Environmental Consulting Company Texas
Texas Commission on Environmental Quality issued environmental fines against 51 Texas companies and entities last week.
We are a Texas environmental consulting company and receive these notifications weekly, and trust me, this is a low total. Normally total environmental fines are double this amount, and the # of entities and companies fined is much higher. Many of these companies are small Texas manufacturers, who are very vulnerable due to a common lack of internal expertise and resources needed to manage environmental compliance requirements.
In our experience, the most common environmental compliance violations in Texas involve the following regulations:
- Stormwater Permits: Storm water permit regulations are triggered by SIC codes, and virtually all manufacturers SIC codes trigger, yet a vast majority of small Texas manufacturers are unaware of the regulation. The biggest regulatory requirement is development and managing a Stormwater Pollution Prevention Plan (SWPPP). Requirements include drafting a SWPPP, training employees, regular inspections, stormwater testing, etc.
- Hazardous Waste Management: The most common violations include failure to properly label hazardous waste containers, and failure to complete waste determinations for all industrial waste streams generated at a facility.
- Air Permitting; The vast majority of Texas manufacturers and unaware of TCEQ’s air permitting regulations. The most common violations involve failure to claim Permit by Rules, or PBR’s. TCEQ has approximately 300 PBRs which address virtually all common air emissions from manufacturing. These aren’t actual air permits, but companies must determine which PBRs apply to their operations, and then claim the appropriate Permit by Rule. Most are very simple, but many require extensive emission tracking requirements. The most common such PBR is for Surface Coatings and Painting. Companies who exceed PBR emissions may have to apply for a New Source Review Air Permit, or NSR. This is a complicated and costly air permit that can take up to 2 years to obtain.
- Hazardous Materials Reporting: The most common violations include failure to submit TRI and Tier II annually. These hazardous materials reporting requirements trigger when companies exceed storage and/or usage of certain hazardous materials.
Failure to manage these environmental regulations is very common, especially for small manufacturers, but can result in major environmental fines and penalties.
We are a Teas environmental consulting company and specialize in helping small manufacturers understand, manage and achieve environmental compliance. Our common approach includes a recommendation for clients to participate in TCEQ’s Environmental, Health and Safety Audit Privilege Act. This incentive program provides companies full immunity from environmental fines and penalties if they do 3 things:
- Provide notice of intent to conduct an environmental audit, including dates and locations.
- Provide a notice of violations, specifying all environmental compliance violations.
- Follow through with all needed corrective actions within a “reasonable amount of time” which normally means within 90 days. Extensions can be granted for valid reasons.
We’ve helped many small companies through this environmental audit process, as well as assisting with all environmental compliance corrective actions identified during the audit.
Texas companies who complete this environmental audit process will achieve environmental compliance, and thus protect themselves from potentially devastating environmental fines and penalties, as well as protect their local communities from potential damage and contamination.
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