Environmental Featured Project
Project Name: Environmental Permitting: Site Assessment through Operation & Expansion
Providence coordinated and conducted all environmental activities required for initial construction and operation of a $2 billion chemical manufacturing facility in Iberville Parish, Louisiana. Since initial facility permitting, Providence has continued to coordinate all environmental activities for ongoing compliance, facility expansions, and new facility additions. With the most recent new facility permitting, Providence conducted the first inter-precursor trading (IPT) modeling, and only IPT modeling completed to date, in Louisiana involving a high-level of interaction and coordination with the state regulators.
Providence’s responsibilities included:
- Phase I & II Environmental Due Diligence Site Assessments
- Multimedia permitting for air quality: Clean Air Act (CAA) Part 70, Title V, PSD, Nonattainment New Source Review
- Water quality assessments and Louisiana Pollution Elimination System (LPDES) industrial wastewater & construction stormwater permits
- RCRA Subtitle C “Part B” hazardous waste management permits
- State of Louisiana “public trust doctrine” Environmental Assessment Statement
- State of Louisiana environmental risk assessment (“RECAP”)
- State of Louisiana groundwater protection certification
- Federal Clean Water Act wetlands delineation and Section 404 USACE permitting and mitigation planning
- Federal threatened and endangered species protectiveness reviews
- Spill prevention control and countermeasure (SPCC) plan
- Stormwater pollution prevention plans (SWPPPs) for construction and operational phases
- CAA chemical accidental release/risk management plan (RMP)
- RCRA hazardous waste management plan
- Coordination of National Historic Preservation Act (NHPA) Section 106 Cultural Resources Phase I, II, and III assessments, surveys, and archeological data recovery
- Technical assistance and coordination of public meetings, public hearings, and community outreach
Some key successes during the project have included avoiding permitting obstacles presented by 316B, obtaining emissions reduction credits, and obtaining Section 10/404 wetlands permit despite culture resource issues.
In addition to initial facility permitting, Providence designed, prepared, and implemented an Environmental Compliance Program for Shintech to ensure compliance with all applicable environmental permits and regulations. Upon reviewing all applicable environmental permits, laws, and regulations, Providence prepared an environmental manager compliance manual, various operator compliance manuals, an emergency and unauthorized notification/reporting manual, facility startup checklist, regulatory compliance tables, an environmental regulatory compliance calendar, and a full environmental compliance training program with training sessions to increase overall plant awareness of environmental requirements and responsibilities.