Environmental consulting
that gets into the details.

Air Compliance, Emissions Tracking & Reporting

Ongoing air compliance support for industrial facilities, including emissions calculations and tracking, permit condition evaluations, regulatory recordkeeping, annual emissions inventories, and periodic reporting required under Title V permits, MACT/NESHAP standards, and other applicable requirements. Air permitting assistance is also available for projects within Holdfast’s technical capabilities.

• Air permit and Title V condition tracking and emissions recordkeeping
• MACT/NESHAP and NSPS emissions calculations, tracking, and regulatory documentation
• Periodic permit-required and MACT/NESHAP compliance reports
• Annual air emissions inventories and related data compilation
• Regulatory applicability reviews and compliance evaluations
• Selected air permit applications, renewals, and modifications

Selected air permitting projects are evaluated individually based on scope and technical requirements.

EPCRA Tier II & TRI Reporting

Comprehensive support for EPCRA Tier II and Toxic Release Inventory (TRI) reporting, including applicability evaluations, chemical inventory assessments, threshold determinations, release and transfer calculations, report preparation, and electronic submission support.

• EPCRA Section 312 Tier II chemical inventory reporting
• EPCRA Section 313 Toxic Release Inventory (TRI) reporting
• Threshold determinations and applicability evaluations
• Chemical inventories and materials-use data compilation
• Release, transfer, and waste-management quantity calculations as relevant to TRI
• Report preparation, technical review, and electronic submission support

Field Inspections & LDAR

On-site field services focused on thorough observations, accurate documentation, and actionable findings.

• EPA Method 21 leak detection and repair (LDAR) inspections
• SPCC facility inspections and follow-up documentation
• Industrial stormwater and SWPPP inspections
• Inspection record development and deficiency tracking
• Practical corrective action recommendations and follow-up support
• Facility-specific field assignments based on applicable requirements

Compliance Plans & Written Programs

Development, evaluation, and revision of facility-specific environmental compliance plans, written programs, and implementation procedures. Services include SPCC, SWPPP/SWBMP, LDAR, NESHAP/MACT, and other regulatory compliance plans, as well as selected safety written programs. Additional plans and programs are considered based on applicable requirements, project scope, and technical qualifications.

• SPCC plans, evaluations, and revisions
• SWPPP and SWBMP plans and related industrial stormwater procedures
• LDAR plans, procedures, and implementation documents
• NESHAP/MACT compliance plans, work practice plans, and implementation procedures
• Facility-specific BMP plans and other regulatory written programs
• Selected municipal compliance plans and safety written programs

Compliance Audits & Gap Assessments

Comprehensive or program-specific environmental compliance assessments designed to identify regulatory requirements, evaluate existing compliance practices, document deficiencies, and develop practical corrective action recommendations. Assessments can address individual environmental programs or multiple regulatory areas across a facility.

• Multi-media environmental compliance audits and gap assessments
• Regulatory applicability determinations and permit-condition reviews
• Program assessments, recordkeeping reviews, and tracking evaluations
• Corrective action plans and prioritized compliance recommendations
• Follow-up assessments and implementation assistance
• Ongoing technical support to facility environmental teams

Waste & Materials Compliance

Compliance support for hazardous waste, universal waste, used oil, and related waste management requirements for very small quantity generators (VSQGs), small quantity generators (SQGs), and large quantity generators (LQGs).

• Generator status evaluations and regulatory applicability determinations
• Accumulation area inspections; container labeling, marking, and management reviews
• Recordkeeping evaluations and state-specific waste regulatory assessments
• RCRA Site Identification notifications (EPA Form 8700-12)
• Applicable annual and biennial hazardous waste reporting, including EPA Form 8700-13
• Solid waste certifications
• Waste characterization, including sampling and waste determinations
• Hazardous waste manifesting support
• Corrective action assistance
• Universal waste and used oil management requirements