Facility Environmental Permits and Reports

For many facilities, federal or state environmental permits constitute the controlling guidance for environmental compliance programs and activities. These permits include more than limits on emissions and discharges; they often require operational and management actions, preventative actions, implementation of facility-level plans, internal monitoring, employee training, agency reporting, a variety of actions that must be taken under certain conditions, and other requirements. Environmental managers must understand all provisions of their plans and develop strategies to simplify and streamline compliance management. Compliance evaluations should include a careful analysis of all permit conditions and requirements. When facility conditions change or plans expire, new or modified permits must be obtained, and effectively navigating the permit application process can drastically reduce permit issuance timelines and result in more manageable permit requirements.

Most environmental permits require routine reporting to the permitting authority, such as monitoring reports, annual summaries, facility modifications, and other permit implementation information. Submitting these reports on schedule is required, and a facility representative is normally required to attest to the accuracy of the information presented.

Some regulations require reporting directly, not defined by permit conditions. For example, facilities may be required to submit biennial reports for large quantity generators of hazardous waste (and sometime small quantity generators) or EPCRA Tier I/II and Toxic Release Inventory (TRI) reports, without the need for an associated facility permit.