See other sample projects:
Site Investigation and Remediation – PCB & Lead
Site Investigation and Remediation – Ecological Risk Characterization
Site Investigation and Remediation – Covenant Not to Sue for Former Industrial Complex
Pollution Prevention & Spill Control – Roofing Products Mfg.
IRWIN has provided multi-media compliance services for a number of years for our client’s PVC roofing manufacturing operations. Services include:
- Writing a Spill Prevention, Control and Countermeasures / Stormwater Pollution Prevention Plan for 40 CFR 112 and NPDES permit compliance.
- Preparing a Toxics Use Reduction Plan for the Facility.
- Preparing documentation for a Responsible Care® environmental management system.
- Performing an internal regulatory compliance audit of the manufacturing building and the local warehouse, and assisting with performing corrective actions.
- Responding to two MCP reportable spills of oil and trichloroethylene, and both responses were completed with Class A1 RAO’s.
- Supporting the Facility’s air permit compliance by writing progress reports and evaluating air emission sources for permit applicability.
- Providing general EHS compliance research support on a routine basis.
Multimedia Engineering & Compliance for Large Scale Printing Operation
IRWIN provided multimedia engineering and compliance services for a large scale newspaper printing operation. Services included:
- Designing a wastewater treatment system using polymer addition to flocculate metals.
- Creating a Toxic Use Reduction Plan and preparing a Toxic Release Inventory Report.
- Evaluating experimental cooling tower antifouling treatments.
- Designing emergency generator stack to comply with state air regulations (310 CMR 7)
- Conducting treatability testing to reduce metals in wastewater.
- Conducting industrial wastewater sampling to demonstrate permit compliance.
- Identifying sources of contamination when effluent exceedances are detected.
Audit for a Responsible Care® Environmental Management System
IRWIN performed an internal regulatory compliance assessment audit as part of an ongoing compliance relationship with a manufacturer of roofing and waterproofing membranes in Massachusetts. The assessment included the 70,000-square foot manufacturing building, as well as a neighboring 125,000-square foot warehouse. The objective of the audit was to identify potential noncompliance issues and identify recommendations for corrective action, in accordance with the Facility’s Responsible Care® Environmental Management System. The audit was conducted over a two-day period, and included a visual inspection of both buildings and a review of selected Facility records.
IRWIN audits follow ASTM E2107-00 Standard Practice for Environmental Regulatory Compliance Audits. The scope of the audit covered a wide range of environmental and safety programs, including the following federal and state regulations:
- OSHA Hazard Communication (29 CFR 1910.1200)
- Emergency preparedness and response
- 29 CFR 1910.38, OSHA Emergency Action Plan
- 1910.120, OSHA HAZWOPER
- 40 CFR 112, Spill Prevention, Control, and Countermeasures
- 40 CFR 68, Risk Management Plan
- 40 CFR 355, Emergency Planning
- 6 CFR 27, Chemical Facility Anti-Terrorism Standards
- Spill reporting
- 40 CFR 110, Oil Discharge Reporting
- 40 CFR 302 and 355, Emergency Notification
- 310 CMR 40.0000, Massachusetts Contingency Plan
- Air programs
- 310 CMR 7.00, Air Pollution Control
- 40 CFR 60 and 63, NSPS and NESHAP
- 40 CFR 82, Protection of Stratospheric Ozone
- Stormwater (40 CFR 122)
- 40 CFR 403 and 463, EPA Pretreatment Standards
- 314 CMR 7.00, DEP Sewer Permit Program
- 360 CMR 10.000, MWRA Sewer Use Regulations
- Water supply protection
- 310 CMR 22.00, Drinking Water
- 248 CMR 10.14, Water Distribution System
- Wetlands (310 CMR 10.00, local wetlands by-law)
- Hazardous waste (310 CMR 30.000, 40 CFR 260-272)
- Tier II reporting (40 CFR 370)
- Toxics Release Inventory and Toxics Use Reduction reporting (40 CFR 372, 310 CMR 50.00)
- Combustible liquid storage
- 29 CFR 1910.106, Flammable and Combustible Liquids
- 527 CMR 14.00, Handling of Flammable and Combustible Liquids
- 527 CMR 9.00, Tanks and Containers
- 780 CMR 414.0-415.0, State Building Code Hazardous Materials Storage
- DOT hazardous material transportation (49 CFR 171-172)
Based on the audit findings, IRWIN prepared an audit report including the following information for each finding:
- A detailed factual description of observations and evidence noted during the audit visit, based on visual observations and on verbal and written clarifications provided by Facility staff. The findings were carefully presented to avoid making judgments about individuals or departments or creating liability for the Facility. A draft copy of the report was provided in advance of the final report in order to allow the client to confirm each finding or request further clarification.
- Descriptions of applicable requirements for comparison, with referenced citations to specifically applicable paragraphs from regulations.
- One or more suggestions for corrective actions.
At the client’s request, we also provided a qualitative classification designating the severity of each finding. IRWIN’s classification scheme is consistent with ASTM E2365-05 Standard Guide for Environmental Compliance Performance Assessment. A four-tiered system was used, with Tier A representing an imminent hazard and Tier D representing a minor nonconformance such as a documentation error.
IRWIN communicated the audit findings to the Facility promptly, with a final report submitted within two weeks of the audit conclusion.
Industrial Campus Utility Plant
IRWIN provided permitting assistance for a facility with a Title V permit and NOx RACT limitation. Services included:
- Preparing air source registrations, compliance certification reports, and New Source Performance Standard compliance reports.
- Creating a Plan for Opacity Good Operating Practice to obtain flexibility in permit requirements.
- Establishing compliance recordkeeping procedures.
- Replacing equipment to improve opacity monitor reliability.
- Conducting hazardous waste management training for facility operators.
- Transferring licenses and permits for fuel tanks.
Air, Hazardous Waste and Wastewater Permitting – Metal Platers
IRWIN saved money and reduced emissions for our client, a metal plating operation. We prepared a Title V air permit modification to allow a replacement boiler, switch to low VOC coatings and eliminate a wastewater sludge dryer. IRWIN also wrote a wastewater pretreatment system operations and maintenance manual. Services included:
- Preparing a Rhode Island Air Toxics Operating Permit application.
- Preparing a Title V air permit modification.
- Writing biennial hazardous waste reports/
- Writing EPCRA Tier II reports.
Energy Recovery for Smoke and Odor Control -Specialty Fabric Maker
IRWIN reduced utility costs 20% while resolving an odor and smoke discharge problem at this manufacturing plant. By understanding the chemistry and engineering involved in the process, we were able to figure out and solve this client’s problem rather than just putting a bandaid on it. The change in process not only solved their emissions issue but saved them money! First we tested our theories at the bench scale, before asking the client to make a real investment. Then, we constructed a pilot scrubbing operation, made some adjustments once it was operational and the regulators were satisfied.
Stormwater & Spill Prevention Compliance Assistance – Manufacturing Facility
IRWIN prepared a combined Spill Prevention, Control, and Countermeasures Plan and Stormwater Pollution Prevention Plan (SPCC / SWPP Plan) for a manufacturing facility in Massachusetts. The Plan was written for compliance with 40 CFR 112 and with the Facility’s Multi-Sector General Permit (MSGP) for industrial stormwater discharge (Sector Y – Rubber and Miscellaneous Plastic Products).
The Facility had an existing SPCC Plan, which included a description of the oil storage at the Facility, measures in place to prevent oil discharges, procedures to be taken for responding to spills, a partial listing of regulatory agencies to notify in the event of a reportable discharge, and a cross-reference matrix indicating where each requirement of 40 CFR 112 could be found in the Plan text. However, the Plan was several years old, and had not been updated to reflect changes in Facility data, management practices, or applicable regulations. Additionally, the existing Plan had not been intended to address MSGP requirements.
IRWIN visited the Facility, in order to review the oil storage and stormwater exposure and the pollution prevention measures currently in place. Based on the prior Plan as a template, IRWIN added the following elements in order to create a current SPCC / SWPP Plan:
- A complete Facility spill history including a discussion of completed clean-up operations.
- A summary of plausible equipment failure scenarios and the resulting volumes and flow directions, and a discussion of how current Facility layout and management practices are designed to prevent a release to the environment.
- A discussion of the locations of stormwater exposure at the Facility, the pollution control measures present at each location, and the Facility’s housekeeping procedures.
- An updated description of steps to be taken in response to a spill or emergency, revised in order to reflect current Facility policy and OSHA HAZWOPER regulations and guidance.
- An extended listing of regulatory agencies to be notified in the event of various types of spills, conditions that trigger notification, information to include in a notification, and deadlines.
- An extended inspection schedule including inspections required to comply with MSGP requirements, increased frequency of tank inspections in order to meet 40 CFR 112 and local requirements, and procedures for corrective action. IRWIN also evaluated the need for stormwater discharge monitoring, and included documentation that monitoring was not required for the Facility.
- Requirements for annual reporting to EPA under the MSGP.
- A brief discussion of other federal and state laws and regulations that the Facility should consider when managing oil storage.
IRWIN submitted the Plan to the Facility in draft form for comments and clarifications, and then as a final document bearing an original P.E. stamp and signature. IRWIN also filed a Notice of Intent (NOI) on the Facility’s behalf via EPA’s Central Data Exchange, in order to obtain coverage under the MSGP.
Site Investigation and Remediation
PCB and Lead in Historic Fill
(Former Junk Yard & Rail Spur)
Historical industrial activities at the subject site include coal and ice storage during the early 1800’s, operation as a glass manufacturing facility from the mid-1800s to early-1930s, and as a scrap metal yard from the early 1930s to approximately 1994. The site vicinity has historically been a mixture of commercial and residential properties since the mid-1800s, including junk dealers, auto salvage yards, scrap metal facilities, meat rendering operations, and barrel refurbishing.
Over a period of 10 years, environmental consultants working on behalf of a municipal Brownfields initiative collected nearly 500 soil samples and at least 100 groundwater samples from numerous assessment locations have been analyzed for a variety of parameters. This is relatively large scope of investigation on a property that covers less than one acre of land. IRWIN consulted with the property owner and found that while EPA Brownfield grant money was used for these investigations, very little value with respect to planning a remedy was realized.
Applying practices prescribed in EPA’s Quality Assurance Project Plan (QAPP) guidance, IRWIN evaluated the data set and identified that the primary area of concern is adjacent to the existing building where fill material had been placed over railroad spurs associated with previous site activities. This area was found to have elevated levels of PCBs and lead. After evaluating the feasibility of numerous treatment options, excavation and off-site disposal was chosen as the remedial action. Due to the concentrations of PCBs encountered, IRWIN had to prepare a Self Implementing Plan for EPA approval under the Toxic Substance Control Act (TSCA). In addition, the lead concentrations subjected the removal action and remediation waste to Resource Conservation and Recovery Act (RCRA) regulations.
During the planning stages, IRWIN identified that the transportation and disposal costs associated with the soil removal would be high due to the leachable lead content. IRWIN identified several industry specialists and chose to stabilize the lead in-situ with a soil amendment. Careful planning of project logistics and knowledge of regulatory requirements allowed IRWIN to have the lead stabilized within the impact zone, avoiding unnecessary spread of the contamination and the subsequent need for follow-up confirmatory testing.
As residential properties were present within 500-feet of the work zone, IRWIN implemented a site-specific Health and Safety Plan to monitor conditions during work. This included air particle testing, noise control, and general worker/public safety considerations.
During excavation, additional volumes of PCB-impacted soil were identified. IRWIN was able to successfully work with the client to analyze alternate redevelopment plans. IRWIN conducted the work in compliance with regulatory requirements to the satisfaction of the client.
Site Investigation and Remediation (Cont’d)
Ecological Risk Characterization
(Parkland adjacent to an Active Foundry Operation)
IRWIN performed LSP Services for impacts of metals on soil, groundwater, surface water, and sediment from approximately 35,000 cubic yards of spent foundry casting sands historically filled under an existing high-alloy metal foundry. Foundry operations dating back to the early 1960s abut protected parkland. IRWIN investigated the extent of the impacts, and found elevated levels of metals (primarily nickel and zinc) in the adjacent parkland and nearby wetland.
IRWIN evaluated potential pathways, and found the primary source of metals to be overland migration associated with historical stormwater runoff into both upland and wetland areas in the park. IRWIN directed the video inspection, cleaning, and repair of storm water drainage system components. IRWIN also assisted the foundry to implement structural and non-structural Best Management Practices (BMPs) for improvement of storm water discharge quality. These improvements have been implemented and maintained in accordance with the facility’s coverage under the Multi-Sector General Permit such that there is not ongoing release to the parkland.
Migration of dissolved metals through groundwater was determined to be a small component of the overall source of metals. The limited migration of metals through groundwater has been addressed by injection of remedial additive on the foundry property. IRWIN engineered the in-situ remedial additive application so it resulted in distribution of some of the treatment compound onto the parkland to treat dissolved metals in groundwater immediately adjacent to the foundry property.
With the source now controlled, IRWIN had to evaluate the ecological and human health risks to in both upland areas and the wetland. The areas subject to assessment were designated as Protected Open Space and, and part of the Natural Heritage and Endangered Species Program (NHESP) Estimated Habitat of Rare Wildlife in Wetland Areas. The investigation area also included space under the jurisdiction of the local Conservation Commission, an area of historical importance, and subject to permitting from the state agency that owned and managed the parkland. IRWIN was able to navigate the permitting processes for these various authorities, and implement an exhaustive assessment program with minimal impact to natural resources.
Initial results indicated that elevated levels of metals were present in the wetland area (surface water and sediment) as well as surface soil in upland areas near the storm water outfall leading from the foundry. With a gamut of metals exhibiting elevated concentrations, some of which were used only sparingly in foundry operations, IRWIN performed several background evaluations that eliminated some metals as Contaminants of Concern as they were found to consistent with Site-specific background conditions.
IRWIN planned and implemented a sediment toxicity testing program including benthic macroinvertebrate enumeration and toxicity testing, as well as a variety of chemical analyses of sediment and surface water. The findings indicated that the wetland ecology had not been adversely impacted by the metals. However, with elevated concentrations of metals in upland soils, risk to the upland ecosystem could not be ruled out. This was based on ecological modeling of metal transport from invertebrates in the surface soil through the food chain to birds and mammals.
The physical removal of the impacted soil would have entailed a moderate disturbance to the upland system. In addition, permitting and logistical issues would have been costly, if not prohibitive. Instead of relying on the ecological modeling results, IRWIN collected Site-specific data of metals in upland macroinvertebrates to evaluate food-chain transport. These results indicated that there was not an active metals transport mechanism through the ecosystem. IRWIN willingness and ability to scrutinize the assumptions in established ecological models saved the client up to $500,000.
Throughout the entire Ecological Risk Characterization process, IRWIN was able to satisfy complex permitting requirements, thoroughly assess a complex ecosystem with endangered species, and demonstrate that there were no adverse risks associated with existing metals concentrations. Ultimately, our approach avoided disruption to an ecosystem that was shown to be healthy, and saving our client significant amounts of time and money.
Site Investigation and Remediation (Cont’d)
Covenant not to Sue – Former Industrial Manufacturing Complex
A developer was evaluating the economic development potential for a 275 acre property including nearly 1 million square feet of industrial manufacturing complex situated on roughly half the land. The seller had moved most of its business units out of the country and the work force was only 10% to 15% of historic peak operations. Complicating any redevelopment was the presence of a massive, chlorinated solvent plume in both shallow and bedrock aquifers which represented a major concern for liability upon acquisition of the property.
In this case, the Responsible Party selling the property was conducting the ongoing remedy implementation. Using the innovative instrument of a Covenant Not to Sue provided a means to separate the new buyer, and future buyers, from certain liability for the environmental cleanup. IRWIN and the client met with the Massachusetts Attorney General’s office and prepared the technical supporting documents for application to obtain the Covenant Not to Sue. This effort included the conduct of a Phase II Assessment addressing a variety of historical environmental conditions including sampling of soil, groundwater, and building surfaces as the Covenant Not to Sue requires appropriate due diligence to discover existing environmental conditions. Of note, there are currently less than 20 Covenants Not to Sue in Massachusetts.
The developer was proposing to subdivide the industrial portion of property and market the individual buildings to tenants or buyers and to construct a residential development on the undeveloped portion of the property bringing jobs and affordable housing to an economic development target area. With the Covenant Not to Sue in place, the developer was able to successfully invest in construction of a new building for an anchor tenant and attract other tenants to occupy existing buildings, and then to sell the occupied parcels. IRWIN participated in the discussions with prospective buyers in order to educate them about the environmental conditions on site and the impact of the Covenant Not to Sue on prospective liability.