Environmental Assessments

 

Hazardous Materials Management, Recycling, Site Assessments and Annual Environmental Assessments that minimize risk and put clients in control.

 

Hygieneering offers:

 

  • Hazardous material management, recycling, site assessment and removal services for schools, commercial buildings, hospitals and general industry.

  • Hazardous material management services include: hazardous material identification, written procedures for disposal and disposal services.

  • Recycling programs that assist in sorting and disposal of lighting fixtures/bulbs and batteries and other specialty waste recyclable products that can build USGBC LEED certification credits.

  • Site assessments including Phase I, Phase II Site Assessments and Phase III Remediation work to support property transactions, new construction projects, project cost estimates and site closures.  Annual Environmental Assessments are a risk management tool for property managers and portfolio managers to ensure light industrial tenants are controlling and managing environmental risks to preserve real estate asset values.

 

 
Air Permitting

 

Air Permitting Permit Procurement

  • Construction & Operating

  • NSR/PSD

  • RESOP (Synthetic Minor)

 

Regulatory Compliance

  • NSPA (New Source Performance Standards)

  • NESHAPs (National Emissions Standards for Hazardous Air Pollutants)

  • MACT (Maximum Available Control Technology)

  • RACT (Reasonably Available Control Technology)

  • BACT (Best Available Control Technology)

  • LAER (Lowest Achievable Emission Rate)

 

Additional Services

  • Permitting strategies to meet company objectives and reduce burden

  • Regulatory analysis and applicability

  • Annual Emission Report (AER) and Toxic Release Inventory (TRI) submittals

  • Continuous Emission Monitoring System (CEMS) QA/QC Plan generation

  • Agency representation and N.O.V. negotiation

  • Air emission inventories and regulatory audits

  • Air dispersion modeling

  • Air testing project management

  • Control device consulting

  • 112(r) Risk Management Plans

 

 
Phase I Environmental Site Assessments

 

Phase I Environmental Site Assessments, commonly referred to as Environmental Site Assessments, are often conducted for real estate property transactions, lending, and re-financing situations. Phase I Environmental Site Assessments are conducted to aid in significant business and risk management decisions associated with commercial real estate. The purpose of a Phase I Environmental Site Assessment is to assess a property for potential environmental liabilities based on current and previous property uses, review of environmental records, and a property site inspection. Sampling of building materials or subsurface sampling is not typically included with the standard scope of a Phase I Environmental Site Assessment.

 

Hygieneering, Inc.’s staff conducts Phase I Environmental Site Assessments in accordance with the American Society for Testing and Materials (ASTM) Standard E 1527-13 “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.” A Phase I ESA conducted in accordance to ASTM E 1527-13 meets the minimum requirements of the Environmental Protection Agency’s (EPA) All Appropriate Inquiry (AAI) Rule per 40 Code of Federal Regulations (CFR) Part 312. The goal in conducting a Phase I ESA on a property is to assess the property for the presence of “Recognized Environmental Conditions” (RECs), as defined under ASTM E 1527-13. Generally, a REC refers to conditions at a site that indicate a past, present, or threat of a release of hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property.

 

 
Phase II Subsurface Site Investigations

 

A Phase II Subsurface Site Investigation, commonly referred to as a Phase II, is often conducted after the completion of a Phase I Environmental Site Assessment (ESA) to confirm the environmental liabilities or suspect findings identified during the Phase I ESA process. Phase II Subsurface Site Investigations aid in significant business and risk management decisions associated with commercial real estate transactions, lending, and re-financing. Phase II Subsurface Site Investigations confirm whether environmental impact is present on a property through the sampling and laboratory analysis of soil and/or groundwater. A Phase II Subsurface Site Investigation includes, but is not limited to, the following tasks:

 

  • Evaluation of geologic conditions of the property.

  • Collection of soil samples on the property typically through utilizing drilling equipment.

  • May involve the installation of monitoring wells for the collection of groundwater samples.

  • Analysis of soil and/or groundwater samples for contaminant parameters. The contaminant parameters selected for analysis are based on site specific information and/or the suspect environmental findings obtained from the Phase I Environmental Site Assessment.

  • Interpretation of analytical results in comparison to applicable cleanup objectives adopted by the Illinois Environmental Protection Agency (IEPA) listed under the Tiered Approach to Corrective Action Objectives (TACO).

  • Preparation of a written report detailing Phase II activities, laboratory analytical results, and interpretation of analytical results for managing potential for risk at a property.

 

Once environmental findings are confirmed through the Phase II Subsurface Investigation, proceeding steps include establishing the extent of conditions and evaluating an appropriate remedial method. This remediation process may be conducted in conjunction with environmental regulatory programs, such as the IEPA’s Site Remediation Program (SRP). The SRP is an environmental cleanup program in which the IEPA provides oversight of investigations and cleanup activities. Once the full extent of subsurface contamination on a property is defined and remediated to conditions considered acceptable to the IEPA, the IEPA will issue what is referred to as a No Further Remediation Letter (NFR). The NFR letter signifies that remedial objectives and regulatory requirements have been satisfied.

 

Contact us for further information on Phase II Subsurface Site Investigations, the Site Remediation Program, or assistance with your environmental needs.

 

 
Underground Storage Tanks

 

Hygieneering offers technical expertise associated with UST requirements and regulations and has successfully managed the closure of USTs through the Office of the State Fire Marshall (OSFM) removal or abandonment-in-place process. Hygieneering also offers environmental consulting services pertaining to leaking USTs and has successfully managed remediation of leaking UST sites under the IEPA’s Leaking Underground Storage Tank (LUST) Program. The LUST Program oversees remedial activities associated with a petroleum release from a UST system.

 

Once the site has met its remediation objectives and requirements, the IEPA issues a No Further Remediation Letter (NFR) for the leaking UST incident. The NFR letter is signifies that remedial objectives and regulatory requirements have been satisfied.

 

Contact us for further information on how we can assist with your underground storage tank system needs.

 

 
Chemical Inventory Reporting Compliance

 

Are hazardous chemicals present at your facility? According to the Occupational Safety and Health Administration (OSHA), a hazardous chemical is defined as any chemical that causes a physical or health hazard. Under OSHA, the definition of a hazardous chemical is very broad and encompasses numerous materials. If hazardous chemicals are present at your facility in certain quantities, you may be required to reporting compliance to regulatory agencies.

 

The Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), establishes requirements regarding emergency planning and “Community Right-to-Know” reporting on hazardous and toxic chemicals. The Community Right-to-Know provisions help increase the public’s knowledge and access to information on chemicals at individual facilities, their uses, and releases into the environment. EPCRA regulations are codified in Title 40 of the Code of Federal Regulations, Parts 350 to 372. Below are some of the services offered by Hygieneering to assist with EPCRA compliance:

 

  • EPCRA 40 CFR, Part 355, Section 302 - This Part establishes requirements for a facility to provide information necessary for developing and implementing state and local chemical emergency response plans. This Part lists Extremely Hazardous Substances (EHSs) and the EHS Threshold Planning Quantities (TPQs), which are used in determining if a facility is subject to emergency planning requirements. A facility that produces, uses, or stores any of the 356 EHS listed under EPCRA 40 CFR, Part 355 in quantities above its TPQ, is required to submit a Section 302 Notice to the State Emergency Response Commission (SERC) and the Local Emegency Planning Committee (LEPC). In Illinois, the SERC is the Illinois Emergency Management Agency (IEMA). Note: a Section 302 Notice solely applies to EHS, and is a one time notification.

 

  • EPCRA 40 CFR, Part 370, Section 311/312 – This Part establishes reporting requirements for providing the public with important information on the hazardous chemicals in their communities. The reporting requirements established under this Part consist of Material Safety Data Sheet (MSDS) reporting and inventory reporting. Under the Occupational Safety and Health Administration (OSHA) regulations, facilities must maintain MSDS for any hazardous substance stored or used at the facility. In accordance to OSHA’s Hazard Communication Standard, a hazardous substance is defined as a substance for which a facility must maintain an MSDS. If MSDSs are maintained onsite, facilities must submit a Section 311 Notice, also known as a Tier I, to the SERC, LEPC, and local Fire Department. Facilties covered by Section 311 must also, under Section 312, submit an emergency and hazardous chemical inventory, also known as a Tier II report, to the SERC, LEPC, and local Fire Department by March 1 on an annual basis. If at any time a facility has 10,000 pounds or more of a hazardous substance, as defined under OSHA, a Tier II report must be submitted to the SERC, LEPC, and local Fire Department; if at any time a facility has an EHS that meets or exceeds the substances’ TPQ, a Tier II report must be submitted to the SERC, LEPC, and local Fire Department.

 

Contact us for further information on how we can assist with your hazardous substance EPCRA reporting requirements.

 

 
Water Quality Sampling

 

Have you ever wondered about the quality of your drinking water? The US Environmental Protection Agency’s Safe Drinking Water Act (SDWA) established health and safety standards for public water systems. The EPA regulates various contaminants in public drinking water supplies by establishing maximum contaminant levels, which are the highest level of a contaminant that is allowed in drinking water, via the National Primary Drinking Water Regulations, also known as Primary Standards. The EPA also established the National Secondary Drinking Water Regulations, also known as Secondary Standards, which are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (skin or tooth discoloration), aesthetic effects (undesirable taste, odor, or color), and technical effects (damage to water equipment or reduced effectiveness of treatment for other contaminants) in drinking water.

 

Hygieneering offers technical guidance for regulated and unregulated contaminants found in drinking water. Hygieneering provides drinking water quality testing services and comparative analysis to EPA’s Primary and Secondary Drinking Water Standards. Contact us for further information on how we can assist with your water quality needs.

 

 
Waste Minimization & Management​

 

  • What do I do with my leftover paint?

  • Are my spent solvents a hazardous waste?

  • I just cleaned out our warehouse, how do I dispose of all of the unwanted chemicals I found?

  • If I recycle my hazardous waste, is it still a waste?

  • How can I save money on my disposal costs?

 

Answers to questions like these can be difficult. The regulations which govern what you can and cannot do with the waste you generate, particularly those wastes that are considered hazardous, are complex and often confusing. Properly managing your wastes can be a frustrating, and at times a daunting task. Not doing so can result in unnecessary costs and exposure to regulatory violations and fines.

 

The hazardous waste regulations established under the Resource Conservation and Recovery Act (RCRA) require that you determine whether your waste is hazardous or not. You must also determine the amount of hazardous waste that you generate each month, as this determines your “generator status”. Your status defines the specific regulatory requirements applicable to your operation. These requirements may include such items as the length of time you can keep your waste before disposing of it, maintaining your waste containers, emergency procedures and planning, and personnel training. Also, your generator status can change depending on how much you generate in any given month.

 

Your state may have hazardous waste regulations more stringent than the Federal regulations. States also have regulations governing the management of wastes generated from commercial or industrial activities, even if the wastes are not hazardous.

 

Finally, minimizing your waste generation is, in certain situations, mandated by regulation, but it also makes good economic sense. Identifying viable opportunities for waste reduction requires an understanding of both the process that generates the waste, and the applicable regulatory framework.

 

How Hygieneering Can Help

 

Hygieneering provides a complete set of services designed to assist our clients in reducing waste generation and properly managing wastes that are generated in a compliant and cost-effective fashion. These services include:

 

  • Waste characterization, including sampling/testing services.

  • Compliance assessments to define the specific regulations applicable to your facility, based upon the types and quantities of wastes generated.

  • Regulatory submittals, such as requests for waste “generator” numbers and annual/biennial waste reporting.

  • Waste minimization

  • Emergency Procedures and Contingency Plans.

  • Waste Analysis Plans

  • Waste disposal services

  • RCRA training (as well as related OSHA HAZWOPER, and DOT training)

  • Closure and Corrective Action activities

 

Hygieneering can also develop a comprehensive hazardous waste management program specific to your Facility. Designed to assist you in properly managing the waste generated at your facility, it will incorporate many of the specific service items listed above. To accomplish this, we typically will conduct an initial waste assessment of your operations. This assessment will identify the processes that generate wastes, the types and quantities of wastes that are typically generated, and current waste management practices. Using this information, we will then outline the specific regulatory requirements applicable to your operations, and provide recommendations for addressing any areas of non-compliance. We will then design a management program specific to your business. The program will include protocols for minimizing waste generation and ensuring on-going compliance.

 

Benefits of a Waste Management Program

  • Regulatory compliance

  • Waste minimization

  • Reduced waste disposal costs

  • Loss prevention and reduction of potential liability

 

 
Brownfield Projects

 

The Environmental Protection Agency (EPA) defines a brownfield as "real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant."

 

Brownfields are often abandoned, closed or under-used industrial or commercial facilities, such as an abandoned factory in a town's former industrial section or a closed commercial building or warehouse in a suburban setting.

 

REGULATORY


The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 made the purchaser of any real property liable for any contaminants on this property. CERCLA's retroactive liability has made the performance of an Environmental Site Assessment (ESA) a practical necessity for any potential buyer of property, who naturally does not want to assume liability for the cleanup of any contaminants found there.

 

Because CERCLA mandated that the purchasers of property are now liable for any contamination on this property regardless of when they acquired the site, it also created the need for a method to determine whether or not a property was contaminated before any purchase of real estate was completed. CERCLA also provided an escape from liability called the “innocent landowner defense”, but this defense could only be used to escape liability if “appropriate due diligence” was conducted prior to the acquisition of the property. That why a purchaser should always conduct a thorough ESA.

 

There are many benefits of developing a brownfield site:

 

  • Cleans up past issues for future safe and productive uses

  • Financial Incentives:

    • USEPA grants funds, which assists to achieve a comprehensive goal. 

    • Tax Incentive Funding (TIF)

  • Redevelopment of a property can provide jobs to the community

  • Restoring land for reuse benefits the community

  • Broad-based community support, which translates into political support

 

How Hygieneering Can Help

 

Hygieneering’s ESA is a multi-step process:

  1. Phase I of an ESA includes research on current and former uses of the land, collection of all documents relevant to the property, and a non-invasive inspection of the site to determine the possibility of contamination on the property. The goal of a Phase 1 ESA is to determine if there is anything on the site that will require further investigation. 

  2. Phase 2 ESA is to resolve the issues presented by the Phase 1 study and, if present, delineate the nature and extent of any contamination on the property. This is a much more invasive process than the Phase 1 ESA and can include excavation, drilling, as well as sampling and analysis of soil and groundwater.

  3. The discovery of contamination on the property may trigger the need to for a Phase 3 ESA or detailed plan for the remediation of the site.

 

Not only will a Hygieneering’s Environmental Site Assessment evaluate your property’s condition, we can assemble a team for the redevelopment of the property.  To receive a free quote for an Environmental Site Assessment at your facility or for further information about our other environmental health and safety services, please contact our Director of Environmental Services, Bob Anderson using the info below.

 

For more information on any of our Environmental Services, click to contact Bob Anderson via email or call 630-706-6680.

To see examples of recent Environmental projects, click here.

Hygieneering, Inc. | 7575 Plaza Court, Willowbrook, IL 60527 | 630-654-2550 | info@hygieneering.com

© 2016 by Hygieneering, Inc.