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Compliance Assessment

Huff & Huff, Inc. (H&H) follows the environmental regulations closely and keeps clients alerted whenever a new regulation is adopted. The impact of these regulations is also assessed specifically for some firms. H&H provided a detailed analysis of the Community Right-To-Know and many hazardous waste regulatory changes, and the storm water regulations for numerous companies with plants throughout the U.S. These analyses included recommended sampling, inventory, and reporting (Tier 1 and Form R) necessary to comply with the regulations.

Environmental permits, such as air permits, have routinely been prepared by H&H. Development of permit documentation and emission levels have been completed for a variety of sources, including new chemical plants, paint lines, baking ovens, and vapor degreasers.

Baseline Monitoring Reports (BMRs) and compliance reports are required for categorical sources discharging to municipalities. H&H has prepared or provided review of BMRs for facilities in the following industries: pharmaceutical, casting, printed circuit board, metal finishing, organic chemicals, and foundry. Methods of achieving compliance, including design of pretreatment facilities, have been addressed for these facilities.

Storm water permit requirements have been evaluated for both industrial and commercial facilities. H&H has then prepared storm water pollution prevention plans for industrial, commercial, and construction facilities in Illinois, Indiana, Texas, Louisiana, and California. The impact of the 1-acre construction permit requirement on the gas utility industry was presented at the 2003 AGA Conference by James Huff.

H&H has assisted legal counsel in preparing permit appeals and variances, and provided the necessary technical support for the hearings. An NPDES permit appeal, including extensive technical and economic documentation for a brine solution mine in New York, was prepared. NPDES permit appeals have been evaluated for municipal limitations as well, including ammonia effluent limits and mixing zone applicability.

Disinfection exemption petitions, mixing zone determinations, ZID delineation, biomonitoring plans, and antidegradation analyses are all aspects of NPDES permits which H&H has performed. The firm has extensive computer modeling capabilities on mixing zones and water quality modeling which have proven beneficial in many projects. Utilizing CORMIX, NPDES permit limits have also been developed for an industrial dischargers on both the Mississippi River and the Illinois River.


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