OUR COMPLIANCE EXPERTISE

Environmental Site Assessment – Phase I Audit

An Environmental Site Assessment provides an accurate evaluation of a property for Recognized Environmental Conditions. A site assessment is essential in identifying potential environmental liabilities of a parcel of land, building, or facility, as such liabilities can dramatically impact the economics of property transactions and highlight significant environmental conditions that any potential buyer, seller, or lender should be aware of.

Phase-I Site Assessment Includes:
  • Site visit of property and surrounding areas in order to assess general land use.
  • Visual inspection of the land for recognized environmental conditions such as fuel tank leakage, contamination of the land, etc.
  • Review of geological and hydrological data.
  • Assessment of the past and current usage of the property.
  • Review of local and state governmental records.
  • Summary report of findings, data and recommendations in accordance with ASTM guidelines

Spill Prevention, Control and Countermeasures Plan (SPCC)

In accordance with Federal Rules, 40 CFR 112.7 and 112.8, an SPCC Plan must be developed and implemented by any facility that operates more than 1320 gallons of above ground storage tanks (ASTs) containing petroleum products, including containers with a capacity of 50 gallons or more, or 42,000 gallons of completely buried storage capacity of petroleum products, except those that are subject to the technical requirements of 40 CFR Parts 280. An SPCC Plan is also required if a facility’s location could reasonably be expected to discharge petroleum products into or upon the “navigable waters” of the United States. Many facilities ignore this provision of the SPCC rule under the mistaken belief that it only applies to water-adjacent properties. But the definition of navigable waters is very broadly applied and can include not only large bodies of water such as oceans, lakes, or rivers, but also tributaries, wetlands, and even storm sewers -- basically any area that currently does or that may in the future share a hydrologic surface connection with any waters of the United States. In other words, every facility must comply with this section of the rule as well.

The plan comprises a responsible person’s contact information, hot line numbers for spill reporting (Local, State and EPA), a lay out of the facility detailing the tanks, products stored, capacity, direction and rate of the flow, predicted quantity of the spill, pipes and oil filling locations, drainage, secondary containments, spill control methods, procedure for preventing the discharge, response details including clean up procedure, disposal of waste oil, etc.

All petroleum containers must be tested for leaks. The plan must be signed by a licensed Professional Engineer. Periodic updating of the plan is required if any tanks were added or modified. Every 5 years, the plan must be reviewed and, if required, amended. A comprehensive training program must also be provided to all oil-handling personnel. The EPA assesses hefty fines for non-compliance with this rule.


Annual Emission Statements (AES)

The USEPA, after the establishment of the Title V of the Clean Air Act Amendment (CAAA), requires that all major emission sources comply with the fuel consumption and other operating standards as agreed to in the permit. This is done via an Annual Emission Statement which incorporates multiple data measurements, including the actual rate of emissions, estimated annual fuel consumption, the efficiency of control devices, and more. Failure to comply with this requirement is a violation of Air Pollution Control Act.

EES has prepared hundreds of AES for virtually every class of emissions source, and in multiple states. EES also has developed proprietary emissions calculations, which serve to save annual emissions fee.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Permit to Construct

No person or entity in the United States may produce or discharge any hazardous pollutants utilizing any air pollution source without first obtaining a permit. Such a permit is obtained through a federal, state, or local environmental regulatory agency depending upon the jurisdiction of authority. Some of the most common emission sources are paint spray booths, boilers, emergency generators, incinerators, fume hoods, underground storage tanks, ethylene oxide sterilizers, power plants, co-generators and other chemical plants. Successful permit application requires a thorough understanding of application procedures process and design criteria, and a qualified staff of licensed, professional engineers and industrial hygienists is required essential.

EES has 20 years of experience in navigating the permit application process and has built solid relationships with regulatory agencies to effectively negotiate on your behalf.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Certificate to Operate (CO)

Because a facility’s Permit to Construct is often based on engineering estimates, once completed, the engineer-of-record is required to inspect the facility and certify that the facility is in fact operating according to applicable regulations and design criteria. Any deviations from the permit estimates must be accounted for in order to determine risk or no threat to the Environmental Health and Safety (EH&S). An EPA approved risk assessments and other environmental studies are required to ensure EH&S.

EES is highly experienced in performing field inspections, certifications, risk assessments and finally obtaining certificates to operate for all emission sources.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Environmental Impact Statement (EIS)

An EIS is required for all actions which may impact environmental quality. Analysis of the existing air, waste, water, traffic and other criteria surrounding a proposed real estate development, building, a new plant, highway constructions, etc (Action) should be made, and incremental impact due to the Action should be estimated. Use of dispersion modeling and other state-of-the-art software are required to prepare a comprehensive EIS. The founding principal of EES has performed several of these including one for White Oak Lab (WOL), located in Silverspring, Maryland when FDA planned to relocate some of their key operations to the Naval Warfare Center of WOL. This work was carried out under the auspices of General Service Administration (GSA), Washington D. C.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Emissions Inventory & Title V Permits

The Clean Air Act (CAA) contains key provisions to control common pollutants which, at the time of the 1970 amendments, formed dense, visible smog in many of the nation’s cities and industrial centers. To protect public health and welfare nationwide, the law requires EPA to establish national ambient air quality standards based on the latest science, and requires states to adopt enforceable plans to achieve the standards. State plans also must control emissions that drift across state lines and harm air quality in downwind states. Congress designed the law to minimize pollution increases from growing numbers of motor vehicles, and from new or expanded stationary sources (i.e., power plants, industrial plants, and other facilities that are not mobile). The law calls for new stationary sources to be built with best technology, and allows less stringent standards for existing stationary sources. Sections 108 and 109 of the Clean Air Act (CAA) govern the establishment, review, and revision, as appropriate, of the National Ambient Air Quality Standards (NAAQS) for each criteria air pollutant to provide protection for the nation’s public health and the environment.

Essentially, the operators/owners of all emissions sources are required to perform a facility wide emission inventory. Depending upon level of emissions, appropriate application (major or reduced versions) will have to be submitted to the delegated authority (state regulatory agency). Several emission calculations for various scenarios will need to be done in order to identify and agree to most cost-effective permit conditions. EES has assisted several private and governmental facilities to comply with this rule.

For assistance in this regard or if you need additional information, please contact EES at kasi@eespc.com

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Air Quality Dispersion Modeling

Ambient air is continuously affected by pollution generated by automobiles, industrial and power plants, and all stationary combustion sources. The term “pollution” refers to the concentration of micrograms of any pollutant(s) in one cubic meter of air. The EPA identifies and sets limits for each pollutant. The criteria for pollutants is covered by the National Ambient Air Quality Standards (NAAQS) and includes regulation of toxic pollutants according to the level of incremental cancer risk.

The EPA has developed several computer models to test ambient air quality, including Screen and ISCST. Site-specific topographical information, design and emissions data, meteorological conditions, and other factors are used in predicting the air quality impact of a facility. Air quality modeling is required as a part of Permit to Construct or EIS or for certain public hearings. This study serves to scientifically and quantitatively illustrate a facility’s impact on ambient air quality and improve the plant for proper compliance. In addition, this study helps to determine the required Stack Height in conformance with Good Engineering Practice (GEP) stack height analysis.


Medical Waste Management

Medical waste management is an essential requirement of the USEPA’s new medical waste disposal regulations for Hospital, Medical, and Infectious Waste Incinerators (HMIWI). The waste generated at healthcare facilities range from general, infectious, hazardous to radioactive materials. Based on a 1990 survey report to the US congress, hospitals account for 70% of the medical waste generated in the United States. This consists of approximately 20% of infectious, 75% general and 5% as other wastes. Healthcare facilities must identify and segregate wastes generated through contact with highly infectious diseases. This is necessary in order to:

  • Reduce handling or mishandling
  • Reduce waste volume that are otherwise considered infectious
  • Protect the worker from exposure
  • Reduce the cost of disposal
  • Reduce the toxic emissions from the combustion of waste
  • The healthcare facilities are therefore environmentally and economically obliged to evaluate their waste generation and waste management practices.

Further, the enactment of 40CFR subpart Ce -- the HMIWI regulations -- requires that a waste management program be incorporated and submitted for approval to the respective state regulatory agency. This program should, at a minimum, include management of sharps, summary of alternative medical waste treatment technologies, current and future trends relevant to medical waste disposal costs, analysis of waste reduction initiatives, coordination with a medical waste removal contractor, interviews with the various department heads, and follow up procedures. Segregation, minimization, source reduction, recycling and conversion of equipment and supplies, and adoption of alternate disposal systems must also be included in an effective waste management program.


Medical Waste Disposal & Incineration

Medical waste disposal methods include mechanical, chemical, on site incineration, autoclaves, and microwaves. The enactment of the EPA’s final HMIWI regulations forced many healthcare facilities to seek disposal technologies beyond incineration. These technologies are grouped into mechanical and chemical categories. Medical waste can be autoclaved and disposed of in municipal landfills. Certain wastes can be shredded in conjunction with other disposal technologies. There are some cost-saving advantages and capacity limitation disadvantages in pursuing alternates to incineration.

On site incineration units are required to comply with stringent regulations of HMIWI. These are summarized in 40 CFR part 60, subpart Ce. In addition, respective State regulations such as 6NYCRR part 219-3 are also mandated. Compliance with incinerator regulations requires the inclusion of air pollution control devices such as scrubbers, continuous emission monitoring systems (CEMS), and state-of-the-art burners which meet specific emission levels and design conditions. And of course, a permit from the respective state environmental agency is required to install any waste disposal unit.


Regulatory Violations Enforcement & Mitigation

Any operating emission sources found to be non-complaint with applicable federal, state, or local regulations will be subject to enforcements. The enactment of the Title V Rule forces every source to be proactive in its operations and to pre-determine permit restrictions. Failure to do so can result in violations and penalties as high as $1,000 to $25,000 per day. The EPA's environmental enforcement efforts not only correct and deter illegal conduct but maximize the redress of its consequences. Civil penalties, injunctive relief, and mitigation are the most common legal means through which the EPA recovers the economic costs of noncompliance, halts designated actions, and reduces or offsets the environmental harm caused by ongoing violations. In addition, the EPA makes a distinction between a simple violation, in which a regulatory violation simply exists, and a knowing violation, which indicates an intent to knowingly break the law. Understanding this distinction can mean the difference between paying a fine and facing a felony prosecution. EES works to bring our clients’ facilities into compliance, thus avoiding violations, but we also help clients with existing violations navigate the mitigation process. EES can negotiate settlements, represents clients at hearings, and protects our clients’ best interests in all we do.


Good Engineering Practice Stack Height Analysis

The ambient air quality in the vicinity of emission sources is affected by the nature of dispersion. The most impactful element of dispersion is the height of the stack. The parameters of the stack are determined by the height, distance, and type of nearby structures. USEPA approved procedures as outlined in GEP manual should be followed for determining adequate height in order to avoid the “wake” and “cavity effect “.

The staff at EES are fully knowledgeable in this area and have designed many stacks.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Risk Assessments & Management Plans

Incremental cancer risk arising from exposure to toxic pollutants discharged from any air pollution sources must be studied and compared with acceptable levels such as one-in-a-million standard. These standards and procedures are outlined in USEPA’s risk assessments documents. In general, air quality dispersion modeling, plant design data, and emissions information are required to perform risk assessments. A detailed study includes exposure analysis via soil ingestion, mother’s milk, dairy, vegetations, etc.

EES has performed several multi path health risk assessments and plans.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Building, Code & Fire Protection Assistance

EES assists clients in obtaining all necessary permits from local building and fire departments. We also negotiate and mitigate any violations issued by these agencies.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Dry Cleaning Facility Inspection (NYS-Third Party/P.E)

In May 1997, NYSDEC implemented a regulation called NYCRR Part 232 which primarily targets the reduction of Perchloroethylene emissions from all dry cleaning facilities. This rule follows guidelines established by the EPA’s CAAA, OSHA, NFPA, NIOSH, RCRA, CERCLA, NESHAP and CWA. All facilities need to comply with this rule or face severe penalties. In order to demonstrate compliance, a qualified Professional Engineer, trained and NYSDEC certified individual must inspect and certify the facility as per Part 232.16.

EES staff is qualified to perform such inspection.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Lead Based Paint Sampling, Inspection and Risk Assessment

The Presence of Lead in Pre 1970, Federally Assisted Buildings (Housing Authorities) must be determined and appropriately removed as per Title X. EES is Certified by USEPA pursuant to 40 CFR Part 745.226 and HUD Guidelines to conduct lead-based paint activities. EES staff are certified Inspectors and Risk Assessors. EES is also licensed to own and operate XRF instruments.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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Design Engineering & Contract Documents

EES can design, engineer the following equipments which are specific to meet the client requirements:

  • Boilers & Wood Burning Furnaces
  • Continuous Emission Monitors
  • Emergency Generators
  • Fume hoods
  • Scrubbers
  • Medical Waste Treatment Systems
  • Underground Storage Tanks
  • Paint Spray Booths
  • Ethylene Oxide Sterilizers
  • Incinerators
  • Co-Generation Plants

We can prepare bidding documents, assist bidding process and contract award. We will also provide construction management support.

For assistance in this regard or for additional information contact EES at kasi@eespc.com

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CONTACT US


  EESPC - HQ
   Address : EES, P.C.,

1106 Main Street,
Peekskill, NY 10566

Reg : + 914-788-4165

Fax : + (914) 788-7121

Mail : kasi@eespc.com
Business Hours : 8:30AM - 5:00PM

   NORTH CAROLINA
   Address : 1150 Revolution Mills Drive

Greensboro, NC 27405

Reg : + 336-738-3410

Fax : + (336)-738-3411

Mail : muni@eespc.com
Business Hours : 8:30AM - 5:00PM

  INTERNATIONAL AFFILIATION
   RKEES Pvt. Ltd. - INDIA

Address : 1408, VBS Rajan Street Kanathur, Kanchipuram - 603 112, Tamil Nadu, India

Reg : + 914 600 5550

Fax : + (91) 2744 4378

Mail : lakshmi@rkees.com
Business Hours : 8:30AM - 5:00PM (EST)

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