Environmental Monitoring

Environmental monitoring covers a large field of testing.  The media include soil, groundwater, surface water, air, sediments, stormwater, and industrial wastewater.  The reasons for environmental monitoring are even more numerous.  From the regulatory side, it can be done for a permit application or exemption, a sanitary sewer pre-treatment ordinance, specific conditions of a permit, government regulated cleanups, investigation of spills or discharges, complaints from neighbors or employees, or regulatory citations.  In the non-regulatory area, it can be done to exercise due diligence as a Phase II Environmental Site Assessment, to prevent pollution, or to be proactive and demonstrate the company’s status as a good citizen who is concerned about the environment and the community.

environmental monitoring

There are two basic types of environmental monitoring.  The first type is done in situ (i.e., measured in the field directly on the sample media) most commonly with electronic meters, while the second type involves samples which are collected in the field and typically analyzed in a laboratory.  There are other types of readings taken in the field such as Secchi disks to determine transparency of surface water and visible evaluation of emissions from smoke stacks to determine the opacity of the smoke in comparison to allowable limits in air permits.

Samples can be discrete or grab samples or they can be composite samples collected over specified time internals or collected in proportion to the flow of a source.  Samples can be collected manually directly into the sample bottle or first into a sample collection device such as a bailer or vertical sampler which is then transferred into the sample bottle.  There are also automated samplers such as composite samplers and electric sampling devices such as peristaltic pumps, bladder pumps, and centrifugal pumps.  There are also samplers for specific tasks such as dredge samplers and corers for sediments and stack probes for air emissions.

Analysis of samples includes biological, physical, and chemical parameters.  Examples of biological analyses are benthic invertebrate identification, bioassays, zooplankton, and algal assays.  Physical analyses include particulate matter in air, turbidity (i.e., particulates in water), and temperature.  Chemical analyses include nutrients, pH, dissolved oxygen (typically done in the field, not laboratory), radioactivity, solvents, petroleum hydrocarbons, pesticides, inorganic chemicals, and organic chemicals.  Regulatory standards for these analytes can be found in various sections of Chapter 62 in the Florida Administrative Code (F.A.C., http://dos.myflorida.com/offices/administrative-code-and-register/) enforced by the Florida Department of Environmental Protection.  Specific air testing methods are found in various Parts in Title 40 of the Code of Federal Regulations (40 CFR,  https://www.ecfr.gov/cgi-bin/ECFR?page=browse.) enforced by the U.S. Environmental Protection Agency (EPA).

In designing environmental monitoring, first, the objective must be identified.  It may be to meet regulatory requirements, to complete due diligence, or to determine if there has been a release of pollutants.  After that, the scope of work must be developed to meet the objective.  That will involve identifying the frequency of monitoring, types of samples, methods, analytes, interpretation of results, and report of results.  Standard Operating Procedures should be followed to insure the accuracy and precision of the data.  Equipment calibrations, Chain-of-Custody forms, and Field Book records need to be part of the monitoring.  Analysis of the samples should be done by a laboratory certified by the Florida Department of Health (FDOH) and accredited by the National Environmental Laboratory Accreditation Program (NELAP).  If the monitoring is not done in this manner, the results may be suspect, inaccurate, and inadmissable.

If it seems too daunting, Environmental Safety Consultants (www.escflorida.com) can help you with your environmental monitoring.  We are a Florida-licensed Engineering business with over 32 years of experience.  We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net).  Contact us today!

Industrial Wastewater Permits

Industrial Wastewater PermitsFlorida Department of Environmental Protection (FDEP) regulates wastewater discharges in Florida.  There are two types of wastewater, domestic and industrial.  Domestic wastewater is sanitary wastewater or sewage, while industrial wastewater is generally everything else.  Industrial wastewater can come from various sources.  These include manufacturing plants, industrial operations, construction, agricultural production and processing, commercial businesses, car washes, food processing facilities, ready mix concrete plants, boat repair yards, marinas, petroleum and solvent cleanup sites, mines, and more.

 

To be regulated, the discharges must have pollutants in them and be discharged to waters of the State (or to groundwater, which is not the focus of this article) or have a reasonable expectation to be a source of water pollution.  Waters of the state include rivers, streams, lakes, ponds, estuaries, bays, the gulf, and oceans.  Ditches that flow into these waters are included.

 

The pollutants are identified in 62-302, Florida Administrative Code (F.A.C.).  They include organic matter and chemicals, metals, nutrients, solvents, petroleum hydrocarbons, particulates, pesticides, radioactive materials, and more.

 

All industrial wastewater permits stem from the federal Clean Water Act enacted by the U.S. Congress in the 1970’s and implemented by the U.S. Environmental Protection Agency (EPA, www.epa.gov) under its National Pollutant Discharge Elimination System (NPDES).  In Florida, the NPDES regulations are implemented by FDEP (www.flwaterpermits.com).   Usually, the local FDEP District Office is the permitting authority.  Sometimes, it is a county environmental office and for a couple of permit types, it is the State FDEP Office in Tallahassee.

 

There are NPDES permits for point sources (e.g., discharge pipe from a manufacturing plant) and nonpoint sources (i.e., stormwater runoff).  In this article, we are focusing on point sources.  Regardless of that, FDEP issues one NPDES permit for the facility which serves as both the state and the federal permit.

 

Not every facility needs an individual industrial wastewater permit.  There are general or generic permits which cover common facilities with similar operations, pollutants, controls, and discharges.  These are available for concrete ready mix facilities, tomato wash operations, laundromats, fish farms, sand and limestone mines, fresh citrus wash water, and car wash systems.

 

The first step is to determine if you are discharging to waters of the State and if the discharge contains pollutants.  After that, you will need to calculate volumes and concentrations of pollutants in the discharge.  Testing may be required to determine the concentrations.  The testing may require a simple grab sample or may require a sample composited over 24 hours or more.  A state certified lab will be required to analyze the samples.  A Chain-of-Custody form will be required to follow the sample bottles from the laboratory shipping the empty bottles through sample collection, transportation, and submission to the laboratory.  While you may save money collecting the sample yourself, it pays great dividends to have a trained environmental scientist or engineer collect it.

 

Whatever your needs are, Environmental Safety Consultants (www.escflorida.com) can help you evaluate your operation, test your discharge, and apply for your industrial wastewater permit.  We are a Florida-licensed Engineering business with a Professional Engineer (P.E.) on staff.  We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net).  Contact us today!

Air Emissions Permits

Certain businesses often ask us at Environmental Safety Consultants if they are required to apply for air emissions permits.  The Air Emissions Permitsanswer depends on what types of equipment they operate, what chemicals they use, and what kinds of pollutants they generate.  Although the State of Florida reserves the right to permit any sources of pollution, it does not want to get bogged down with a multitude of small or “de minimis” sources.Why then are sources such as paint spray booths, dry cleaners, and fiberglass spa manufacturers regulated?  The answer lies in the pollutants generated.  Certain chemicals such as methyl ethyl ketone (MEK) in paint or solvents, tetrachloroethylene or perc used in dry cleaning, and styrene in fiberglass manufacturing are categorized as hazardous air pollutants (HAPs) by the U.S. Environmental Protection Agency (EPA).  You can find information on the EPA at www.epa.gov.These chemicals present a higher risk to human health than others and, consequently, are regulated more strictly.  Beyond HAPs, those sources that can generate a significant nuisance such as blowing dust, paint overspray, metals, or fuel odors are also targeted for permitting.  General usage of solvents and chemicals inside a facility can require an air permit for fugitive emissions since there is no single emissions point such as a smoke stack.

Obtaining an air emissions permit for a source, even a small one, can be a lengthy, complicated, and expensive process for any business.  Fortunately, there are some less harrowing alternatives for certain sources.  Additionally, modifying the process or substituting less hazardous materials or chemicals may eliminate the need for a permit or may simplify the permit.  Reducing the amount of material escaping to the atmosphere can drop a source’s emissions below a permitting threshold.For common sources with similar operations, there may be a general permit available with less rigorous application and compliance requirements.  To determine permit requirements, businesses must review their operations, chemicals, controls, and pollutants.  With this information, they will be ready to determine permit requirements.

There are a few different types of air emissions permits.  Title V Permits cover the largest sources and are the most complicated to obtain.  For smaller sources which still require an individual permit, there is the Federally Enforceable State Operating Permit (FESOP).  Finally, there are General Permits for commonly encountered sources such as concrete ready-mix plants, crematories, and other facilities.For individual air emissions permits such as Title V Permits or FESOPs, the air permit application is a two-step process.  First, the Construction Permit application is submitted so the source can be constructed or installed.  After it is up and running, an Operating Permit application is submitted.  There may be inspections, engineering certifications by a Florida Professional Engineer (P.E.), and emissions testing required before the Operating Permit application can be submitted.  The Operating Permit will contain general conditions and specific conditions which can include record keeping, testing, and reporting.Permitting requirements all originate with the Clean Air Act (CAA) passed years ago by Congress.  EPA has promulgated regulations to implement the CAA.  Florida Department of Environmental Protection (FDEP) has passed its own state regulations to enforce the EPA’s federal regulations.  Check FDEP out at https://floridadep.gov.  Therefore, in Florida the FDEP is the air permitting authority.  So typically, the appropriate FDEP district office is contacted to determine permit requirements.  For some of the larger counties, the counties themselves are the permitting authority for the FDEP.  But, FDEP can tell you that.

So, there you have it.  A broad picture of air emissions permits in Florida.  Let us know at (941) 795-2399 if we at Environmental Safety Consultants can help you.  You will be able to breathe a lot easier!

Environmental Permits

Environmental PermitsEnvironmental permits are a big concern for many in Florida.  There are permits for wetlands, endangered species, air emissions, wastewater emissions, stormwater, sewer discharges, septic tanks, drinking water, solid wastes, hazardous waste facilities, and even more.  Developers, builders, banks, attorneys, manufacturers, industrial facilities, hospitals, crematories, municipalities, and many more have to deal with environmental permits.

The first step is to decide if your planned operation will require an environmental permit.  Second, you have to decide what part of the environment you may impact.  Next, you have to determine what the permits may be.  And, finally, you have to determine what agencies administer the permits.

There are several key agencies which typically administer the various types of environmental permits.  These include the Water Management Districts, Florida Department of Environmental Protection, counties, cities, U.S. Environmental Protection Agency, and U.S. Army Corps of Engineers.  All of them have web sites and are generally helpful.

Environmental Safety Consultants can help you determine your needs and apply for your environmental permits.  We are just a call or an e-mail away.  Contact us at (941) 795-2399 or (727) 538-4154 today!