AECOM EHS Service Summary Sheet

ECI Program

Permit Streamlining and Simplification

Innovation:

Permit review that combines (1) focussed advocacy for simplest compliance obligations and (2) enhanced operator compliance through targeted action protocols.

Benefit:

  1. Review air permits to verify continued applicability and identify requirements that can be removed, updated, or streamlined.
  2. Identify and develop compliance plans, monitoring approaches and BACT to provide the most operational flexibility.
  3. Developed practices that allow rapid transition between operational modes and/or add new equipment with minimal agency involvement.
  4. Identify regulatory options for various operating scenarios and plant expansions.
  5. Develop equipment or process database that includes applicable air regulations and operational data.
  6. Identify opportunities for reduction of administrative requirements.
  7. Compare air permit to permits issued to similar facilities to determine if more flexible approaches can be achieved.
  8. Evaluate actual and maximum air emissions to determine if the facility potentially qualifies for a less burdensome class of permit
  9. Provide up to date information on EPA and state policy changes

Deployment Steps:

  1. Identify permits due for renewal across NVS operating portfolio
  2. Agree those that have not been critically assessed recently or are will be subject to more demanding intervening legislation
  3. Assign to AECOM permit review specialists as appropriate to assist in developing best application

Timeline to Develop:

  1. Permit renewal data base depends upon NVS data infrastructure in place at present
  2. Actual review depends upon complexity of permit and relationship with relevant regulator
  3. ‘Action word’ editing for focused compliance tasks can be done at any time

Rough Cost:

Depends upon permits

AECOM Team location:

Globally with CoE in United States

Novartis Interface Required:

HSE Compliance Lead, HSE Data Manager

Link to more info / video:

N/A

Notes:

N/A