Industrial Compliance

Condor provides assistance in developing many compliance programs for local, state and federal environmental and hazardous materials regulations.

  • Spill Prevention, Control, and Countermeasure (SPCC)
  • Steel Tank Institute (STI) SP001 Formal Inspections
  • California Accidental Release Prevention Program (CalARP), Risk Management Program (RMP) and Process Safety Management (PSM)
  • Hazardous Materials Management
  • Hazardous Waste Management
  • Hazardous Waste Tank Assessments
  • Toxic Release Inventory (TRI)
  • Industrial General Permit (IGP)

The SPCC rule applies to owners or operators of facilities that store, use, process, refine, transfer, distribute, or consumes oil and oil products. SPCC Plans are required for most facilities with an aggregate aboveground storage capacity of 1,320 gallons. The goal is to prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil with secondary containment, equipment and procedures. Condor’s engineering staff, including Registered Professional Engineers, can help you prepare a self-certified SPCC Plan or develop an engineered SPCC plan to meet the SPCC requirements. 

STI SP001 Formal Tank Inspections

STI SP001 is the commonly used inspection standard to meet the Spill Prevention, Control, and Countermeasure (SPCC) rule integrity inspection requirements for shop-built and certain field-erected oil storage tanks. The SPCC regulation requires facilities to ensure that tanks are properly designed, maintained, and inspected to prevent oil discharges to navigable waters or adjoining shorelines. For SPCC-regulated containers and tanks with capacity 5,000 gallons or less, STI SP001 allows facility personnel to conduct monthly and annual inspections. For tanks 5,001 gallons or greater, the formal external inspection interval is typically 20 years. Condor integrates STI SP001 inspection requirements into SPCC plans and our team of certified inspectors conduct formal external inspections. 

California Accidental Release Prevention (CalARP) Program, Risk Management Program (RMP) and Process Safety Management (PSM)

Condor assists with the development and implementation of California Accidental Release Prevention (CalARP) Program, Risk Management Program (RMP) and/or Process Safety Management (PSM). With more than three decades of industrial compliance experience, Condor is your go-to source for regulatory program support. CalARP/RMP/PSM programs require ongoing compliance efforts. Condor helps manage and maintain compliance of your regulated processes. Condor’s services include: 

  • CalARP/RMP/PSM program management and implementation assistance
  • Risk management Plan (RMP) updates (due every 5 years or when major changes occur)
  • Process Hazard Analysis (PHA) or Hazard Review updates (due every 5 years or when major changes occur)
  • Compliance Audit (due at least every 3 years)
  • IIAR 6 Mechanical Integrity Audits and program development
  • Operating Procedures
  • Process Safety Information development
  • IIAR 9 Minimum System Safety Evaluations
  • Relief design evaluations
  • Ventilation design evaluations
  • Training
  • Emergency Response Training FRO, Industry Technician and Incident Command
  • Management of Change (MOC) and Pre-Startup Safety Review (PSSR) assistance
  • Off-Site Consequence Analysis (due every 5 years under CalARP)
  • Contractor qualification and safety reviews
  • Incident Investigations
  • Preparing for inspections and responding to regulatory agencies
  • Documenting CalARP/RMP/PSM exemptions and applicability
  • Coordinating emergency response actions and 
  • Providing guidance and periodic compliance assessments 

Hazardous Materials Management

Condor Supports clients to maintain compliance-from conducting PE-certified hazardous waste tank assessments to preparing HMBPs. Condor provides training and guidance to meet regulatory requirements and develop compliance strategies that reduce risk, support operational continuity, and stand up to regulatory scrutiny. Condor provides support for the Certified Unified Program Agency (CUPA) program requirements: 

  • Hazardous Materials Release Response Plan and Inventory (Business Plan or HMBP)
  • Hazardous Materials Management Plan/Hazardous Materials Inventory Statement
  • Underground Storage Tanks
  • Hazardous Waste Generator and Hazardous Waste Treatment
  • Aboveground Petroleum Storage Act (APSA)
  • California Accidental Release Prevention (CalARP)

Hazardous Waste Management

The goal of federal Resource Conservation and Recovery Act (RCRA) and state (non-RCRA) hazardous waste regulations is to prevent toxic substances from contaminating ecosystems, preventing illnesses, and protecting public safety. Handling, transport, and disposal activities need to adhere to environmental laws to avoid penalties and lawsuits. If you are a large quantity generator of RCRA hazardous waste or a hazardous waste generator in California, you have biennial reporting and/or a California Department of Toxic Substance Control (DTSC) electronic verification questionnaire (eVQ) to prepare. Condor can assist with providing guidance in meeting both federal and state hazardous waste requirements, provide training to operations personnel handling hazardous waste or managing operations, and develop quick reference guides following the Generator Improvements Rule (GIR). 

Hazardous Waste Tank Assessments

State and federal requirements mandate a written integrity assessment of hazardous waste tanks certified by an independent, California-registered, Professional Engineer (PE) for large quantity generators. These assessments evaluate tank design, age, waste compatibility, corrosion protection, secondary containment, and results of integrity testing to ensure systems can safely operate without leaks or structural failure. Condor conducts hazardous waste tank assessments for the initial installations of the tank system and every 5 years thereafter for existing tanks.

Toxic Release Inventory (TRI)

The Toxic Release Inventory (TRI) is a federal reporting requirement for the management of TRI-listed  chemicals. Industrial facilities in covered sectors -including manufacturing, mining, and electric power generation- must evaluate their operations annually to determine whether TRI reporting is required. Facilities that meet the criteria submit TRI data to the U.S. Environmental Protection Agency (EPA) by July 1, reporting chemical usage, releases, and waste management activities from the previous calendar year. Condor assists facilities through the TRI reporting process, from applicability determinations and threshold evaluations to data compilation, form preparation, and submittal. Whether you are reporting for the first time, managing multiple facilities with reportable chemicals, or looking to strengthen internal tracking and documentation, Condor helps streamline TRI compliance while reducing the risk of errors, late submissions, and enforcement actions. 

Industrial General Permit (IGP)

The Industrial General Permit (Order 2014-0057-DWQ as amended in 2015 and 2018) regulates storm water discharges and authorized non-storm water discharges from industrial facilities in California. Coverage requirements under the Industrial General Permit (IGP) are based on a facility’s Standard Industrial Classification (SIC) Code and the level of exposure of industrial operations/materials to storm water. A No Exposure Certification (NEC) means that industrial activities and materials are not exposed to storm water while Notice of Intent (NOI) coverage is required where industrial materials, equipment, or activities are exposed to storm water. Condor offers a complete range of storm water regulatory compliance support including report preparation, training, visual observations, storm water sample collection, testing, analysis, and Stormwater Multiple Application and Report Tracking System (SMARTS) data entry. Condor’s Industrial Storm Water Compliance Services include:

  • New Discharger site evaluation and pollutant source assessments.
  • Preparation and submittal of Permit Registration Documents (PRDs) for NOI or NEC coverage.
  • Storm Water Pollution Prevention Plan (SWPPP) development and implementation support.
  • Monitoring Implementation Plan (MIP) and Site Maps.
  • Evaluation and recommendation of Best Management Practices (BMPs).
  • Monthly Dry Weather Visual Observations
  • Qualified Sampling Event (QSE) sampling and visual observations.
  • Data compilation and analysis.
  • Annual SWPPP Training.
  • Qualified Industrial Storm Water Practitioner (QISP) to conduct Exceedance Report Action (ERA) Plans and Technical Reports.
  • Annual Evaluations (due by June 30th)
  • Annual Report preparation and SMARTS submittal (due July 15th)
  • Notice of Termination (NOT) assistance upon facility closure or ownership change.
  • Notice of Non-applicability (NONA) assessments and technical report preparation.
  • Client advocacy and coordination with permitting agencies.
  • Client support response to corrective actions and third-party litigation.