Regulatory Compliance Projects
SPCC Plans Oil & Gas production Facilities - Louisiana, Texas, Oklahoma, Kansas, and North Dakota
Blackshare prepared Spill Prevention, Countermeasure and Control (SPCC) Plans for over 400 oil and gas production facilities. Blackshare conducted site visits to document and photograph oil storage, facility layout, area topography, and secondary containment for all sites. Following the site visits, SPCC plans and site diagrams were prepared to conform with the amended SPCC regulations.
RCRA NOV Response - Aerospace Maintenance Facility
A large aerospace maintenance facility received a Notice of Violation (NOV) for RCRA compliance issues. These consisted of inadequate generator status determination, absence of contingency and disposal plans, failure to file quarterly reports, inadequate emergency preparedness, improper satellite collection of hazardous waste, inadequate profiling of land ban wastes, storage area inspection deficiencies and inadequate training of employees that handle hazardous waste. Blackshare developed programs, conducted training and established procedures to address all of the non-compliance issues. As a result of the work and fast track implementation schedule provided by Blackshare, the NOV was closed out with no fines.
Waste Management Audit - Storage Terminals Midwest & Eastern US
Blackshare was retained to evaluate waste handling, profiling, and disposal practices for more than 60 pipeline terminals throughout the Midwest and southeastern U.S. Site visits were conducted at several terminals and questionnaires developed and sent to all. After the results were evaluated, revised procedures were developed and distributed to assist with compliance. Blackshare also assisted with implementation of the new waste handling procedures and vendor choices by conducting training on the new procedures and developing user-friendly manuals specific to each facilities’ site-specific waste streams. Contingency plans were also developed for each terminal that was classified as a Large Quantity Generator.
Surface Impoundment Design and Permitting - Chemical Plant
Blackshare assisted a facility with violations related to stormwater runoff. Regulators required that the facility install a means to capture and possibly treat stormwater, if necessary, to reduce pollutant loading. Blackshare evaluated various locations for a flow-through surface impoundment, designed the impoundment along with construction estimates to prepare a bid package for contractors, and obtained necessary permits to construct the impoundment and resulting discharge. Factors such as lifting requirements, amount of cut/fill, ease of maintenance, space usage, and other factors were considered to choose the final location of the impoundment.
Mining Permits - Multiple Locations
Blackshare has several clients in the mining, aggregate, and asphalt businesses. As these clients move operations to new locations, Blackshare obtains all necessary permits including mining permits, sand and gravel permits, air permits, SPCC plans, and other compliance requirements. This normally involves extensive research and documentation of data such as geology, groundwater, water wells, surrounding population, noise, access roads/traffic, bridge limits, and reserve estimates. Normally, a reclamation plan is required and Blackshare has developed numerous such plans for our clients.
Retained Environmental Consultant
Blackshare serves as ad-hoc environmental staff for numerous facilities – essentially functioning as a part-time extension of existing plant personnel. Blackshare often has specific compliance tracking and reporting responsibilities such as completion of air emissions inventories (AEIs), greenhouse gas (GHG) reporting, Emergency and Hazardous Chemical Inventory (Tier Two), Toxic Release Inventory (Form R), CERCLA releases and follow-up reports, excess emissions, RCRA bi-annual reports, TSCA Form U, periodic visible emissions (opacity) readings, effluent sample collection, analysis, and reporting, and other requirements.
Comprehensive Environmental Audit - Manufacturing Facility
Blackshare conducted a compliance audit of a manufacturing plant that was cited by a regulatory agency. The purpose of the audit was to evaluate and identify non-compliance issues, resolve them, and turn in all results to the agencies to avoid enforcement. The audit was viewed as proactive by regulators and eliminated further enforcement and penalties/fines. The audit evaluated compliance with all media’s – air, water, and waste – and judges permits, procedures, practices, reporting, etc. Blackshare then assisted with implementing recommendations from the audit including applying for permits, training, writing plans and procedures, and preparing historical reporting requirements.
Title V Air Permit Application - Hydrogen Sulfide Gas Well
Blackshare's client drilled a natural gas well that also produced hydrogen sulfide gas. Because of the high toxicity hazards from hydrogen sulfide, it was necessary to treat the gas stream with an ammonia unit. The ammonia unit is designed to remove hydrogen sulfide from the natural gas. The emissions resulting from the ammonia unit were calculated to be over 100 tons/year, which necessitated the preparation of a Title V air permit. Blackshare performed all calculations and prepared all permit tasks to permit the ammonia unit.
Stormwater Compliance - Large & Medium Size Airport Facilities
For more than six years Blackshare has been the environmental consultant for two (2) main airports located in a metro area. Among other environmental services, Blackshare has performed all tasks related to compliance with the stormwater regulations for both facilities. The tasks have included development of the stormwater pollution prevention plan (SWPPP), conducting monthly inspections of all airport and tenant areas, completing the annual report, collecting quarterly samples, preparing for and conducting semi-annual pollution preservation team meeting to evaluate plan and build effectiveness.
Water Use Permits - Six Facilities
A natural gas transmission and processing company required the commercial use of groundwater at six of their field sites. The commercial use of groundwater requires approval from the state regulatory agency. Blackshare accumulated all of the necessary data and prepared detailed permit applications. After the applications were submitted and approved, Blackshare performed title research of surrounding properties and sent notices of the permit application to all adjoining landowners. No protests were filed by adjoining landowners during the notification period, and all six applications were approved.