Clover Leaf provided support to Hess Oil for compliance with 40 CFR 98 Mandatory Reporting of Greenhouse Gases and Annual Emissions Inventory for all global operations. We helped evaluate Hess facilities for applicability, using interviews and collection of data for all upstream and downstream assets. Our staff also evaluated the type of facility and process, type of combustion reporting required, identification of potential source codes, and initial assessment of annual emissions. After conducting an initial pilot, we assisted Hess with an integration process that allows them to transfer all production related data from their data warehouse into the system and export data for internal reporting purposes.
American Electric Power (AEP) – Title V Optimization of Software, Ohio, Louisiana, Arkansas, and Oklahoma sites
Clover Leaf assisted AEP with the implementation of software at six of AEP’s power plants in four states to optimize management of Title V permits. The project included staging data for integration, populating permit requirements into the system for tracking, configuring the system for calculations, and developing automated deviation reports and compliance certifications. AEP is the largest coal-fired electric generation company in the world.
Clover Leaf designed and implemented a solution for the Air Emission Inventory and TR reporting needs of five Luminant coal-powered power plants in Texas using a web-based, database software (Enviance). The project included analyzing previous reports and spreadsheets and modifying/replicating calculations in the database as appropriate. The Emissions Inventory reports produced by the system integrate directly with the online Texas Air Reporting System to allow for efficient reporting.
Clover Leaf originally developed AutoPilot®, our patented “no log-in” software management system, to help with compliance in environment, health, and safety (ES&H) areas. Using our proprietary, cost-effective system, managers can track performance on a variety of metrics to ensure that essential tasks are completed on time. Has your staff completed their quarterly water samples? It’s simple to send out reminders and, with our CLICK-CLICK-DONE system, to get the news when sampling has been completed. AutoPilot operates from your email or the web, so there’s no need for your staff to learn a new software system. If your company needs with compliance areas other than EH&S, AutoPilot can easily be adapted to track any type of compliance task throughout your organization.
Kirtland Air Force Base (KAFB) owns and maintains a Public Water System (PWS) that serves approximately 27,000 people. To ensure that KAFB stays in compliance with the Safe Drinking Water Act, Clover Leaf updated the base’s Management Action Plan (MAP). The MAP is used as a Best Management Practice to ensure that compliance activities required by the EPA, New Mexico Environmental Department (NMED), and U.S. Air Force are met or exceeded, as well as to meet the Sampling and Analysis Monitoring (SAM) plan required by NMED. The MAP details all of the requirements that pertain to the KAFB PWS, such as the Ground Water Rule, Stage 2 Disinfection Byproduct Rule, Unregulated Contaminant Monitoring Rule 3. The MAP follows the format of the AFI 48-144, Drinking Water Surveillance Program. As part of the MP, Clover Leaf also updated KAFB’s Ethylene Dibromide Contingency Plan. The goal of the plan is to minimize hazards to human health and/or the environment.
Clover Leaf staff reviewed potential Clean Water Act violations at the University of New Mexico’s Albuquerque campus. The review also included UNM’s MS4 Discharge Permit for storm water. Clover Leaf water experts revised UNM’s storm water management plan and identified key sampling points on the campus by point-source risks.
Clover Leaf efforts were key to the development of Materion’s municipal wastewater discharge permit application for the City of Albuquerque, NM. We provided direct coordination with City regulatory authorities, and on-site support for the collection of data relevant to the renewal of a municipal wastewater discharge permit for industrial processes involving the extraction and refinement of special metals.
Clover Leaf staff conducted on-site inspections at 12 VaARNG locations to ensure that the locations were in compliance with OSHA and industry standard requirements for storage of hazardous materials. The inspections included reviewing labeling of hazardous materials; conducting an inventory of hazardous materials; inspecting storage of hazardous materials for incompatibilities; reviewing shelf life; and inspection procedures. VaARNG personnel were present at the inspections to learn about OSHA, Defense Logistics Agency (DLA), and industry standard requirements (NFPA and ANSI), such as Safety Data Sheets (SDS), shelf life, and storage of incompatible materials.
New Mexico Army National Guard (NMARNG) – Spill Prevention, Control and Countermeasures (SPCC) Plan & Training
Recent construction at the Army Aviation Support Facility (AASF) in Santa Fe, NM, included the addition of a 12,500 gallon aboveground storage tank (AST) and a 2,500 gallon AST for a generator. Clover Leaf environmental staff visited the facility to document site conditions then revised the SPCC Plan that was implemented at AASF sites across the state. The plan details policies and procedures to prevent environmental incidents, and establishes effective response plans should spills occur. We also developed and presented on-site training that targeted OSHA HAZWOPER training requirements, 1910.120(q), and demonstrated how NMARNG Spill Response Team Members should safely respond to spills.
NMARNG conducts a variety of field maneuvers and activities at the Camel Tracks Training Area (CTTA). To ensure compliance with their Integrated Natural Resources Management Plan (INRMP) and manage sustainability of their property, the training area was surveyed for peregrine falcons and herpetological species. Amphibians were surveyed in aquatic habitats following U.S. Fish and Wildlife Service survey protocols. Terrestrial herp surveys included lizard transects established in the canyon bottom of Canada de Santa Fe and on the mesa top in open grassland and pinon-juniper habitats. To further identify snake species that may occur at the Camel Tracks site, drift fences with funnel traps were installed in areas previously cleared for use.