EnviroForensics® staff members have specialized in compliance and permitting for the past 20 years, developing a broad expertise by assisting clients in regulatory strategy formulation, preparation of permit applications, review of project regulatory requirements, and compliance monitoring and reporting.

Service Areas

•   Environmental Audit
•   Wastewater Characterization
•   Storm Water Pollution Prevention Management
•   Spill Prevention, Control and Countermeasures (SPCC) Plan
•   Hazardous Material Management Plan (HMPP)
•   Pollution Prevention and Waste Minimization
•   National Pollutant Discharge Elimination System (NPDES) Permitting
•   Wetlands and Waters of the United States Permitting
•   Air Permitting

Environmental Audit

An environmental audit is the first step towards developing an environmental compliance program. Audits aid industries in identifying areas where compliance deficiencies may exist, in prioritizing compliance goals, and in obtaining fund appropriations. Audit findings provide industries with detailed information on where the waste is generated, how much is generated, and reasons why waste is generated. The audit enables industries to monitor the generation of wastes more closely and to assure they are being disposed of legally and in the most economic manner. EnviroForensics® assists clients in conducting an environmental audit through five basic steps:

•   Review operating practices
•   Identify applicable regulations
•   Identify compliance deficiencies, if any
•   Establish compliance goals and priorities
•   Prepare a corrective action plan, schedule, and budget

To perform successful audits, EnviroForensics® has developed standard procedures, protocols, and checklists for audit teams comprised of client staff and EnviroForensics® staff members. Teams identify deficiencies in compliance, and develop recommendations for short and long-term goals.

Wastewater Characterization

Wastewater characterization provides the basis and foundation for developing facility-wide pollution prevention and control plans. Flow and quality of waste streams are characterized in terms of low-volume concentrated wastes or high-volume diluted wastes. EnviroForensics® assists clients in developing wastewater sampling and analysis plans. Based upon manufacturing schedules, anticipated daily and weekly variations, and other activities such as construction, equipment cleaning, etc., sampling plans can be developed which identify the impact on wastewater quality due to process and operating variables, and other outside factors. This data is necessary for the development of cost-effective waste management plans.

Storm Water Pollution Prevention Management

Storm water, a pollutant source, can contribute substantial pollution to receiving streams if not managed properly. As part of developing an overall industrial waste management plan, EnviroForensics® can assist industries in developing a storm water management program to allow maintenance of an effluent quality within regulations. To develop cost-effective storm water management plans, the following is considered:

•   Facility and site setting
•   Major pollution sources including loading and unloading areas, outdoor storage and operating facilities, parking lots, dust generating operations, non-storm water discharge connections, and/or flows to storm water sewers, solid and hazardous materials and waste management
•   Stormwater quality and quantity
•   Pollution prevention options that may include or improve/ operating practices, containment, diversion, run-on controls, good housekeeping, proper maintenance, etc.
•   End-of-pipe treatment, if necessary
•   Monitoring and record keeping Plans such as emergency response plans, contingency plans and spill prevention/control/ countermeasure plans, complement storm water pollution prevention and management programs.

Spill Prevention, Control and Countermeasures (SPCC) Plan

Under the Clean Water Act (311(j)), owners and operators of oil storage facilities are required to prepare and implement SPCC plans, which detail facility control and countermeasures to prevent oil spills and its impact on the environment. EnviroForensics® staff has developed SPCC plans for several large utility clients using sound engineering practices. The key to developing a sound SPCC plan is:

•   Identify all oil and chemical storage facilities
•   Evaluate their integrity and containment capacities
•   Review past spill history and actions taken
•   Predict potential spill events and their impacts
•   Design a proper spill containment, monitoring and disposal plan
•   Develop a testing, monitoring, recording and maintenance program
•   Develop a training program for a responsible organization

Hazardous Material Management Plan (HMPP)

Under the Federal Superfund Amendments and Reauthorization Act of 1986 (SARA), industries handling regulated hazardous and toxic materials above their threshold quantities are required to have a HMPP. Reporting threshold quantities for gas, solid and liquid materials are established under regulations. EnviroForensics® can assist its clients in developing HMPPs to be in compliance with the regulations. Key parts of the HMPP are:

•   Hazardous and toxic material inventories and related data
•   Emergency response plans to be followed for a release or threatened releases
•   Personnel training program

EnviroForensics® develops a detailed chemical inventory including chemical name, physical state, trade and common name, manufacturer, quantity range, location, physical and health hazard, and storage temperature and pressure. EnviroForensics® develops facility maps showing loading and storage areas, internal roads, parking lots, stormwater and sewer drains, type of storage, emergency response equipment etc. EnviroForensics® staff works closely with client staff in developing an emergency response plans and procedures to address releases or threatened releases of hazardous materials. EnviroForensics® and the client staff together develop facility specific training program for new employees and annual training, including refresher courses, for all employees in safety procedures in the event of a release or a threatened release.

Pollution Prevention and Waste Minimization

An alternative approach to “end-of-pipe” waste management is Pollution Prevention/Waste Minimization (PP/WM). The PP/WM approach seeks to eliminate or reduce undesirable by-products from the production process itself, rather than by treating by-products after they are created. This approach decreases the need for costly treatment, and also provides the following benefits:

•   Improved public health and environment
•   Reduced risk of liability
•   Improved productivity and efficiency
•   Reduced operating costs
•   Improved company image PP/WM is more cost-effective and environmentally sound than traditional end-of-pipe pollution control methods. This has led the United States Environmental Protection Agency (USEPA) to place Pollution Prevention at the top of its hierarchy of environmental management strategies.

National Pollutant Discharge Elimination System (NPDES) Permitting

Permitting is initiated when the system design basis is established. Several permits may be required to construct and operate a facility and to discharge treated wastewaters. These permits include, but are not limited to:

•   National Pollution Discharge Elimination System (NPDES) permit
•   Construction and industrial stormwater NPDES permits
•   Pretreatment permit from the local city agency
•   Permit to construct in wetlands or Waters of the United States

EnviroForensics® contacts appropriate regulatory agencies, prepares permit applications, and submits applications and fees. EnviroForensics® ’ staff members work closely with regulatory agencies to resolve problems that may arise. Key to successfully obtaining permits is the identification of best management practices (BMPs) to reduce pollutant discharges in urban storm water, as well as, setting measurement goals for BMPs. EnviroForensics® has a complete interdisciplinary watershed team, to assist in these areas, when design of a BMP program is critical for compliance.

Wetlands and Waters of the United States Permitting

With ever increasing scrutiny of environmental impacts on aquatic resources has come the need for identification of existing wetlands and for mitigation of development impacts on aquatic and wetland habitat. EnviroForensics® has staff members who are qualified in delineating jurisdictional wetlands according to the United States Corp of Engineers procedures. having Investigations have involved delineation of existing wetlands, determination of project impacts on wetlands, and preparation of mitigation plans to meet the requirements for replacement of resources. EnviroForensics® has developed plans for the creation of new wetlands to replace wetlands impacted by project development, as well as, having permitted a number of projects through the Corp and state agencies that include impacts to wetlands, streams, and floodplains.

Air Permitting and Monitoring

Industrial air emissions often need to be controlled for compliance with regulations for protection of ambient air quality. EnviroForensics® ’ air quality services include:

•   Permitting
•   Preparation of emissions inventories
•   Air quality audits
•   Emission control plans (RMPPS)
•   Health risk assessment and risk communication
•   Air pollution control engineering
•   Air monitoring services
•   Odor control, impact assessments
•   Noise studies