HETI's staff continually reviews new and proposed regulations to make sure that we have current knowledge of compliance and environmental issues. We excel at researching and interpreting complex environmental regulations in support of our government, commercial and industrial clients…and have extensive experience working with State and Federal regulatory agencies. HETI personnel are adept at gathering and interpreting information efficiently… and helping to ensure that our client is in compliance from all sides.

HETI's comprehensive regulatory support services include:

	Air permits
	Air dispersion modeling
	Storm Water Pollution Prevention Plans (SWPPPs)
	Spill Prevention Control and Countermeasure (SPCC) Plans
	OPA 90 Facility Response Plans
	Hazardous waste permits for Federal and State regulations (such as California's Tiered Permitting Program for hazardous waste treatment)
	Health Risk Assessments for hazardous waste permits, as well as site closures
	Risk Management Prevention Programs (RMPPs) equivalent to the same Federal Risk Management Plans required under Section 112r of the Clean Air Act
	OSHA Process Safety Management (PSM) Programs
	Compliance Audits (multimedia audit coverage: air, water, and waste)
	Environmental Compliance Manuals (air, water, and/or waste)
	Hazardous Material Management Plans (HMMPs) and Business Plans
	Emergency Response Plans
	Hazardous Waste Contingency Plans
	Closure for units or facilities that handle hazardous wastes and materials
	Tank and secondary containment area Professional Engineer certifications
	Training for storm water, spill plans, and Hazard Communication
	Reimbursement assistance from State cleanup funds
	Ground and surface water discharge permits (i.e., NPDES)
	Site construction permits
	Wetlands permits
	Waste/soil removal permits
	Tank removal and dewatering compliance monitoring

Representative Projects *

NPDES Permitting (Massachusetts) – HETI negotiated with USEPA Region 1 to successfully obtain a NPDES permit on behalf of a railroad for the continued discharge of treated wastewater and stormwater from a rail yard located along a stream that flows to the Connecticut River. The permit was initially appealed by a citizens’ action group.

Multimedia Compliance Audits, Spill Prevention Control & Countermeasure Plans, and Storm Water Pollution Plans (Multi-State) - HETI has completed multimedia compliance audits, Spill Prevention Control & Countermeasure (SPCC) Plans, and Storm Water Pollution Prevention Plans (SWPPPs) for over 100 petroleum bulk plants located in Alaska, Arizona, California, Hawaii, Nevada, Oregon, and Washington.

Hazardous Materials Management, Chemical Manufacturer (Illinois) - HETI was retained by an international pigment manufacturer - in the process of developing a new product and new product packaging - to provide guidance to their customers on environmental issues associated with the disposal of the new packaging and container residues. After reviewing Federal, California, and Illinois regulations and guidance documents associated with contaminated inner container liners, HETI summarized disposal and other regulatory requirements (waste characterization, the definition of empty containers, the prohibition of liquids in landfills, and State "special waste") to the client. HETI also provided guidance on other environmental issues faced by the client's customers (increased off-site disposal liability, increased disposal costs, impact to customers' waste minimization programs, etc.)…along with ideas for alternative packaging management, including recycling and waste minimization. As a result of HETI's efforts and recommendation, the pigment manufacturer will be able to provide analytical data and regulatory guidance to their customers for the new product/packaging…resulting in a time and cost savings to their customers.

Wetlands Permitting, Remediation Project (Massachusetts) - A remedial response for a subsurface release of gasoline required extensive construction, excavation, and filling of a small wetland. Wetland boundaries were delineated using both Massachusetts (310 CMR 10.00) and Federal (Section 404) criteria. Based on the Federal delineation, it was determined that the proposed work did not require a filing due to an exemption under a Nationwide Permit. A request for Determination of Applicability was filed with the local Conservation Commission and a public hearing was attended. A Negative Determination was granted.

Risk Management Prevention Program & Process Safety Management Plan (California) - HETI completed a Risk Management Prevention Program (RMPP) for a facility that handles acutely/extremely hazardous substances. The project included performing a HAZOP study to identify the hazards associated with the storage, handling, and processing of the acutely hazardous materials. Worst-case and most-likely scenarios were developed and air dispersion modeling was used to identify the zone of influence for an emergency situation at the facility. The project findings were documented in the RMPP; and the RMPP results were incorporated into an OSHA Process Safety Management (PSM) Program for the facility that identified the hazards to employees on-site and procedures for mitigating them. The PSM also included a number of procedures to ensure employees participate in safety/hazard assessment of the acutely hazardous material operations and any changes to the procedures.

* This is a brief description of selected Regulatory Support assignments completed by HETI. For a more complete discussion of our capabilities, please contact us for a copy of our Statement of Qualifications.