U.S. Postal Service
Texas, New Mexico, Oklahoma, Louisiana, Arkansas, Arizona
Septic System Permitting

DPRA was contracted to identify all water supply sources and sewage disposal systems in Southwest Area Postal facilities and to determine their existing compliance and operating status. The information was used to evaluate each facility’s compliance status relative to the Safe Drinking Water Act and to assist in USPS decision-making for issues relative to water supply and on-site sewage disposal in Southwest Area Postal facilities.  The Southwest Area identified nearly 1,000 Postal Service facilities in the Southwest Area that have, or are suspected to have, on-site water well and/or on-site wastewater treatment systems.  The scope of this project was to identify all facilities in the Southwest Area with on-site water supply sources and sewage disposal systems, and provide expert analysis of the condition of such systems with recommendations for water quality sampling and the upgrade or repair of these systems to bring them into compliance with federal, state and local regulations.  DPRA conducted site visits at 347 facilities in six states.  The project approach implemented by DPRA included interview scope development, onsite personnel interviews, document collection and review, state and local regulatory review, photo documentation of the wells and sewage treatment systems, development of an access database with well and sewage system data, preparation of wastewater discharge permits for 36 Louisiana facilities, and development of a filing system for 314 facilities that includes fact sheets on the maintenance and operation of water wells and sewage disposal systems.

U.S. Postal Service
California, Florida, Washington DC, Maryland
Spill Prevention, Control, and Countermeasures Plans

DPRA has prepared numerous Spill Prevention, Control, and Countermeasures (SPCC) Plans for the U.S. Postal Service.  The purpose of the SPCC plan is to meet the regulatory requirements associated with the Clean Water Act Program and Federal Oil Pollution Control Act.  The steps taken by DPRA to prepare the SPCC Plans included conducting on-site reconnaissance to gather appropriate data necessary for plan development; modification of inspection procedures and checklists as needed to reflect current conditions.  The checklists and inspections were made to be “operator friendly” as much as possible by combining inspection items with other plans and inspection procedures currently conducted; preparation of the plan; and certification by  a licensed professional engineer.
U.S. Postal Service
Michigan, Illinois, Indiana, Missouri, and Wisconsin Proper Disposal Procedures for Pharmaceuticals
 
DPRA developed management plans for the U.S. Postal Service for the proper disposal of pharmaceuticals found loose in the mail for each of the five states located in the Great Lakes Area.  The disposal procedures included the issues of storage, transportation, required record keeping, special procedures in case of controlled substances, and possible disposal contractors which meet the state requirements to handle this type of waste.  DPRA provided a detailed management plan for all pharmaceuticals that can not be returned to the doctor, pharmacy, or manufacturer.  Under the work assignment, DPRA researched the regulations and pending regulations in each state and supplied a summary of requirements by state so that these requirements could be added to the Great Lakes Area Waste Management Plan.  All applicable regulations affecting the storage, transportation, record keeping, and disposal of pharmaceutical wastes were reviewed and summarized.  In addition, DPRA contacted state regulators, when necessary, to obtain the most accurate and up-to-date regulations and interpretations.  DPRA developed detailed pharmaceutical management plans for each of the five states in the Great Lakes Area.  This pharmaceutical management plans provided the USPS with a standard operating procedure for the management of pharmaceuticals that can not be returned to the doctor, pharmacy, or manufacturer.  The management plans included instructions for the handling, storage, transportation, record keeping, and disposal of pharmaceuticals.  When applicable, forms or log templates were developed and included to help USPS personnel comply with the regulatory requirements or guidance.  For states where there were potential pending regulations, the management plans were written in anticipation of these requirements.  In addition, many pharmaceutical products are characteristic or listed RCRA hazardous wastes.  If a state did not have existing or pending regulatory requirements or guidance specific to the disposal of pharmaceutical wastes, the waste management plan was written based on the applicable RCRA Subtitle C and/or state hazardous waste management requirements.  The pharmaceutical waste management plans were specific to pharmaceutical wastes but were structured to maintain compliance with the hazardous waste regulations.   Potential sources of non-state specific regulations and guidance include but are not limited to the US Environmental Protection Agency, the US Food and Drug Administration, and the Drug Enforcement Administration.
U.S. Postal Service
Throughout the United States
Storm Water Permit Survey/Data Collection
 
As part of a large-scale data collection effort, DPRA surveyed over 900 facilities across the United States to identify facilities that are regulated under the National Pollutant Discharge Elimination System (NPDES) and to capture permit and water discharge data.  The purpose of the survey was to determine whether regulatory requirements and costs associated with NPDES permits and Storm Water Pollution Prevention Plans (SWPPPs) for facilities can be eliminated or reduced using Best Management Practices (BMPs).  Furthermore, DPRA’s survey assisted the client in identifying and prioritizing water issues and actions.  To facilitate the project, DPRA developed a web-based electronic survey and database for collection, entry, and storage of the data.  DPRA assisted the client in developing a web-based water management tool and a Geographic Information System (GIS) to support the management of all aspects of the storm water program.
U.S. Postal Service
Pennsylvania, Maryland, and New Jersey
Storm Water Permitting and Preparation of Storm Water Pollution Prevention Plans (SWPPPs)
 
DPRA prepared Notice of Intent (NOI) forms, No Exposure Certification, and Storm Water Pollution Prevention Plans in accordance with the requirements set forth in the federal Clean Water Act, state environmental laws, and USPS policies and guidance for 36 US Postal Service facilities in Pennsylvania, Maryland, and New Jersey.  DPRA personnel conducted site reconnaissance at all thirty-six facilities and collected information on facility operations by interviews and file and record review.  DPRA prepared NOI forms for the USPS for submittal to the state agencies to allow each of the facilities to discharge a permitted industrial storm water flow from the facility by granting General Storm Water Industrial Permit Authorization. Additionally, DPRA evaluated facility conditions to determine whether the facility qualified for the no exposure certification for discharges of storm water associated with industrial activities.  In accordance with 40 CFR 122.26(g), a condition of no exposure at an industrial facility exists when all industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snow melt, and/or runoff.
U.S. Postal Service
South Carolina
Storm Water Utilities User Fee Legal Interpretation
 
DPRA performed a detailed legal analysis of South Carolina laws and regulations as they relate to storm water. The analysis focused on delegation of storm water authority to local counties and cities for the establishment of storm water programs and their methods of funding.  The analysis addressed the authority to establish storm water utilities and user fees or taxes to fund such utilities. DPRA developed a list of requirements the local authority is required to follow for compliance with state law when establishing a local storm water utility. Information gathering procedures included an in-depth study of the laws and regulations, personal contact with staff at the South Carolina Department of Health and Environmental Control (SCDHEC), Department of Water, and an Interpretation Request to SCDHEC addressing any and all inconsistencies.  DPRA compiled a list of all cities and counties in South Carolina that have enacted local storm water ordinances which have “user fees” or similar charges established pursuant to state statutes and regulations.  In addition, DPRA investigated all 46 county governments for storm water utility user fees.  DPRA also performed an analysis of each local ordinance by identifying the method used to calculate each fee and the method of invoicing for each locality. DPRA provided a legal evaluation of whether the fee was established in accordance with current South Carolina laws and regulations.

Railroad Client
Michigan, Minnesota, Ohio, and Pennsylvania
Storm Water Pollution and Spill Prevention/Response Training 

DPRA was retained by a railroad company to provide onsite environmental compliance training of railroad personnel.  Personnel were trained on the requirements of the NPDES multi-sector general permit, the potential sources of storm water contaminants, and the non-structural and structural preventive measures and source controls implemented at the facility pursuant to the Storm Water Pollution Prevention Plan.  Railroad personnel also were trained on the Spill Prevention, Control, and Countermeasures (SPCC) requirements of the federal Oil Pollution Act.  Training covered the content of the site-specific SPCC plans including designated locations of regulated oil storage, requirements for secondary containment, loading and unloading procedures, security measures, spill response measures, and reporting requirements.  Participants were provided detailed instruction on the location and use of spill response kits and compliance with applicable disposal restrictions on used spill response materials.

 

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