What triggers the need for a Title V air permit?

Title V permits are required under the Clean Air Act for major stationary sources that emit, or have the potential to emit, 100 tons per year or more of any regulated pollutant, 10 tons per year of any single hazardous air pollutant (HAP), or 25 tons per year of combined HAPs. Some source categories have lower major source thresholds in nonattainment areas. Facilities that are near these thresholds should conduct a formal applicability analysis before expanding operations or adding new equipment.

Environmental Compliance Services

Q: How often are SPCC plans required to be reviewed and amended?

Under 40 CFR Part 112, facilities must review and evaluate their SPCC plan at least once every five years. An amendment is required whenever there is a change in facility design, construction, operation, or maintenance that materially affects the facility's potential for a discharge. A qualified individual (QI) or, in some cases, a licensed professional engineer must certify the plan. Failing to keep the plan current is a common enforcement finding during EPA inspections.

Environmental regulations tighten every year, and the cost of falling short can be severe, from operational shutdowns to federal penalties. ESE Partners’ environmental compliance consultants keep oil and gas operators, energy producers, manufacturers, and chemical facilities ahead of those obligations. We handle permitting, auditing, reporting, and regulatory interpretation across air, water, waste, multimedia, and sustainability programs, so your team can stay focused on running the business.

REQUEST A PROPOSAL

SEE OUR CASE STUDIES

Why Clients Choose ESE Partners

Fast Turnaround, No Surprises

Audits, Renewals, and Permits delivered on time every time. Expedited options available. We keep you informed at every milestone

Offices Across Major Markets

With offices in Houston, Dallas, Austin, and San Antonio, we provide boots-on-the-ground service across the Sun Belt and beyond.

Experienced, Credentialed Team

Our team includes licensed Professional Geologists, Professional Engineers, and EPA-recognized Environmental Professionals with decades of experience.

Our Environmental Consulting Services

From a single facility permit to a multi-site compliance program, ESE Partners’ environmental compliance services cover every regulatory obligation your operation faces. We provide our clients with a single experienced team to manage the full scope of their compliance needs. We back each service with licensed environmental compliance consultants who know federal and state requirements in depth and have the hands-on experience to keep your facilities in good standing.

Air Compliance

As an environmental compliance company, ESE Partners provides numerous air compliance services to the oil & gas, energy, chemical, and manufacturing market sectors. Our air expertise includes air permitting (Permits by Rule, Standard Permits, New Source Review, Title V Permits), air dispersion modeling, onsite auditing and inspections, federal and state regulatory analysis, emissions inventory, GHG analysis, and deviation and periodic reporting.

Air Compliance Services:

Permits by Rule
Standard Permits (30 TAC 116.620)
Non-Rule Standard Permitting
New Source Review
Title V Permitting
PSD/NNSR
AVO (NSRP and NSPS OOOO) Inspections
Emissions Case Studies
Vapor Recovery Unit (VRU) Emissions Testing
Semi-Annual and Quarterly Reporting
Deviation Reporting
Mass Emissions Cap and Trade
GHG Analysis
GHG Reporting
Turnkey Inventory Maintenance and Reporting
Emissions Inventory
Annual Compliance Certification
Air Quality Audits
Air Quality Modeling

Water Compliance

ESE’s water compliance capabilities include industrial and construction stormwater permitting, stormwater pollution prevention plan (SWPPP) preparation, SPCC planning, FRPs, RMPs, Tier II reporting, TRI reporting, AST/UST registration/permitting, wastewater permitting and reporting, onsite inspections and compliance audits, drinking water assessments, wetlands determinations, and water sourcing/acquisition planning. Our environmental compliance services keep your facilities in line with state and federal regulations.

Water Compliance Services:

Stormwater Inspections
Industrial Stormwater Permitting
Construction Stormwater Permitting
Stormwater Reporting
Drinking Water Assessments
Wastewater Permitting
Wastewater Source Mapping
Wastewater Reporting
Water Licensing
Water Sourcing/Acquisition Planning
Water Use Reporting

Waste Compliance

ESE Partners provides comprehensive waste permitting, planning, and compliance services to assist our oil & gas, energy, chemical, and manufacturing clients in addressing federal, state, and local requirements. Our environmental compliance consultants provide services including waste characterization, industrial/hazardous waste registration, waste management support, pollution prevention planning, and other state- or federally required waste permitting, waste reporting, onsite inspections, and compliance auditing.

Waste Compliance Services:

Hazardous & Industrial Waste Characterization
Waste Generator Registration (EPA, State & Local)
Hazardous Waste Permitting (Treatment, Storage & Disposal – TSDF)
Industrial & Special Waste Permitting
Pollution Prevention (P2) & Waste Minimization Planning
Waste Profiles & Disposal Approvals
Biennial Reports & Waste Reporting
TRI (Toxics Release Inventory Reporting Support
Tier II Reporting
RCRA Hazardous Waste Management Compliance Audits
Contingency Plans & Emergency Response Preparedness
Universal Waste & Used Oil Management Support
Waste Storage Area Design & Compliance
Facility Waste Management Plans

View MSW TYPE V Recycling and Recovery Registration Applications Here:

View SMI Type V Registration

View SMI Type V Registration NOD Response

View SMI Type V Registration NOD 2 Response

View SMI Type V Registration NOD 4 Response

View SMI Type V Registration NOD 5 Response

Multimedia Compliance

ESE also provides custom-tailored, cost-effective multimedia compliance solutions to help clients manage regulatory, permitting, and internal requirements. Our multimedia environmental compliance services include compliance audits, regulatory applicability and interpretation, EHS management systems design and implementation, EHS risk assessments, compliance assurance tool design, EHS organizational strategies, best management practices/corporate EHS standards development, and other permitting, planning, and compliance support.

Multimedia Compliance Services:

SPCC Plans
SPCC Inspections
PST Registration
Facility Response Plans (FRP)
Oil Spill Contingency Plans
Risk Management Plans (RMP)
Mechanical Integrity Inspections
Tier II Reporting
TRI Reporting
Emergency Planning/ Community Right to Know Support

ISO 14001 Audits
EHS Management Systems
EHS Compliance Audits
Compliance Assurance Tool Development
Regulatory Applicability Assessments
Compliance Program Design and Implementation
EHS Standards Development
EHS Risk Assessment
Endangered Species Studies
General Land Use Regulations

Sustainability Compliance

ESE Partners is committed to helping today’s corporations achieve their sustainability goals. We understand that these goals should dovetail into the specific needs of a growing organization. We also understand that each company’s sustainability needs are unique and specific to their core purpose, location, and industry. ESE offers a wide range of expertise and environmental compliance services to match your company’s sustainability needs.

Sustainability Compliance Services:

ESG Reporting
Greenhouse Gas Inventories
Carbon Footprint Analysis
Carbon Sequestering Permitting & Consultation

Carbon Reduction Planning & Implementation
Air Permitting
Compliance Auditing & Permitting
Health & Safety Consulting

Why Choose ESE Partners for Environmental Compliance Consulting Services?

ESE Partners is a full-service environmental compliance company with deep roots in the industries where compliance pressure is highest, including oil and gas, energy, manufacturing, and chemical production. Our consultants hold active licenses across multiple disciplines and maintain ongoing education in the regulatory areas they serve, so you always have someone who understands the specific rules that apply to your facility.

We take a practical approach to compliance. That means finding the most efficient path to a permit, catching gaps before an inspector does, and structuring reporting programs that your internal team can maintain. Our environmental compliance services span air, water, waste, multimedia, and sustainability.

Because we also provide due diligence, remediation, and natural resources services, we can address compliance issues in the broader context of your facility’s environmental history and future development plans.

Industrial storage tanks with exterior staircases at a facility supporting environmental compliance and regulatory operations.

Headquartered in Texas with a national project footprint, ESE Partners has completed compliance work for large operators across the Gulf Coast and beyond. Our clients return to us because we know the regulatory agencies, understand local permit processes, and get results.

Talk to an Environmental Compliance Consultant

Compliance gaps don’t fix themselves, and the longer they go unaddressed, the more expensive they become. ESE Partners’ environmental compliance consultants are ready to assess your current obligations, identify exposure, and put a program in place that keeps your facility in good standing. Contact us today to speak with a member of our team.

REQUEST A PROPOSAL

More Services

Due Diligence

Early-stage environmental risk identification protects deal value and prevents costly surprises during financing or construction.
Learn More

Remediation

Site investigation and cleanup services that turn contaminated properties into usable, financeable assets.
Learn More

Butterfly on flowering plant in a wooded area with environmental compliance technician conducting fieldwork in the background

Natural Resources

Permitting, wetland delineation, and ecological assessments for energy, infrastructure, and development projects.
Learn More

Cultural Resources

NHPA Section 106 surveys, monitoring, and mitigation for projects requiring federal or state cultural resource review.
Learn More

two men in construction safety gear surveying incomplete building interior

Building Sciences

Science Asbestos, lead, mold, and indoor air quality assessments for property owners, buyers, and facility managers.
Learn More

Sustainability

ESG reporting, carbon footprinting, and sustainability strategy tailored to your organization’s growth.
Learn More

Renewable

Environmental support for solar, wind, and energy storage projects — from due diligence through construction.
Learn More

Frequently Asked Questions About Environmental Compliance

What triggers the need for environmental due diligence?

Environmental due diligence is most commonly triggered by a commercial real estate transaction, an oil and gas acquisition, or a lender’s financing requirements. Under CERCLA, buyers who fail to conduct appropriate due diligence before purchasing a property can be held liable for pre-existing contamination, even if they had no involvement in creating it. The innocent landowner defense and the bona fide prospective purchaser defense both hinge on completing a Phase I ESA that satisfies the All Appropriate Inquiries (AAI) standard.

How often are SPCC plans required to be reviewed and amended?

Under 40 CFR Part 112, facilities must review and evaluate their SPCC plan at least once every five years. An amendment is required whenever there is a change in facility design, construction, operation, or maintenance that materially affects the facility’s potential for a discharge. A qualified individual (QI) or, in some cases, a licensed professional engineer must certify the plan. Failing to keep the plan current is a common enforcement finding during EPA inspections.

What is the difference between a Tier II report and a TRI report?

Tier II reporting is required under EPCRA Section 312 for facilities that store hazardous chemicals above certain threshold quantities. These reports go to state emergency response commissions (SERCs), local emergency planning committees (LEPCs), and local fire departments, and they focus on chemical storage inventory. TRI reporting under EPCRA Section 313, by contrast, is a release and transfer report, meaning it tracks how much of a listed toxic chemical a facility releases to the environment or transfers off-site in a given year. The two programs have different chemical lists, thresholds, and deadlines.

Texas Firm with a National Reach.

Discover featured projects from across ESE Partners’ disciplines: Due Diligence, Building Sciences, Remediation, Compliance, and Natural & Cultural Resources.