Straight answers on regulatory scope, pricing, and how we operate.

Yes. We operate Title V major-source programs end-to-end under 40 CFR Part 70 — permit application, compliance assurance monitoring plans (CAM), semi-annual monitoring reports, annual compliance certifications, deviation reporting, and TCEQ permit renewals under Chapter 122. Operator+ and Enterprise tiers include CEMS/CPMS integration.

Subpart N (chromium electroplating and anodizing) is our primary metal-finishing subpart — we run the required add-on controls compliance, monthly inspections, and initial notification of compliance status. Subpart WWWWWW for plating and polishing area sources, Subpart MMMM for surface coating of miscellaneous metal parts, and Subpart PPPP for surface coating of plastic parts are all in scope. We build the monitoring and reporting schedule into your calendar and operate it.

Yes. We compile the facility-specific PFAS inventory, run the supplier chain-of-custody discovery, and file the annual report through CDX with the 2011-forward look-back. We also track the downstream obligations from the EPA PFAS Strategic Roadmap that affect industrial users.

Yes. Individual NPDES permits, TPDES stormwater MSGP (TXR05000), industrial multi-sector coverage, and pretreatment categorical standards. We operate DMRs monthly, run the SWP3 (stormwater pollution prevention plan) inspections, and coordinate with local POTW pretreatment coordinators on categorical discharge metrics.

Yes — LQG, SQG, and VSQG status management, biennial reporting for LQGs, contingency plans per 40 CFR §262.261, training under §262.17, container inspections, and the RCRA manifest program. Universal waste, used oil, and e-waste flows under 40 CFR Part 273 are included.

Both are annual deliverables that live inside every Vertexium retainer. We run the threshold determination, alternate-threshold certifications where applicable, supplier-provided information for de minimis exemptions, and the Tier II facility chemical inventory for state and local LEPCs. PFAS additions under the 2020 NDAA are tracked.

Full PSM program operation under 29 CFR 1910.119 — process safety information, process hazard analyses on the 5-year cycle, operating procedures, management of change, pre-startup safety reviews, and compliance audits. RMP program parallel coverage under 40 CFR Part 68 for the same threshold chemicals.

Yes. Annual AEI under 30 TAC Chapter 101 for facilities exceeding the reporting thresholds — emission calculations, source classification, data submission through STEERS, and coordination on any audit findings from TCEQ Region 4 (Dallas-Fort Worth).

At the Enterprise tier we support consent-order and agreed-order negotiations alongside your legal counsel — technical positions, supplemental environmental project (SEP) design, injunctive-relief scope, and penalty-mitigation arguments. Operator+ includes representation at informal settlement conferences.

Because below that we can’t operate a real program — we can only advise, and advice without operation is what got most compliance programs into their current state. At $20k/mo we staff embedded hours against your specific program every week, run the reporting calendar, and accept accountability for deliverables. A site-specific EHS manager fully loaded runs $120k–$180k per year plus benefits and tech stack; we are cheaper and more senior.

We down-sell. If you land within three points of a tier boundary on the diagnostic, we recommend the lower tier with written upgrade triggers in the SOW — e.g., “any new NOV, any new Title V permit, any M&A closing → auto-escalate to next tier.” That saves you money on day one and makes the upgrade the customer’s choice when it happens, not ours.

Quarterly prepaid. All three tiers bill every three months ($60k, $120k, and $240k per quarter for Operator, Operator+, and Enterprise respectively). Stripe handles invoicing and auto-renewal. No hourly. No pass-through of our internal tool costs. No surprise line items.

Week 1: program audit and data ingest. Week 2–3: calendar build (all reporting obligations, deadlines, owners). Week 4: operating rhythm live — weekly standups, monthly compliance reviews, quarterly tier-fit reviews. We don’t pause your clock for onboarding — the first month of retainer is our problem to prove out.

Quarter-end termination with 30 days’ notice, no penalty. We hand back the full compliance calendar, all work product, and run a 2-week transition to whoever takes over. The relationship only stays as long as the value does.

Rarely. Our model is operational, not advisory. The exceptions are (a) permit applications for prospective clients we’re about to sign, (b) M&A environmental due diligence on a project basis, and (c) targeted audit-readiness engagements where a retainer would be over-spec. Everything else funnels to the retainer conversation.

Multi-site coordination (2–5 facilities under one program), CEMS/CPMS data integration and automated monthly exception reporting, a dedicated senior operator instead of a shared one, informal settlement conference representation, and faster incident-response SLAs (6 hours vs 24). If you’re running multiple facilities or HAP-heavy operations, this is usually the fit.

Six or more regulated facilities, multi-HAP exposure with PFAS, active enforcement or consent-order obligations, M&A deal flow, or a combination. Enterprise includes 24/7 incident response, agency negotiation support, and M&A environmental due diligence coverage on new acquisitions.

The basics: last three years of permits, reporting submissions, inspection reports, and NOVs. Process flow diagrams for regulated units. Chemical inventory (SDS library). Monitoring data — CEMS, CPMS, or periodic stack-test reports. Current incident log. If you don’t have some of it, we find it.

Yes — at Operator+ and Enterprise tiers we pull directly from vendor platforms (CONSOL, Spectrum Continua, ESC’s DAS) or your on-prem DAS. We run automated exception-hour alerts, monthly QA audits, and produce the Title V and NESHAP compliance data reports directly from the source stream.

Operator: 24 business hours for non-release events. Operator+: 6 hours around the clock. Enterprise: 2 hours with an on-call senior operator, 24/7, 365. Events triggering CERCLA §103 release reporting (RQ-exceeded spills) or EPCRA §304 notification get same-hour response on all tiers.

Yes. We run internal environmental audits on a one-year or two-year cycle depending on risk profile, produce findings reports with corrective-action plans, and track closure. We also prep you for and support agency inspections (TCEQ, EPA Region 6, OSHA) — opening conferences, document presentation, closing conferences.

Operator+ and Enterprise include after-hours coverage for reportable events. Operator tier gets next-business-day response. For both, we maintain an on-call rotation — the person answering the phone can execute the release notification, not just escalate.

Yes. We use AI to compress the time from event to report — automatically pre-drafting deviation narratives from CEMS exception hours, pre-populating Form R calculations from SDS and production data, and pre-flagging permit renewals. Every output is reviewed by a licensed environmental operator before anything leaves our system. AI accelerates us; it does not replace accountability.

In a dedicated tenant on our Vertexium Operations Platform (VES OPS) — US-hosted, SOC 2 Type II controls in progress, encrypted at rest and in transit. Your data is never used to train shared models. Export is available at any time, in standard formats (CSV, JSON, PDF for reports).

A named senior operator as primary, a backup operator, and a support analyst. Full-name introductions during week 1. At Enterprise tier you also get a named regulatory-liaison operator for agency interactions.

Two reasons. First, DFW has an unusually dense cluster of mid-market operators in these sectors — roughly 40 sites in the metro with Title V or major-source status in metal finishing alone. Second, their compliance burden is heavy (Subpart N chromium, Subpart WWWWWW area sources, PFAS in fluoropolymer plating, TRI reporting) and poorly served by the generalist consulting model. We operate, not consult — that’s the gap.

Full Subpart N operation — add-on control device compliance (polypropylene mesh pads, packed-bed scrubbers, composite mesh pads), weekly surface-tension testing if fume-suppressant compliance method, monthly inspections per §63.342(f), initial and every-5-year performance tests, and the semi-annual monitoring reports. We also run Ni and Cr(VI) compliance under OSHA 1910.1000.

TSCA §8(a)(7) reporting (back to 2011), supplier chain-of-custody verification, the National PFAS Testing Strategy preparation, TRI reporting of PFAS substances added in 2020 and expanded since, and — if discharged — NPDES monitoring under the 2023 interim rule. We also help you understand the CWA ELG rulemaking exposure for your sector.

Selectively. Food processing commonly involves ammonia refrigeration (PSM + RMP thresholds at 10,000 lb), FDA food safety coordination, and wastewater high-BOD discharge programs. We take food processors where the program overlap with industrial compliance is tight — ammonia PSM, pretreatment, CAA air permits. Pure FDA food-safety programs we refer out.

Yes at Operator+ or Enterprise — pharma CMOs carry Subpart GGG (pharmaceutical production), solvent recovery NESHAP, wastewater pretreatment, RCRA LQG status almost always, and PSM for process chemicals. The compliance density usually puts you at Operator+ regardless of size.

Not our current focus. Midstream has OOOOa/OOOOb, Subpart W, flaring-specific programs, and methane-rule obligations that are better served by specialists. We will take adjacent operators (specialty chemical sites supplying into oil & gas, for example) but not operate pure midstream.

Yes at the Enterprise tier. We operate federally-delegated programs (CAA, CWA, RCRA, TSCA) across any state where your facilities sit. State-specific programs get local co-counsel or local operator support where needed. DFW is our operating hub; facilities in Oklahoma, Louisiana, Arkansas, and New Mexico are handled natively.

The opposite. Recent NOVs are the clearest signal we belong inside a program. We’ll review the NOV, the response, and the corrective-action plan — if you’re mid-response, we come in at Operator+ minimum and help drive to closure. If it’s been closed, we come in at whatever tier fits the underlying complexity.

Zero. The diagnostic at diagnostic.vertexiumenv.com is ten questions and produces a written burden assessment plus tier recommendation. If the tool says you’re not a fit, we tell you. If it says you are, you book a call.