Who wrote your permit? Who applies its provisions? Do they speak the same language? It’s highly likely that they don’t, since the typical permit is written by an engineer, but applied by field staff. Unfortunately, engineers are notorious for writing language that is unintelligible to the average layperson. Indeed, there is very good chance that your permit is written in a language that your landfill staff simply cannot understand.
ML’s Senior Landfill Engineer, Adam Jochelson, P. E., has spent most of the last decade interacting with landfill equipment operators almost daily. As the planning and development engineer for the largest landfill in Texas, Mr. Jochelson realized the need to bridge the communication gap between permit and operator. To solve this problem, he developed Permit Fulfillment Plans (PFPs)–your facility could benefit from implementation of PFPs.
A Permit Fulfillment Plan (PFP) is a guidance document with no actual legal bearing that describes in plain English how a facility fulfills a particular requirement stipulated in the facility permit. Because it is not part of the permit, a PFP can me modified at any time to reflect changes in practices in the field, without triggering the sometimes burdensome permit modification process.
ML will read and evaluate your permit, draw up an outline of sections in need of translation from Engineer to Operator, and talk to you and your operators about how you fulfill those sections, then develop your PFPs to fit your activities. After implementing the PFPs (including any training needed), ML will continue working with you on a regular schedule to ensure that your PFPs stay up-to-date as your facility grows.
Let ML give your staff a fighting chance to properly apply the provisions of your permit. Without PFPs, you risk violating your permit due to the simple act of misunderstanding. Don’t let the intention of your permit–and your environmental compliance reputation–be lost in translation.