project management, test day record keeping, results and report review and final submittal to the Agency.

Our team is available to assess your operations and work practices to determine if you are complying with federal regulations and provide guidance. Some of these federal programs require reporting to the state Agency or EPA through the CDX software and we are experienced in preparing and filing these reports.

Where state and federal rules require specific training, BCA may provide the training or can help facilitate the training with an appropriate vendor.

Our engineers and project managers have been working with facilities since the Clean Air Act amendments of the 1990s, so we have worked through several 114 requests and have experiences related to nearly any request that the EPA may issue to the facility.

We are not a law firm, nor do we partner with any law firms. We may provide suggestions, but our role in litigation is to help the facility locate records, provide technical data, assess rules, applicability, and compliance and assist in preparing response submittals to the Agency. Overall our role is to be the liaison between the facility, Agency and legal counsel.

Other relevant air related services include Risk Management Plans, Preventive Maintenance Plans and Emergency Reduction Plans.

We have experience with reporting in over twenty-five (25) states and their reporting platforms. We can visit the site to conduct a chemical inventory needed to complete the Tier II or work with personnel at the facility remotely to gather information to complete the inventory and file the report. All Tier II reports are due by every year March 1.

Our direct experience with reporting Form R includes industries such as chemicals, steel, plastics, and automotive, but our collective experience across all service categories (e.g. air, waste and air reporting and permitting) allow us to all types of industries. We can visit the site where needed to assess what is manufactured, processed or otherwise used to estimate emissions, discharges and waste generated. All Form R and A reports are due every year by July 1.

BCA will assess the facility and implement methods to communicate hazards of the chemicals being stored and used at a facility. Methods of communication may include hard copy or digital means. BCA is available to translate any hazard communication and GHS materials to Spanish.

We provide 3-year DOT training to those that receive, handle and prepare hazardous materials for shipment. Our team is also available to provide consulting, guidance and work instructions related to how hazardous materials need to be received, handled and prepared for shipment.

Each state has different rules related to storage tank permitting, but most states require above ground storage tank holding flammable materials to be permitted through the state department of homeland security or other emergency services agency. We are equipped to asses tanks and their contents and file for a permit if required by the state's rule.

Whether it is related to Tier II reporting or complying with OSHA SDS requirements, BCA is experienced with developing chemical inventories and tracking tools for facilities to maintain and use going forward. BCA is available to conduct routine chemical inventories as part of an organization's assurance programs.

Federal, state or internal programs may require a facility to assess and categorize all substances on site. This may include identifying the hazards and which chemicals are specifically listed and regulated by EPA, OSHA, Canada and Mexico. BCA is available to facilitate the chemical inventory and identify any special handling and reporting thresholds described in local, state and federal rules.

Organizations that import, export or manufacture chemicals may be required to submit a Form U under TSCA 40 CFR Part 711. BCA is available to determine what chemicals need to be reported and can file the report on behalf of the organization. Reports are required every four (4) years (2024, 2028, 2032...).

We help manage SDSs in various ways including hard copies on site, PDFs on a shared cloud server or on a client owned software. Combined with our chemical inventory and hazardous substance determination, BCA is available to help maintain an accurate SDS file so employees have quick access to current and past SDSs.

Other relevant chemical related services include REACH, RoHAS, Prop 65 and Life Cycle Analysis.

Facilities with more than 1,320 gallons of oil on site may be required to implement a Spill Prevention Control and Countermeasure Plan in accordance with 40 CFR 112. This includes process and storage containers equal to or greater than 55 gallons. Our team is available to prepare, implement and train staff on the SPCC Plan. If the Plan is required to be certified by a licensed Professional Engineer, our staff includes licensed Professional Engineers so we can certify the Plan.

Facilities with industrial related materials exposed to stormwater may be required to implement a Storm Water Pollution Prevention Plan or Best Management Plan. Sites may be governed by the General stormwater permit rule or under certain circumstances may be issued an Individual stormwater permit by the Agency. In either scenario, our staff of environmental professionals are available to prepare, implement and train staff on the SWPP Plan. Our professionals will also train facility staff on proper collection of stormwater samples during rain events.

Our engineers and environmental professionals are experienced with modifying existing permits and permitting new discharges. We are experienced with permitting facilities as indirect dischargers to a local Publicly Owned Treat Works (POTW) or direct dischargers to a regulated body of water. When pretreatment is required, BCA can provide support in the design and procurement of the treatment system.

Our engineers and environmental professionals are experienced with modifying existing permits and permitting new discharges. We are experienced with permitting facilities under the General permit rules or as an Individual permit with the state Agency. When pretreatment is required, BCA can provide support in the design and procurement of the treatment system.

Our staff of environmental professionals and certified wastewater operators are available to conduct routine wastewater or stormwater sampling of facility effluent to complete Discharge Monitoring Reports. BCA is also available to train and write work instructions for facility staff to conduct sampling in-house.

40 CFR 112.7 requires annual training for staff that are handling oil at the facility. Our PEs and Senior Professionals are available to provide on site custom training that is tailored to the facility, operations and oil handling practices.

General and Individual stormwater permits require annual training for personnel that interact with exposed materials and Best Management Practices at the facility. Our PEs and senior professionals are available to provide on site custom training that is tailored to the facility, operations and oil handling practices.

Our network of integrity testing companies allows us to connect you with a tester in your region and that is available. We can then guide the facility through the integrity testing process including preparing the facility, filing notifications, test day project management, test day record keeping, results and report review and final submittal to the Agency.

Our network of certified wastewater operators allows us to provide a wastewater operator in your area.

Facilities that discharge wastewater to a POTW may be required to implement a Slug Prevention and Control Plan to identify, mitigate and control sources of spills and illicit discharges to the wastewater system. This includes process and storage containers. Our team is available to prepare, implement and train staff on the Slug Prevention and Control Plan. If the Plan is required to be certified by a licensed Professional Engineer, our staff includes licensed Professional Engineers so we can provide a certified Plan.

Our team of engineers, geologists and environmental professionals are available to coordinate the removal of underground storage tanks. Tanks need to be assessed, tested and appropriately closed through the Agency. If testing indicates pollution from the storage tank, BCA will establish and coordinate an approved clean-up plan. When the tank is approved for removal, BCA will coordinate removal through our network of vendors

Our team of engineers, geologists and environmental professionals are available to develop a clean-up plan and coordinate remediation with our network of vendors. During the evaluation phase we estimate which pollutants were released and compare that to reporting thresholds described in EPA rules. For more information our Spill Response service page. (link to the Spill Response page under Investigation and Remediation)

We are not a law firm, nor do we partner with any law firms. We may provide suggestions, but our role in litigation is to help the facility locate records, provide technical data, assess rules, applicability, and compliance and assist in preparing response submittals to the Agency. Overall our role is to be the liaison between the facility, Agency and legal counsel.

Facilities that provide drinking water on site via a well rather than via local water supply may be required to file for a drinking water permit as a non-community public drinking water supply system. We are available to permit the facility and provide on-going sampling support as required by the drinking water permit.

Other relevant water related services include PPC Plans, Flow Measurement Plans, Pretreatment Contingency Plans, Pretreatment System Consulting, Facility Response Plans, DNR Water Withdrawal Reporting and Wellhead Protection permitting and Plans.

All Large Quantity Generators must report the amount of waste generated at least once every two (2) years to the EPA. State Agencies may require more frequent reporting for Large Quantity and Small Quantity Generators. Our team of environmental professionals are available to review waste manifests and assess points of generation to file Waste Manifest Reports. RCRA Hazardous Waste Manifest reports are due March 1.

40 CFR 262 requires Large Quantity Generators to provide annual training for staff that are handling and managing hazardous waste. Small Quantity Generators are required to ensure all affected employees are appropriately trained. Our PEs and Senior Professionals are available to provide on site custom training that is tailored to the facility and site waste practices.

40 CFR 262 requires Large Quantity Generators to implement a Contingency Plan focused on preventing and controlling emergency situations that may involve hazardous waste. The Plan must also include a Quick Reference Guide that is submitted to local emergency authorities. Our staff of environmental professionals are available to prepare, implement and train staff on the Contingency Plan.

Our team is experienced with assessing waste streams at the point of generation and assessing applicability with Land Quality regulations to determine how it will need to be profiled and managed. BCA will identify and categorize each point of waste generation and determine how each waste stream must be managed. Our team is also available to coordinate with the disposal facility and hauler to receive approval.

When profiling waste streams, some wastes may need to be tested by a laboratory to determine if they need to be Categorized as RCRA Hazardous Waste. Our team of environmental professionals are experienced with assessing raw materials and processes that produce the waste stream so we can determine the appropriate test methods and ensure it is categorized and handled in a compliant manner.

Prior to shipping RCRA Hazardous Waste, a facility must register with the EPA and state Agency to obtain a RCRA Site ID number. BCA will file for a Site ID through the appropriate application methods with the state Agency, or EPA if the facility is not in an Authorized state.

Small Quantity and Very Small Quantity Generators are allowed one (1) unplanned (e.g. spill) and one (1) planned (e.g. plant cleanout) episodic waste generation event per year. BCA has assisted several facilities discard of episodic wastes under this exclusion. Our team of professionals are available to file the notification for the episodic event, coordinate waste removal, maintain appropriate records and inventory and file closure notifications to the Agency.

Large Quantity Generators must follow the closure requirements described in 40 CFR 264 which includes pre-notifications and certifications that the site is not contaminated. Our experienced team includes Professional Engineers and Certified Hazardous Materials Managers are available to assess the facility to ensure it is not contaminated or develop a clean-up plan when needed. We will file the required notifications and guide the facility until the facility receives closure approval from the Agency.

For facilities located in Northern Indiana, Southern Michigan and Northwest Ohio, BCA can provide an environmental professional to visit the site each week and conduct weekly hazardous waste inspections of waste generating and storage areas.

Our engineers and project managers have been working with facilities since the Hazardous and Solid Waste Amendments of 1984, so we have worked through several RCRA requests and have experiences related to nearly any request that the EPA may issue to the facility.

New facilities wishing to conduct solid waste operations must submit the appropriate permit or registration application and receive approval from the Agency before beginning construction and operation of the facility. We are experienced with permitting new facilities and modifying existing, including changes to design, operation, monitoring, and maintenance activities.

Depending upon the type of waste and how it is to be reused, the facility may need a registration approval or a processing facility permit from the Agency. Our engineers are knowledgeable of solid waste facilities and the rules to make an accurate assessment of the processing and waste activities to file for the appropriate approvals.

If the facility if shipping hazardous waste for reuse or recycling, RCRA requires due diligence from the generator, including maintaining records identifying the vendor and how they are recycling or reusing the hazardous waste. Or, a facility may be concerned how non-hazardous waste is being handled and would like the value stream to be audited. In either case our engineers and environmental professionals can conduct the proper evaluations and make a determination if the recycling and reuse practices are legitimate.

Solid Waste facilities must implement a Facility Operations Plan to document work practices and describe contingencies to prevent and control releases or other emergency situations. Our staff of environmental professionals are experienced with developing these Plans and are available to prepare, implement and train staff on the Plan.

BCA will identify and categorize each waste stream at the point of generation and develop a waste inventory. The inventory identifies the Category of each waste stream and how they must be handled, managed and shipped in accordance with applicable local, state and federal EPA, DOT and OSHA requirements.

We are not a law firm, nor do we partner with any law firms. We may provide suggestions, but our role in litigation is to help the facility locate records, provide technical data, assess rules, applicability, and compliance and assist in preparing response submittals to the Agency. Overall our role is to be the liaison between the facility, Agency and legal counsel. .

Other relevant waste related services include Solid Waste Transfer Station Permits, Marketing and Distribution Permits, Landfill Operator, Waste Removal Coordination, and Recycling Coordination.