NovelEsolutions, Inc.

Engineering | Environment | Earth

About

NovelEsolutions, Inc. is licensed and staffed to provide comprehensive environmental services for public and private sector clients. Environmental services include activities from permitting, compliance audits, waste management, and environmental assessments, to site remediation, decommissioning and closure. Navigating the regulatory climate associated with environmental issues can be challenging without a professional and competent consulting firm as your guide.

NovelEsolutions, Inc. is here to expedite your environmental needs. Please call us to discuss your environmental needs at any time at 239.220.4138. A summary of environmental services and what they might mean for your site is provided below for your use.

Planning, Permitting and Compliance

Environmental planning comes in many forms. Sustainability Plans may look at the entire facility operations and provide methods for reducing a carbon footprint, increasing functionality, and creating a holistic vision for the company. A Recycling Plan may be put into effect as part of a larger sustainability effort or as a stand-alone green effort. Sustainability or Recycling Plans are great ways to help the environment and bring in eco-friendly revenue. Plans such as these are beginning steps towards programs, such as the Green Lodging Program or Clean Marina Grants offered by the Florida Department of Environmental Protection (FDEP).

Best Management Practices (BMPs) for storm and surface water management work to reduce pollutant loads and concentrations of constituents of concern. Implementation of Best Management Practices (BMPs) may bring a site into compliance or address a desire for sustainable procedures by the facility. Best Management Practices (BMPs) may be required as part of a permit needed for facility operations.

Permitting needs might include completion of an Environmental Resource Permit (ERP), a National Pollutant Discharge Elimination System (NPDES) Permit, or a Consumptive Use Permit (CUP). Permitting conducted on a routine basis during site investigations might include right-of-way (ROW) permits or off-site access agreements.

Compliance with onsite permits, hazardous waste or petroleum product management is required for a multitude of facilities. Storage tank compliance requires accurate record-keeping and maintenance of the integrity of the storage tank system. Designation as a Small Quantity Generator has its own record-keeping components and storage requirements. Permits such as a National Pollutant Discharge Elimination System (NPDES) have ongoing monitoring and Best Management Practice (BMP) requirements.

Assessment

Sometimes you may need to know if there are hazardous substances or petroleum products that may have adversely impacted a site. Often this information is useful when a property is being refinanced or purchased by a new buyer. In this instance, a Phase I Environmental Site Assessment (ESA) is conducted. The Phase I evaluation determines if there are Recognized Environmental Conditions (RECs) associated with the subject property. The Phase I scope includes a site walk, interviews, and review of historical information. The Phase I Environmental Site Assessment is mainly a desktop investigation.

If Recognized Environmental Conditions (RECs) are identified, an intrusive investigation may be considered appropriate. This Phase II Environmental Site Assessment (ESA) may consist of sampling of soils, sediment, groundwater or vapors from the property. The samples collected are sent to a Florida certified laboratory for analysis of constituents of concern. The scope of the Phase II is based upon information obtained from the Phase I investigation and provides additional information about the condition of the property.

If contaminants of concern are detected above the Cleanup Target Levels (CTLs) determined by the State regulatory agency, or Florida Department of Environmental Protection (FDEP), or Maximum Contaminant Limits (MCLs) as regulated by the Environmental Protection Agency (EPA), a Discharge Notification Form (DNF) may be required. Subsequently, a Site Assessment may be prepared under Chapter 62-780 of the Florida Administrative Code. The Site Assessment will determine the horizontal and vertical extent of the contaminants detected in the soil, sediment, groundwater or vapors. Site Assessment activities often include the installation of soil borings and monitoring wells. This formal Site Assessment is a larger document with regulatory requirements dictating the scope and deadline for submittal.

Federal agencies go one step further with their assessment as they are required to comply with the National Environmental Policy Act (NEPA). This may require submittal of an Environmental Impact Statement (EIS) or National Environmental Policy Act (NEPA) evaluation per the specific federal agency requirements. These assessments include specific components in excess of the requirements for a non-Federal facility.

Remediation

If impacts are identified that exceed State or Federal regulatory criteria, as applicable, active remediation may be required for site cleanup. Often concerned responsible parties choose to pursue remediation even if levels are below regulatory mandated cleanup concentrations. In situ methods where the contamination is treated in place or ex situ methods where the contamination is removed are evaluated with the responsible party and regulatory agency. A Remedial Action Plan (RAP) is drafted by a licensed Professional Engineer (PE) and submitted for approval by the regulatory agency. Prior to implementation, a Remedial Action (RA) Approval Order will be issued by the appropriate regulatory agency (e.g., Florida Department of Environmental Protection (FDEP)).

Operation and Maintenance

Operation and maintenance (O&M) refers to the routine inspection of an operating remediation system. O&M is typically conducted daily for three to five days after startup of a new system. These activities help to streamline the remediation of the contaminated media and adjust the system to meet site specific conditions. O&M may then be conducted weekly for the first month, and monthly thereafter depending on the requirements of the individual system. Complicated remediation systems or sites with discontinuous lithology may require more frequent visitation.

O&M activities typically include conducting routine maintenance on remediation equipment, collection of pressure and/or vacuum readings from equipment and monitoring points, and cleaning of filters, flow meters and remediation piping. Additional data collected from monitoring points might include dissolved oxygen or oxidation potential readings, depth to water, or groundwater sampling for constituents of concern (COCs) or biological parameters.

Monitoring

The state of Florida has standard Cleanup Target Levels (CTLs) for groundwater entitled Natural Attenuation Default Concentrations (NADCs). If constituents of concern are detected at levels below the Natural Attenuation Default Concentrations (NADCs), the site may qualify for Monitoring Only. In this type of cleanup activity, groundwater samples will be collected from onsite monitoring wells on a frequency of quarterly or semi-annually depending on the Monitoring Only Plan (MOP) agreed to by the responsible party and applicable regulatory agency.

Risk-based Site Closure

Maximum Contaminant Levels (MCLs) and Cleanup Target Levels (CTLs), determined by the Environmental Protection Agency (EPA) and Florida Department of Environmental Protection (FDEP), respectively, are based upon average site conditions and assumptions on human and ecological exposure. Actual site conditions may be more favorable to reduction of site contaminant levels that the average site conditions. In this case an argument can be made for modification of the Cleanup Target Levels (CTLs) or setting of Alternative Cleanup Target Levels (ACTLs) for the site. If warranted, a full Risk Assessment could be conducted to determine the site specific exposure scenarios and risk to humans and ecological systems. The Risk Assessment could also result in modification or lowering of the standard Cleanup Target Levels (CTLs). Risk Assessments are often completed in phases with each level increasing in detail, scope and costs to the project.

NovelEsolutions, Inc.

Engineering | Environment | Earth

Liza Grudin, PE President

Phone: 239.220.4138

Email: liza.grudin@novelEsolutions.com