Institutional Control Project Descriptions
Site Investigation and Remediation
Waste Management
Permitting
Environmental Management Systems
Storage Tank Management
Water Discharge Management
Compliance Audits
Environmental Due Diligence
Emergency Planning and Community Right-To-Know
Site Investigation and Remediation
DPRA conducted a Phase I ESA then advanced over 70 soil probes, installed 30 monitoring wells, and conducted vapor and groundwater receptor surveys as part of the site investigation prior to site redevelopment. DPRA prepared a Remedial Action Plan recommending excavation and vapor extraction/air sparging and, following agency approval, prepared bid specifications, reviewed bids, and selected remedial contractors. DPRA performed excavation oversight, collected confirmation samples, and installed and operated the vapor extraction/air sparging systems. DPRA obtained a Certificate of Completion on schedule, allowing site redevelopment to occur as planned.
DPRA reviewed construction plans and conducted a Phase I ESA to identify sites with the potential to impact soil and groundwater along a proposed roadway corridor. Following the initial due diligence effort, DPRA mobilized to the project site to advance soil probes adjacent to impacted sites and identify areas of contaminated soil and groundwater. In addition, DPRA prepared an Impacted Soil Contingency Plan that detailed contaminated soil screening, handling, and disposal methods for the contractor to follow during roadway construction. DPRA staff were on site to screen and segregate soil during construction and prepared a final report summarizing the soil handling and disposal techniques. Finally, DPRA obtained reimbursement for investigation and remediation costs for its client from a state petroleum fund.
Waste Management
On behalf of the USPS Great Lakes Area, DPRA researched regulations affecting the management of pharmaceutical waste. Based on our review of the regulations and USPS policy, DPRA prepared a Pharmaceutical Waste Management Plan for each of the five states in the USPS Great Lakes Area. The Waste Management Plans addressed the state-specific hazardous and non-hazardous waste management and wastewater requirements in the context of applicable USPS policies. A supplemental report summarizing the current and pending state and federal regulations and the local POTW regulations affecting the management of pharmaceutical waste was prepared as a reference for environmental management staff at the USPS. DPRA conducted research to determine the most cost effective, environmentally responsible, and compliant waste management methods to assist the USPS with the selection of acceptable waste management methods. The five Pharmaceutical Waste Management Plans were prepared as manuals for USPS facility personnel to use when managing pharmaceuticals encountered in the mail. The management plans included flow charts and detailed descriptions of each step of the approved pharmaceutical waste management methods. The management plans also included appropriate background and reference information including waste management company and USPS contact information necessary to implement sound decisions that are protective of human health and the environment.
Permitting
DPRA prepared Notice of Intent (NOI) forms, No Exposure Certification, and Stormwater Pollution Prevention Plans (SWPPPs) in accordance with the requirements set forth in the Clean Water Act and Pennsylvania’s Clean Streams Law, and USPS policies and guidance for 11 US Postal Service facilities in Pennsylvania. DPRA personnel conducted site reconnaissance at each facility and collected information on operations through interviews and file reviews. The submittal of NOI forms to the PADEP allowed the facility to discharge a permitted industrial storm water flow from the facility by granting General Storm Water Industrial Permit Authorization (PAG-3). 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).
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 (SWPPP) 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.
DPRA obtained an air quality construction permit for a nutra-ceutical facility in Nebraska. The facility encompasses approximately nine acres and consists of two natural gas boilers, two cooling towers, three solvent tanks, three solvent recovery units, grain load out operations, and one natural gas dryer. DPRA performed the potential-to-emit calculations, coordinated and participated in a meeting with the Nebraska Department of Environmental Quality (NDEQ), and submitted the completed construction permit application forms to the NDEQ.
Environmental Management Systems
DPRA conducted a review of Environmental Management System implementation at three representative facilities for a multi-facility, distributor of scientific instruments, equipment and supplies. The assessment was conducted in order to establish a baseline for EMS implementation within U.S. facilities and to determine actions required to conform to ISO14001. DPRA prepared an Assessment of Environmental Management Systems report detailing strengths, weaknesses, recommendations and an Action Plan presenting actions to address gaps identified in the assessment phase.
DPRA completed a comprehensive Assessment of Environmental Management System Requirements in August 2002 for the Southwest Area of the U.S. Postal Service. The assessment aimed to review environmental systems as they currently relate to USPS organization, operations, and management approach, consistent with ISO14001. Strengths and weaknesses associated with existing environmental initiatives were identified in conjunction with recommendations to achieve conformance with ISO14001 and suggested performance measures to demonstrate appropriate implementation. DPRA developed Action Plans to assist the USPS with implementation of high priority recommendations. Ten Action Plans were provided to the USPS with each providing a methodology to address gaps identified during the EMS assessment to conform to ISO14001 and to ensure that organizational environmental goals and objectives are fulfilled. Action plans were presented in order of recommended priority for implementation.
Storage Tank Management
DPRA investigated and cleaned up over 500 petroleum release sites in the past 15 years throughout the United States. A majority of these sites involve underground storage tank releases at gasoline service stations. These investigations are completed using a standard risk-based approach. This approach involves defining the extent and magnitude of the petroleum release, conducting vapor, groundwater, and surface water receptor surveys, evaluating the risk posed by the soil and groundwater contamination, and preparing a Remedial Investigation Report summarizing the results of the investigation. When necessary, cleanup technologies are evaluated and implemented. DPRA’s clients for these services include private companies such as BP Products (formerly Amoco Oil Company), SuperAmerica, Union Pacific Resources, Murphy Oil Company, Erickson Oil Products, Holiday, and Fleming Companies, along with public entities in state, county, and city government.
DPRA prepared Operation, Maintenance, and Management (OMM) Plans for aboveground and underground storage tanks at more than 100 facilities across the country and provided training to ensure their compliance with the local, state, and federal regulatory requirements for their regulated tank systems. The OMM Plans include applicable operation and maintenance information and required logs of observation. In addition, DPRA developed a hands-on training specific to the types of tank systems installed at the facilities. The training included a PowerPoint presentation and an outdoor demonstration of an existing tank system and its components and inspection/maintenance procedures. The training was developed to encourage participation by facility personnel and was developed in accordance with client policies and standards.
Water Discharge Management
A national client obtained the services of DPRA to identify all water supply sources and sewage disposal systems at their facilities in Texas, Louisiana, Arkansas, Oklahoma, New Mexico, and Arizona and to determine their existing operating status and compliance. The information collected has been used to evaluate each facility’s compliance status relative to the Safe Drinking Water Act and to assist in the client in decision-making for issues relative to water supply and on-site sewage disposal. The client identified nearly 1,000 facilities that have, or were suspected to have, on-site water well and/or wastewater treatment systems. DPRA provided confirmation of the presence of these systems and an analysis of their condition recommendations for water quality sampling and upgrade or repairs required to bring them into compliance with federal, state and local regulations. The approach implemented by DPRA included on-site inspections, personnel interviews, records collection and review, and regulatory analysis.
Compliance Audits
DPRA performed multi-media environmental compliance audits throughout the United States at approximately 200 mail processing and vehicle maintenance facilities over the past four years. The scope of the audits included reviews of activities subject to federal, state, and local environmental laws and regulations including requirements of the Clean Water Act, Clean Air Act, RCRA Subtitle C, RCRA Subtitle D, RCRA Subtitle I, TSCA, FIFRA, CERCLA, Endangered Species Act, and National Historic Preservation Act. State and local requirements also are covered as part of the compliance audit protocol. Each audit consists of an extensive site visit beginning with an entrance briefing where DPRA staff informs facility participants on the compliance review process. Following the entrance briefing, DPRA conducts a comprehensive tour of facility equipment, activities, and processes and a review of all related environmental compliance documents and records. DPRA also conducts formal and informal personnel interviews regarding compliance activities at the site. DPRA then develops written findings of noncompliance and a corrective action plan for obtaining compliance and for implementing additional pollution prevention measures. These are presented during on-site exit briefing where DPRA staff provide additional on-site training necessary to meet compliance standards. Following each audit, DPRA documents audit activities and facility operations in a formal report including a summary of findings, pollution prevention opportunities, and facility corrective actions. After the report is finalized, DPRA conducts follow-up site visits or site monitoring to evaluate implementation of the corrective action plan and provide additional on-site training as needed.
Environmental Due Diligence
DPRA conducted a Phase I environmental site assessment on 12 telephone company properties prior to sale. The properties were occupied by offices, switching stations, warehouses, and equipment storage garages. Due to the large number of sites and limited time to complete the environmental due diligence tasks, DPRA conducted regulatory reviews, historical research, personal interviews, and waste characterizations to determine the magnitude of environmental concerns. DPRA used this information to prioritize site inspections and further reviews. During site inspections, DPRA detected water in several underground storage tanks, volatile chemicals in sumps, and confirmed the presence of asbestos-containing materials and PCB-containing equipment. DPRA recommended follow up tank tightness testing, soil and groundwater sampling, and asbestos surveys, and prepared a detailed cost estimate for addressing future environmental liabilities.
DPRA completed a Phase I environmental site assessment of T.H. 81 from Xerxes Avenue North to 85th Avenue North in Minneapolis, Minnesota, a distance of approximately 7.4 miles. The corridor included all properties within 300 feet of the curbs and endpoints of the segment. The purpose of the Phase I ESA was to identify to the extent possible, source of contamination (based on present or former land uses) that could impact the corridor. DPRA reviewed aerial photographs, fire insurance maps, city directories, and other historical sources, conducted file reviews at the state regulatory agency and at the city, and conducted a drive-by site reconnaissance. Based on this information, the properties encountered on the corridor were ranked high, medium, low, or unlikely, for their potential to impact subsurface or groundwater conditions at the corridor. DPRA used the findings of the Phase I to make recommendations for a subsurface investigation to determine the presence, magnitude, and extent of contaminated soil and/or groundwater along the corridor.
Emergency Planning and Community Right-To-Know
DPRA performed environmental compliance tasks at a plant that manufactures epoxy-based laboratory counter tops and plastic laboratory dishes. Four types of environmental compliance activities exist at this facility: air emissions, wastewater discharge, storm water runoff, and hazardous waste management. DPRA evaluated the status of the facility’s environmental reporting, permits, and operations and provided a letter that summarized future requirements and recommendations. DPRA completed the SARA 313 Form R for the facility and submitted the Form R to the Environmental Protection Agency. DPRA also mobilized to the site on various occasions and completed the monthly documentation and reporting required by the facility’s air permit. After completion of these activities, DPRA provided training to plant personnel that allowed them to perform these activities without assistance. DPRA also assisted the facility in obtaining appropriate air permit modifications, which allowed the facility to install new process equipment.
DPRA provided environmental compliance services for a laboratory equipment manufacturer that involved the preparation of monthly air emission reports for two facilities in Wisconsin. Air emissions data was recorded in accordance with air permit requirements and in order to ensure compliance with emissions limits. DPRA used the monthly records to prepare semiannual reporting of compliance in accordance with the air permits. DPRA collected and analyzed facility inventory and environmental data to determine the applicability of EPCRA Form R reporting requirements. For those materials that exceeded threshold quantities at the two facilities, DPRA prepared Form R reports to be submitted to the appropriate regulatory agencies, as well as supporting documentation for the facilities’ records.
Waste Management
Permitting
Environmental Management Systems
Storage Tank Management
Water Discharge Management
Compliance Audits
Environmental Due Diligence
Emergency Planning and Community Right-To-Know
Site Investigation and Remediation
DPRA conducted a Phase I ESA then advanced over 70 soil probes, installed 30 monitoring wells, and conducted vapor and groundwater receptor surveys as part of the site investigation prior to site redevelopment. DPRA prepared a Remedial Action Plan recommending excavation and vapor extraction/air sparging and, following agency approval, prepared bid specifications, reviewed bids, and selected remedial contractors. DPRA performed excavation oversight, collected confirmation samples, and installed and operated the vapor extraction/air sparging systems. DPRA obtained a Certificate of Completion on schedule, allowing site redevelopment to occur as planned.
DPRA reviewed construction plans and conducted a Phase I ESA to identify sites with the potential to impact soil and groundwater along a proposed roadway corridor. Following the initial due diligence effort, DPRA mobilized to the project site to advance soil probes adjacent to impacted sites and identify areas of contaminated soil and groundwater. In addition, DPRA prepared an Impacted Soil Contingency Plan that detailed contaminated soil screening, handling, and disposal methods for the contractor to follow during roadway construction. DPRA staff were on site to screen and segregate soil during construction and prepared a final report summarizing the soil handling and disposal techniques. Finally, DPRA obtained reimbursement for investigation and remediation costs for its client from a state petroleum fund.
Waste Management
On behalf of the USPS Great Lakes Area, DPRA researched regulations affecting the management of pharmaceutical waste. Based on our review of the regulations and USPS policy, DPRA prepared a Pharmaceutical Waste Management Plan for each of the five states in the USPS Great Lakes Area. The Waste Management Plans addressed the state-specific hazardous and non-hazardous waste management and wastewater requirements in the context of applicable USPS policies. A supplemental report summarizing the current and pending state and federal regulations and the local POTW regulations affecting the management of pharmaceutical waste was prepared as a reference for environmental management staff at the USPS. DPRA conducted research to determine the most cost effective, environmentally responsible, and compliant waste management methods to assist the USPS with the selection of acceptable waste management methods. The five Pharmaceutical Waste Management Plans were prepared as manuals for USPS facility personnel to use when managing pharmaceuticals encountered in the mail. The management plans included flow charts and detailed descriptions of each step of the approved pharmaceutical waste management methods. The management plans also included appropriate background and reference information including waste management company and USPS contact information necessary to implement sound decisions that are protective of human health and the environment.
Permitting
DPRA prepared Notice of Intent (NOI) forms, No Exposure Certification, and Stormwater Pollution Prevention Plans (SWPPPs) in accordance with the requirements set forth in the Clean Water Act and Pennsylvania’s Clean Streams Law, and USPS policies and guidance for 11 US Postal Service facilities in Pennsylvania. DPRA personnel conducted site reconnaissance at each facility and collected information on operations through interviews and file reviews. The submittal of NOI forms to the PADEP allowed the facility to discharge a permitted industrial storm water flow from the facility by granting General Storm Water Industrial Permit Authorization (PAG-3). 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).
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 (SWPPP) 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.
DPRA obtained an air quality construction permit for a nutra-ceutical facility in Nebraska. The facility encompasses approximately nine acres and consists of two natural gas boilers, two cooling towers, three solvent tanks, three solvent recovery units, grain load out operations, and one natural gas dryer. DPRA performed the potential-to-emit calculations, coordinated and participated in a meeting with the Nebraska Department of Environmental Quality (NDEQ), and submitted the completed construction permit application forms to the NDEQ.
Environmental Management Systems
DPRA conducted a review of Environmental Management System implementation at three representative facilities for a multi-facility, distributor of scientific instruments, equipment and supplies. The assessment was conducted in order to establish a baseline for EMS implementation within U.S. facilities and to determine actions required to conform to ISO14001. DPRA prepared an Assessment of Environmental Management Systems report detailing strengths, weaknesses, recommendations and an Action Plan presenting actions to address gaps identified in the assessment phase.
DPRA completed a comprehensive Assessment of Environmental Management System Requirements in August 2002 for the Southwest Area of the U.S. Postal Service. The assessment aimed to review environmental systems as they currently relate to USPS organization, operations, and management approach, consistent with ISO14001. Strengths and weaknesses associated with existing environmental initiatives were identified in conjunction with recommendations to achieve conformance with ISO14001 and suggested performance measures to demonstrate appropriate implementation. DPRA developed Action Plans to assist the USPS with implementation of high priority recommendations. Ten Action Plans were provided to the USPS with each providing a methodology to address gaps identified during the EMS assessment to conform to ISO14001 and to ensure that organizational environmental goals and objectives are fulfilled. Action plans were presented in order of recommended priority for implementation.
Storage Tank Management
DPRA investigated and cleaned up over 500 petroleum release sites in the past 15 years throughout the United States. A majority of these sites involve underground storage tank releases at gasoline service stations. These investigations are completed using a standard risk-based approach. This approach involves defining the extent and magnitude of the petroleum release, conducting vapor, groundwater, and surface water receptor surveys, evaluating the risk posed by the soil and groundwater contamination, and preparing a Remedial Investigation Report summarizing the results of the investigation. When necessary, cleanup technologies are evaluated and implemented. DPRA’s clients for these services include private companies such as BP Products (formerly Amoco Oil Company), SuperAmerica, Union Pacific Resources, Murphy Oil Company, Erickson Oil Products, Holiday, and Fleming Companies, along with public entities in state, county, and city government.
DPRA prepared Operation, Maintenance, and Management (OMM) Plans for aboveground and underground storage tanks at more than 100 facilities across the country and provided training to ensure their compliance with the local, state, and federal regulatory requirements for their regulated tank systems. The OMM Plans include applicable operation and maintenance information and required logs of observation. In addition, DPRA developed a hands-on training specific to the types of tank systems installed at the facilities. The training included a PowerPoint presentation and an outdoor demonstration of an existing tank system and its components and inspection/maintenance procedures. The training was developed to encourage participation by facility personnel and was developed in accordance with client policies and standards.
Water Discharge Management
A national client obtained the services of DPRA to identify all water supply sources and sewage disposal systems at their facilities in Texas, Louisiana, Arkansas, Oklahoma, New Mexico, and Arizona and to determine their existing operating status and compliance. The information collected has been used to evaluate each facility’s compliance status relative to the Safe Drinking Water Act and to assist in the client in decision-making for issues relative to water supply and on-site sewage disposal. The client identified nearly 1,000 facilities that have, or were suspected to have, on-site water well and/or wastewater treatment systems. DPRA provided confirmation of the presence of these systems and an analysis of their condition recommendations for water quality sampling and upgrade or repairs required to bring them into compliance with federal, state and local regulations. The approach implemented by DPRA included on-site inspections, personnel interviews, records collection and review, and regulatory analysis.
Compliance Audits
DPRA performed multi-media environmental compliance audits throughout the United States at approximately 200 mail processing and vehicle maintenance facilities over the past four years. The scope of the audits included reviews of activities subject to federal, state, and local environmental laws and regulations including requirements of the Clean Water Act, Clean Air Act, RCRA Subtitle C, RCRA Subtitle D, RCRA Subtitle I, TSCA, FIFRA, CERCLA, Endangered Species Act, and National Historic Preservation Act. State and local requirements also are covered as part of the compliance audit protocol. Each audit consists of an extensive site visit beginning with an entrance briefing where DPRA staff informs facility participants on the compliance review process. Following the entrance briefing, DPRA conducts a comprehensive tour of facility equipment, activities, and processes and a review of all related environmental compliance documents and records. DPRA also conducts formal and informal personnel interviews regarding compliance activities at the site. DPRA then develops written findings of noncompliance and a corrective action plan for obtaining compliance and for implementing additional pollution prevention measures. These are presented during on-site exit briefing where DPRA staff provide additional on-site training necessary to meet compliance standards. Following each audit, DPRA documents audit activities and facility operations in a formal report including a summary of findings, pollution prevention opportunities, and facility corrective actions. After the report is finalized, DPRA conducts follow-up site visits or site monitoring to evaluate implementation of the corrective action plan and provide additional on-site training as needed.
Environmental Due Diligence
DPRA conducted a Phase I environmental site assessment on 12 telephone company properties prior to sale. The properties were occupied by offices, switching stations, warehouses, and equipment storage garages. Due to the large number of sites and limited time to complete the environmental due diligence tasks, DPRA conducted regulatory reviews, historical research, personal interviews, and waste characterizations to determine the magnitude of environmental concerns. DPRA used this information to prioritize site inspections and further reviews. During site inspections, DPRA detected water in several underground storage tanks, volatile chemicals in sumps, and confirmed the presence of asbestos-containing materials and PCB-containing equipment. DPRA recommended follow up tank tightness testing, soil and groundwater sampling, and asbestos surveys, and prepared a detailed cost estimate for addressing future environmental liabilities.
DPRA completed a Phase I environmental site assessment of T.H. 81 from Xerxes Avenue North to 85th Avenue North in Minneapolis, Minnesota, a distance of approximately 7.4 miles. The corridor included all properties within 300 feet of the curbs and endpoints of the segment. The purpose of the Phase I ESA was to identify to the extent possible, source of contamination (based on present or former land uses) that could impact the corridor. DPRA reviewed aerial photographs, fire insurance maps, city directories, and other historical sources, conducted file reviews at the state regulatory agency and at the city, and conducted a drive-by site reconnaissance. Based on this information, the properties encountered on the corridor were ranked high, medium, low, or unlikely, for their potential to impact subsurface or groundwater conditions at the corridor. DPRA used the findings of the Phase I to make recommendations for a subsurface investigation to determine the presence, magnitude, and extent of contaminated soil and/or groundwater along the corridor.
Emergency Planning and Community Right-To-Know
DPRA performed environmental compliance tasks at a plant that manufactures epoxy-based laboratory counter tops and plastic laboratory dishes. Four types of environmental compliance activities exist at this facility: air emissions, wastewater discharge, storm water runoff, and hazardous waste management. DPRA evaluated the status of the facility’s environmental reporting, permits, and operations and provided a letter that summarized future requirements and recommendations. DPRA completed the SARA 313 Form R for the facility and submitted the Form R to the Environmental Protection Agency. DPRA also mobilized to the site on various occasions and completed the monthly documentation and reporting required by the facility’s air permit. After completion of these activities, DPRA provided training to plant personnel that allowed them to perform these activities without assistance. DPRA also assisted the facility in obtaining appropriate air permit modifications, which allowed the facility to install new process equipment.
DPRA provided environmental compliance services for a laboratory equipment manufacturer that involved the preparation of monthly air emission reports for two facilities in Wisconsin. Air emissions data was recorded in accordance with air permit requirements and in order to ensure compliance with emissions limits. DPRA used the monthly records to prepare semiannual reporting of compliance in accordance with the air permits. DPRA collected and analyzed facility inventory and environmental data to determine the applicability of EPCRA Form R reporting requirements. For those materials that exceeded threshold quantities at the two facilities, DPRA prepared Form R reports to be submitted to the appropriate regulatory agencies, as well as supporting documentation for the facilities’ records.