Permitting and Compliance

The Clean Water Act (CWA) is the primary federal law governing water pollution. Under the CWA, facilities face specific requirements for managing discharges and activities that could impact water quality, including those related to wastewater, stormwater, and wetlands.

Trihydro assists clients across diverse sectors in meeting their CWA compliance and permitting obligations. A key component of this support involves navigating the National Pollutant Discharge Elimination System (NPDES), which regulates the discharge of pollutants into US waters. We offer a range of NPDES services:

• NPDES permit application preparation (e.g., individual permits, multi-sector general permits, construction permits, municipal separate storm sewer system permits, etc.)
• Permit renewals or modifications
• Stormwater Pollution Prevention Plan (SWPPP) development
• Stormwater Best Management Practices recommendations
• SWPPP inspections, sampling, training, and annual reporting
• Wastewater stream characterization
• Treatment options evaluation
• Monitoring and reporting strategy development
• Discharge Monitoring Report preparation

Beyond NPDES, Trihydro also assists with other critical CWA requirements. This includes Section 404/401 certifications for activities involving the discharge of dredge and fill materials.

The Clean Water Act (CWA) mandates robust Oil Pollution Prevention (OPP) measures for facilities that store oil in various containers, including aboveground storage tanks (AST), underground storage tanks (UST), processing tanks, oil-filled electrical equipment, and portable or mobile tanks. Our OPP services include the following:

• Spill Prevention, Control, and Countermeasure Plan (SPCC) development, revision, and technical amendment
• Facility Response Plan (FRP) development and revision, including evaluation of applicability for facilities storing hazardous substances
• Emergency Response Action Plan development and revision
• Discharge scenario evaluation (i.e., worst-case oil discharge response planning)
• AST and UST permitting
• SPCC and FRP training
• SPCC inspections

Effectively managing solid and hazardous waste is critical across various industries, requiring adherence to stringent federal, state, and local regulations. The Resource Conservation and Recovery Act (RCRA) serves as the cornerstone of hazardous waste management in the US, dictating requirements from generation and transportation to treatment, storage, and disposal. Trihydro supports the proper management of hazardous waste under RCRA and associated state and local regulations. We guide clients through these complexities with the following services:

• New and renewal RCRA permitting
• Hazardous waste management plan development
• RCRA biennial report preparation and state reporting
• Contingency Plan development
• Waste identification support and evaluation
• Generator status determination
• Specific waste regulations evaluation, compliance, and permitting (e.g., universal waste and used oil)
• Personnel training
• Ongoing compliance support for storage, labeling, manifesting, and disposal
• Closure and post-closure
• Corrective action

The Toxic Substances Control Act (TSCA) regulates chemical substances throughout their lifecycle in the US. This includes substances such as per- and polyfluoroalkyl substances (PFAS), polychlorinated biphenyls, asbestos, radon, and lead-based paint.

Trihydro helps clients meet federal and state requirements under TSCA. We provide permitting guidance to align manufacturing, processing, distribution, and disposal activities with TSCA requirements. We also offer compliance support services, helping clients interpret regulations, develop management programs, and implement practices to reduce compliance risk. Our TSCA services include the following:

• Permitting assistance for new and existing chemical substances
• Compliance support services
• Chemical data reporting
• New chemical reviews
• Assistance with pre-manufacture notice process for substances not on the TSCA Inventory
• Addressing significant new use rules

Trihydro offers non-hazardous solid waste services, including permitting and managing various facilities such as landfills, transfer stations, and composting operations per state and federal regulations. Additionally, Trihydro assists clients with Underground Injection Control (UIC) permitting and compliance. This includes supporting clients with Class I wells used for hazardous and non-hazardous waste disposal, Class II wells for oil and gas-related waste, and Class V wells that manage a range of non-hazardous industrial and commercial wastes. Our solid waste management and permitting services include the following:

• Preparing non-hazardous and industrial solid waste permit applications (includes developing plans for facility design, operation, closure, and post-closure care)
• Developing solid waste management plans focused on waste reduction, reuse, and recycling
• UIC permitting and compliance (e.g., applications for new wells, modifications and renewals for existing operations)

Facilities storing hazardous chemicals have important environmental reporting duties under the Emergency Planning and Community Right-to-Know Act (EPCRA). This law requires routine reporting of chemical inventories and releases to various authorities, including state or Tribal Emergency Response Commissions and Local or Tribal Emergency Planning Committees. Trihydro specializes in preparing reports to help facilities meet their EPCRA obligations. Our EPCRA services include the following:

• Section 311 Tier I reporting
• Section 312 Tier II reporting
• Section 313 Form R, Toxic Release Inventory (TRI) reporting
• Safety Data Sheet (SDS) evaluation for Section 311 and 312 applicability

Trihydro combines the expertise of environmental planners, biologists, ecologists, and environmental permitting specialists to help our clients navigate environmental review, natural resource management, and regulatory compliance and permitting. We support the review process from project scoping and stakeholder engagement to technical impact analysis and public comment response. Our environmental and planning services include the following:

• Threatened and endangered species surveys
• Migratory bird assessments
• Biological assessments
• Section 404/401 permit applications
• Cultural resource consultation materials
• Drought impacts and water supply studies
• Post-fire response and watershed recovery
• Invasive species and tree disease management
• Wildland-urban interface land use planning
• Overall watershed and ecosystem health degradation management

US environmental regulations require periodic audits and assessments to evaluate facility compliance. To support this process, Trihydro conducts multimedia audits covering air quality, water quality, waste management, chemical storage, and other relevant areas. This typically involves reviewing records, interviewing personnel, inspecting facility operations, and providing a report of findings and recommendations for corrective action. Additionally, Trihydro assesses potential environmental liabilities and compliance issues to support environmental due diligence efforts, which are often part of real estate transactions or corporate acquisitions. Our environmental compliance auditing, assessment, and program development services include the following:

• Conducting multimedia audits
• Designing multimedia due diligence audit assessments in tandem with Phase I Environmental Site Assessments
• Developing plans, procedures, and tracking mechanisms to manage ongoing environmental compliance
• Hazardous waste management, stormwater pollution prevention, SPCC requirements, and general environmental awareness training