Project Profiles - Stormwater

 

A Boston-area scrap metal company was notified that an environmental watchdog organization planned to file suit for various violations under the Clean Water Act's citizen suit provision. GEC was retained by the scrap metal company to evaluate the applicability of the stormwater regulations, be part of the team responding to the notification, then develop a Stormwater Pollution Prevention Plan (SW3P), and implement the steps to achieve regulatory compliance.

 

GEC toured the site, and then prepared a SW3P. After this was reviewed a Notice of Intent was filed with the U.S. Environmental Protection Agency (EPA).   GEC facilitated employee training, began conducting facility inspections,  and specified Best Management Practices (BMPs) and engineering improvements to collect and treat on-site, stormwater that contacted various metals and contaminants.

 

In addition, GEC consulted with both our client's business and environmental attorneys to develop a mutually agreeable Consent Agreement and a plan for sustainable compliance.  GEC helped their client get into compliance, develop cost-effective engineering solutions, and avoid protracted litigation.

 

In another case, a Massachusetts scrap metal recycling company was facing a similar citizen suit for stormwater non-compliance under Section 505 of the Clean Water Act. The company decided to check their compliance. GEC was retained to perform a third party audit, and found that their recent facility upgrade included extensive stormwater engineering and Best Management Practices (BMPs) including: catch basins, berms, drain piping, oil-water separators, and infiltration equipment designed for a 100-year storm event. The system was designed to collect and treat all of the stormwater that fell onto the facility.

 

The third party audit verified to our client that their stormwater compliance was up to par and together with their environmental attorney, we helped our client avoid costly litigation.

Need offsets?

 

Oil, gold, and pork bellies are commodities traded on exchanges around the world.  So are renewable energy certificates (RECs) and carbon offsets.  They all can be purchased from various exchanges in the United States and around the world.  Having these exchanges provides an orderly marketplace with less volatility than barter transactions among individuals or companies.

 

If you work for an electric utility, you may already be involved with buying or selling.  A lot of companies that have installed solar energy have RECs.  REC can satisfy the regulatory and supply chain requirements for reducing greenhouse gas emissions.  As a result, RECs have become increasingly important.  For those looking to create a carbon-neutral company, event, or personal lifestyle, carbon offsets are commonplace.

 

Supporting renewable energy and reducing greenhouse gas (GHG) emissions are linked concepts that often get confused.  Obtaining RECs can reduce emissions if they are used to displace emissions that would have been created otherwise from electricity produced by a fossil fuel source such as a coal-fired power plant.  However, there are other benefits to clean energy such as energy independence, energy security and jobs.  RECs can also be used as a carbon management strategy, in some instances.  Using RECs and offsets can be an involved process.  We'd like you to benefit from our experience.

 

GEC's Sustainable Energy/Environmental Management Program (SE2MP) is a way to help you answer the key underlying questions and locate the full value for you and your organization before you:

 

1. Decide what emissions reduction and/or clean energy technology to support.

2. Baseline your electricity load and emissions.

3. Develop a budget based on your non-negotiables.

4. Determine what standard to use.

5. Communicate your purchase to the EPA, Green Power Partnership, The Climate Registry, DEP or your customers.

 

Contact Brian Donahoe to find out how to make these opportunities work best for you through GEC's SE2MP. Then, you can let your customers know that your company is actively supporting climate protection.

 

Risky Business

 

Risks can come from a variety of sources - from uncertainty in financial markets, project failures (at any phase in design, development, production, or the life cycle of materials), legal liabilities, credit risk, accidents, disasters and other acts of nature, as well as deliberate attacks.  In our business, most of the risks we consult on involve environmental or safety issues.  Risks are disruptive and managing risk can be tricky.

 

A large New Hampshire food distributor was fined $126,700 by EPA Region 1 for having "an inadequate risk management plan."  According to EPA, the plan lacked clear procedures to aid emergency responders in shutting down the distribution system and eliminating the hazard.

GEC has been helping our clients put together risk management plans that not only meet all the regulatory requirements, but assure that they are tailored to the particular needs of the facility.  Here are some of the things you should be noting.

• Specific actions that facility personnel must take in response to any emergency.
• Arrangements for emergency response by local emergency response authorities (e.g., fire and police departments, hospitals, local hazmat response teams). Name, address, and home and office telephone numbers of the facility's primary emergency coordinator.
• Name, address, and home and office telephone numbers of all other personnel qualified to act as emergency coordinator, listed in the order that each will assume responsibility as the emergency coordinator.
• Up-to-date list and location of all emergency response equipment at the facility, including a physical description of each item and an outline of its capabilities.
• Personnel evacuation plan.

Contact Neil Inglis ninglis@goldmanenvironmental.com, he can not only help you evaluate your plan; he can give you some insight on what the government inspectors are looking for and how to make sure your workforce risk management training program is effective.