REGULATORY COMPLIANCE

IRWIN Engineers, Inc. provides emergency and contingency planning services ranging from plans specific to one program area to Integrated Contingency Plans following guidance of the National Response Team. We created a Model Integrated Contingency Plan for the Massachusetts State Office of Technical Assistance. Integrated plans provide a single reference source for emergency response personnel and contain a Core Plan within the document which can be submitted to regulatory authorities.

We are familiar with the real world aspects of manufacturing activities that must be addressed in the plans and will conduct on-site reviews to identify and evaluate key points in the operation. We have the Professional Engineering Registration necessary to assess Good Engineering Practice and certify plans as required by the regulations.

For clients subject to multiple regulatory requirements, having an Integrated Plan eliminates having several different plans which often overlap and duplicate material with the risk of contradicting each other. For example, these comprehensive plans can include Stormwater Pollution Prevention Plans, Spill Prevention Control & Countermeasures Plans, Hazardous Waste Contingency Plans under RCRA, Solvent Control/Slug Prevention Plans Emergency Action Plans (OSHA), and Toxics Organics Management Plans all in one document.

IRWIN works with you to tailor your plans to your facility and operating practices. Even if you have existing plans, integrating all your plans saves money by minimizing plan updating chores and by consolidating training.

IRWIN helps you to:

• Determine if you are subject to regulation -toxics, flammables and explosives are regulated;
• Create a Hazard Assessment Program - identify & analyze accidental release scenarios;
• Construct a Prevention Program - operating procedures, process safety information etc.;
• Design an Emergency Response Program - for mitigating accidental releases;
• Implement an overall Risk Management System.

Even facilities that have regulated substances below the RMP threshold are now required to abide by the General Duty Clause of the Clean Air Act, Section 112(r).

Whether it's compliance with the ISO 14000 Standard or a simpler EMS, Irwin Engineers can tailor our scope of work to your needs. EMS Implementation can help your company:

• Enhance its image & market position;
• Save money by increasing resource efficiency;
• Save money by minimizing fines & penalties;
• Achieve a level beyond compliance.

Our staff includes a Registrar Accreditation Board (RAB) Certified Environmental Auditor. We can help put together the pieces of an EMS or improve on the ones you may already have. As an example, various risk preparedness plans such as Spill Prevention, Control and Countermeasures Plans, Stormwater Pollution Prevention Plans, and Hazardous Waste Contingency Plans can be brought together within an Integrated Contingency Plan. Training, document control, operational controls, and identification of legal compliance requirements are addressed as needed. With our chemical engineering focus, we can also evaluate ways in which a facility may be able to engage in Pollution Prevention & Toxic Use Reduction.

All facilities covered by the Multi-Sector Permit issued by the EPA pursuant to the Clean Water Act must have a SWP3. For plan development IRWIN identifies and locates outfall points, identifies non-storm discharges for elimination, and reviews past spill events. We then develop facility specific Best Management Practices (BMPs). BMPs may involve physical plant facilities or procedures to achieve pollution prevention. The criteria to determine whether your facility requires a SWP3 include: the operational SIC code, and the existence of a conveyance for stormwater, and whether there is actual exposure of stormwater to pollutants. Irwin Engineers can also provide sampling of discharges.

The Multi-Sector permit covers 29 industrial categories. Each state also has its own stormwater permit requirements. Massachusetts is a non-delegated state under the Clean Water act and does not have the authority to issue NPDES permits. EPA Region I issues the permits in Massachusetts; however, the state does review the permit for certification with state water quality standards. Connecticut and Rhode Island, by contrast, have their own General Permits.

RCRA

Waste determination and waste minimization can be first steps to RCRA compliance.

Hazardous Waste Contingency Plans are required by federal and state regulations for large quantity generators. We assist our clients in preparing these plans and establishing procedures for the prevention of hazardous waste releases to the environment and responding appropriately in such an event.

Some of the elements of these plans are: a detailed description of hazardous waste storage facilities with particular emphasis on loading/off-loading areas; a detailed protocol for notifying regulatory agencies and other responders; and storage practices designed to prevent accidents.

When a release occurs, rapid response is required. Consolidating all response procedures into one plan streamlines the entire process and helps prevent confusion. This can be accomplished with the creation of a single overall plan for the facility (Integrated Contingency Plan). With one set of instructions to follow, personnel do not need to decide which plan applies and the possibility of conflicts between different plans and instructions is minimized.

EPCRA - TIER II FILING

The Emergency Planning & Community Right To Know Act (EPCRA), also known as Title III of SARA (the Superfund Amendments and Re-Authorization Act), requires facilities with inventories of hazardous substances that exceed a 10,000 pound threshold or extremely hazardous substances that exceed a 500 pound threshold to participate in the emergency planning and notification process.

IRWIN can perform a facility inspection to:

• determine if a facility triggers EPCRA reporting requirements;
• develop an inventory of the hazardous and extremely hazardous substances on site;
• compile the required physical and chemical data about the substances; and
• prepare the reports (Tier I and Tier II forms) and the facility map need for the submittal.

Flammables and combustibles are usually subject to additional fire code compliance requirements. We are qualified to evaluate compliance with state and local regulations and National Fire Protection Association (NFPA) codes.

IRWIN provides in-plant environmental compliance support, such as:

If you do not have the need for full time environmental personnel, our professional staff is available to go to your facility when needed and cost effectively augment your other resources.

Waste Management

IRWIN can help you manage your waste disposal activities. We can assist you with:

• profiling your waste streams;
• evaluating your waste disposal options;
• scheduling your waste disposal pickups;
• preparing and tracking your manifests;
• preparing your bi-annual reports; and
• establishing an efficient records management program.

We can perform other facility inspections to assess whether wastes are being properly stored and handled, that the required information is being collected for your records management program and that the information is retrievable. We can also prepare waste management procedures for you and train your staff. IRWIN can help you to cure your hazardous waste headaches cost effectively.

Records Management

IRWIN works with plant and office personnel on systems for routine tracking of material use and inventory as necessary to demonstrate compliance. We also complete regulatory filings.

Permit Report Preparation

IRWIN can help you to prepare your water discharge and air emission permit submittals, for example. We can assist you to establish monitoring, record keeping and reporting systems that allow you to cost effectively meet your regulatory obligations. We can perform hazardous waste, wastewater, stormwater, potable water, and groundwater sampling services. IRWIN has established relationships with certified laboratories for analysis of samples.

Sampling

IRWIN staff are trained in proper sampling techniques and can advise clients on appropriate test methods and quality control factors. We also have equipment for screening evaluations.

Treatability Testing

IRWIN has the resources to conduct treatability studies to evaluate alternative systems for water or wastewater treatment to either improve existing systems or to evaluate methods for handling new waste or processes.

Startup Services

The IRWIN team can provide a variety of pollution control system startup services. These include pressure testing, flushing, controls integration and trimming and equipment acceptance testing. We also help you develop operating procedures, train your operating staff and help optimize your operations.