Introduction to Contamination Assessments

That is what Contamination Assessments used to be called in Florida. But then they were renamed Site Assessments, which can be confused with Environmental Site Assessments (Phase I and II – see our other blog articles specific to those types of projects). To avoid confusion, we will stick with the name Contamination Assessment (CA). They became regulatory requirements in Florida in the 1980’s to primarily address contamination from underground and above ground fuel and oil storage tanks. These CAs are required when contaminant levels in the soil or groundwater exceed the State Cleanup Target Levels. They are designed to determine the extent of contamination in the soil and groundwater both horizontally and vertically. Often, the contamination is originally discovered during tank closure, after a leak, from a spill, etcetera.

Which regulatory agencies require the CAs? The lead agency is the Florida Department of Environmental Protection (FDEP, www.fdep.gov). However, several counties (primarily the larger urban centers) have a contract to administer the cleanup program for the FDEP. To determine if that is the case for your site, contact the district office of the FDEP which governs your county.

Which regulation requires CAs? Chapter 62-780 of the Florida Administrative Code (F.A.C.) does. All the detailed requirements are provided in that rule. For questions, contact the FDEP or county administering the cleanup program. The actual scope of work depends on the situation. Certain things affect the scope such as level of contamination, type of petroleum product, history, action taken to clean it up, and whether the soil, groundwater, or both are affected. Action taken could involve initial response, pumping out product, limited soil removal, and more.

Details of CAs will be discussed in another blog article. Just be warned that CAs usually take time. There are certain periods of time required to complete each step. You are given deadlines to complete things and the regulatory agencies have deadlines to review and respond to each document or response you submit. The whole process can easily drag into a year or more.

But for the moment, let’s say you have finished your CA and submitted it to the FDEP or county. What are the potential outcomes? First, additional work (i.e., more testing, information, or clarifications) may be required. Next, let’s say you hit the lottery and you receive approval for No Further Action – you are done! Alternatively, you do not hit the lottery and a Remedial Action Plan is required, followed by Remedial Action, and of course, another report. Finally, there is a low level of contamination which results in potential natural attenuation (the site cleans up on its own). In that case, you are required to complete Natural Attenuation Monitoring, which is done at regular intervals during each year for a two year or longer period of time.

So there you have it – a very brief introduction to Contamination Assessments in Florida. If you need any help, Environmental Safety Consultants (www.escflorida.com) can assist. We have the credentials and experience to answer your questions and steer you in the right direction. We are a Florida-licensed Engineering business with a Professional Engineer (P.E.), environmental scientists, and 30 years of experience completing CAs. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Why All The Fuss With Asbestos?

asbestos suit Well, the fuss with asbestos all comes down to health risks. Some of the potential outcomes are very serious – lung cancer, mesothelioma (i.e., cancer of the lining of the chest cavity), and asbestosis (a pulmonary obstructive disease that eventually puts such a strain on the lungs and heart, that the patient dies from cardiac arrest). The primary route of entry for these extremely small asbestos fibers is inhalation. Theoretically, these diseases can be caused by one exposure episode. However, the greater the dose, the greater the disease. And, finally, the diseases do not show up for ten to thirty years after the exposure. That is a very long latency period.

There are many misconceptions about asbestos. First of all, it is not just the ship workers who were exposed to it during World War II. Second, one does not have to be in a dusty asbestos cloud to experience an exposure resulting in disease. And, finally, it has not been asbestos testing banned from all materials in the United States. It has been banned in five to seven materials and it is still found in building materials being imported today. It is not always listed on the material, sometimes a label states that a product is non-asbestos when it is not, and sometimes it is labeled as asbestos free, but chrysotile (the most common type) is listed on the ingredients).

The mining of asbestos and manufacture of asbestos containing building materials represents potential exposure to the personnel involved. And sometimes, the workers bring the fibers home on clothing and shoes to their families. This reportedly occurred in Libby, Montana where asbestos was mined (www.pbs.org/pov/libbymontana).

So, which materials can contain asbestos? The U.S. Environmental Protection Agency (EPA, www.epa.gov) has a list of building materials suspected of containing asbestos. It virtually includes everything except glass, metal, and wood. Asbestos was added to thousands of materials due to its fire resistance, added strength, and chemical resistance. It is a relatively inexpensive naturally occurring mineral which was added to nearly all building materials, plus brake linings, concrete, cement drinking water pipes, and gaskets. It was used for fireproofing in schools, hospitals, airports, nursing homes, and other public and private installations and facilities.

asbestos workers Finally, workers who install, remove, or demolish it in buildings are at risk. That is why EPA requires testing for asbestos before all renovations and demolitions of most buildings before the work is started. If asbestos is present, certain abatement procedures will be required before the construction or demolition work begins.

But there is no reason to fuss. Environmental Safety Consultants, Inc. (www.escflorida.com) can help. We have the credentials and experience to properly complete your Asbestos Survey. We have accredited Asbestos Surveyors and a Florida Licensed Asbestos Consultant (LAC) on staff. We are a Florida-licensed Asbestos Business Organization with over thirty years of experience in the asbestos field. We prepare abatement specifications, monitor abatement projects, and complete air clearance monitoring. Whatever your asbestos needs are, just call us (800-226-1735 or one of our area office local numbers listed on our home page) or e-mail us (escinc@verizon.net). Contact us today and get rid of the fuss!

Phase II Environmental Site Assessments

So you had your Phase I Environmental Site Assessment (Phase I) done and Recognized Environmental Conditions (RECs) were found. You have decided to proceed with the transaction but you now need a Phase II ESA (Phase II) to fulfill your due diligence in determining if the site is or could be contaminated from usage of the site or properties in the vicinity. On the financial end, you and the seller have decided who will pay for the Phase II. This could mean that the seller will pay for it all, you will pay for it all, or the two of you will share the expense. Many times if you are paying any part of it, there is a proviso that the seller will reimburse you in full if contamination is found and you cancel the trans-action. The specifics are provided by your attorney.

The next step is to retain an environmental consulting firm to complete the Phase II. It may be the same firm that did the Phase I or a different firm. Not all Phase I firms complete Phase II’s. Qualifications, licenses, availability, and a myriad of other considerations may result in switching firms. However, if all things are equal, it is best to stick with the firm that did the Phase I. The reason is that they are most intimately involved in both the assessment of the site and the basis for the RECs they reported.

Whichever firm you select, there are a number of items to check out. You need to know how experienced they are in completing Phase II’s in general and, more specifically, in completing them on similar properties and similar contaminants. Ask for a Statement of Qualifications & Experience which will list Phase II projects completed, resumes of the staff, and engineering or geological licenses with the State of Florida. You can check these licenses out at www.myfloridalicense.com.

Phase II Once you have selected a firm, discuss the Scope of Work, turnaround, and terms. The Scope should be designed to specifically investigate the RECs that were found during the Phase I. This includes the media type and the contaminant types. The media may include soil, surface water, sediments, and groundwater. One or more of these media may need to be included. Types of contaminants include gasoline, diesel fuel, used oil, solvents, pesticides, heavy metals, and perc (perchloroethylene, a dry cleaning chemical), among others. There may be concerns with different contaminants in different locations on the site. These locations may have different media to be tested.

The Scope of Work should follow Standard Operating Procedures of the Florida Department of Environmental Protection (FDEP) for quality assurance and control. Additionally, make sure the firm is using a laboratory accredited by the National Environmental Laboratory Accreditation Program, NELAP (www.nelac-institute.org) and certified by the Florida Department of Health (www.floridahealth.gov). Otherwise, the data may not be court defensible or accepted by regulatory agencies in the event that those agencies become involved with the site. Similarly, make sure that if a Well Driller is involved that they are licensed by the FDEP (www.fdep.gov).

After all of this is done, request a Professional Services Agreement from the firm. This is the written contract between you and that firm. It must spell out the basis for the Phase II, the turnaround, Scope of Work, and Terms & Conditions. Review it closely and make sure it meets your satisfaction. Otherwise, request revisions before you sign it.

So you have retained the firm, they are ready to start the project, and you are done, correct? Not so fast. When you give them notice to proceed, you need to request that they keep communications open. Tell them that you want to know when the site work is scheduled, what the results are from the site work, what the significance of those results are, and what the analytical results from the laboratory are and what they mean. You may need to notify the seller of any significant findings as the work progresses. Finally, let the firm know that you need the report at the time specified in the Agreement.

Once you receive the report, review it closely, then call or meet with the firm to answer any questions or clarify certain sections. Keep in mind that there is no requirement to have the report submitted and approved by environmental regulatory agencies. However, some lenders and other entities use other environmental consulting firms or attorneys to conduct peer reviews of the reports. If significant contamination is found, then you or the seller should explore remediation options, which are the topic of another paper. At that point, you may cancel the transaction and look for another site. Your attorney must advise you.

Environmental Safety Consultants (www.escflorida.com) can make sure due diligence is exercised in completing your Phase II. We have the credentials and experience to properly complete the work. We are a Florida-licensed Engineering business with certified Environmental Site Assessors, a Professional Engineer (P.E.), environmental scientists, and 30 years of experience completing ESAs. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Be diligent and contact us today!

Phase I Environmental Site Assessments Can Save You

There are certain extremely important environmental considerations in commercial property transactions. The soil, groundwater, or surface water, may be contaminated with pollutants such as solvents, PCBs, dry cleaning fluids, petroleum products, pesticides, arsenic, etcetera. There may be buried drums or tanks of pollutants. Or a retention pond may be part of an industrial wastewater treatment system and may be leaking pollutants into the aquifer affecting nearby residents. environmental site assessment

The conditions above may create an economically significant, environmental liability for you as the buyer. Once you enter into the chain of ownership, you are potentially liable for cleanup costs in the future. That is called joint and several liability in legalese and it could bankrupt a business, cause a default on the loan, and affect the market value of the property.

However, the federal Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, aka Superfund, www.epa.gov/superfund) offers protection to the “innocent purchaser”. To qualify, a purchaser must exercise “due diligence” in determining whether a site is or could be contaminated. This is done by completing an Environmental Site Assessment (ESA) prior to the property transaction. The ESA is designed to determine if the property is or could be contaminated from past or current operations both on the site itself or on properties in the vicinity.

phase 1 assessment Environmental Site Assessments are conducted in phases. A Phase I ESA includes an inspection of the site and properties in the vicinity; review of environmental regulatory records, data, permits, and complaints; interviews of the buyer, seller, managers, and regulatory personnel; review of current and historical aerial photographs of the site and vicinity; review of environmental title search back to 1940; and review of nearby landfills, surface waters, and U.S. Geological Survey (USGS) topographical maps.

If the Phase I concludes that the site does not appear to be contaminated, you are done and can move on with the transaction. However, if it indicates that the site is or could be contaminated, then a Phase II ESA will be needed to test the soil, surface water, and groundwater to conclude the due diligence. But that is the topic of another paper.

The key to the ESA is exercising due diligence. Most purchasers of commercial properties retain environmental consulting firms to complete the ESA. Extreme care must be exercised in selecting the firm. It is not a situation where a penny saved is a penny earned. It can be more like a few hundred dollars saved can be thousands to millions of dollars lost.

As a consumer, you must make sure that the consulting firm has the experience, credentials, and qualifications to properly complete the ESA. This applies to the firm itself and to the actual staff members completing the ESA. Highly qualified principal consultants in offices miles away and not actually completing the ESA are of limited to no use.

Desired qualifications may include Professional Engineers, certified Environmental Site Assessors, and Professional Geologists. Of course, appropriate insurance coverage is a must. Check for inclusion of commercial general liability, professional liability, pollutant liability, workers compensation, and automobiles.

There is no requirement to have the ESA Reports submitted and approved by environmental regulatory agencies. However, some lenders and other entities use other environmental consulting firms or attorneys to conduct peer reviews of the Reports.

There are two ways that Environmental Site Assessments can help you. First, they can help you avoid acquiring contaminated properties. Second, if the ESA is completed properly and due diligence is exercised, Superfund is supposed to fund the cleanup if contamination is found later that could not be detected during the ESA. Ultimately, due diligence would be determined by the U.S. Environmental Protection Agency (EPA, www.epa.gov) or the courts.

Environmental Safety Consultants (www.escflorida.com) can make sure due diligence is exercised in completing your ESA. We have the credentials and experience to properly complete your Environmental Site Assessments. We are a Florida-licensed Engineering business with certified Environmental Site Assessors, a Professional Engineer (P.E.), environmental scientists, and 30 years of experience completing ESAs. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Be diligent and contact us today!

Groundwater Environmental Monitoring

One type of environmental monitoring is groundwater testing. This sounds simple enough, but exactly what is groundwater testing? Well, let’s break apart the term. Groundwater Environmental Monitoring

First, groundwater is water that is beneath the surface of the earth, as opposed to surface water which is on the surface of the earth. Sometimes, it is referred to as well water, the water table, or the aquifer. It is the source of water for springs.

Second, testing takes many forms. It can be done with the unaided eye, depth measurement tools, electronic meters, or samples analyzed in a laboratory. Testing done in the groundwater itself or on samples in the field is called in situ testing.

Samples can be collected manually or with automated samplers. Manually collected samples can be collected with bailers, bladder pumps, centrifugal pumps, or peristaltic pumps directly into laboratory sample bottles. The contents are then emptied into laboratory sample bottles.

Automated samplers can be programmed to collect samples at select time intervals over an extended period of time. Separate samples can be collected at each time interval or sample aliquots can be collected at each time interval and then be added to a large sample container to produce a composite sample.

Whether the samples are collected manually or automatically, generally, they are ultimately analyzed in a laboratory. They can be analyzed for biological, chemical, or physical parameters. In Florida, the laboratory should or must be accredited by the National Environmental Laboratory Accreditation Program, NELAP (www.nelac-institute.org) and be certified by the Florida Department of Health (www.floridahealth.gov). The data will not be accepted by regulatory agencies unless it is generated from one of these laboratories.

Why would you want to test the groundwater? There are lots of reasons. One is that you want to be proactive because you truly care or for public relations. For example, you may want to produce groundwater quality data that show your facility is not polluting the groundwater below or adjacent to your facility. Another reason may be for a groundwater remediation project, or to meet monitoring requirements under an existing Remedial Action Plan. Additionally, you may have had a spill or discharge and you are being required or you are volunteering to test the groundwater quality. In that case, you may need to determine if you have impacted the groundwater or if you have cleaned it up. Finally, you may be planning to introduce a new operation and need to establish current groundwater quality conditions so that the operation’s impact can be projected. After the operation is up and running, more testing can be done to determine if your projections were accurate.

If you do end up testing the groundwater, you will want to make sure that it is done properly and that the data are valid and court defensible. Otherwise, you may end up with credibility problems. Adverse publicity and scrutiny from the media and environmental watchdog groups is not worth it. Even if you truly have no impact on the quality of the groundwater, it may be perceived that you do because of faulty data.

This is where Environmental Safety Consultants (www.escflorida.com) can help. We have the credentials and experience to properly complete your groundwater environmental monitoring. We are a Florida-licensed Engineering business with environmental scientists, a Professional Engineer (P.E.), and years of experience testing groundwater quality. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Soil Environmental Monitoring

One type of environmental monitoring is soil testing. This sounds simple enough, but exactly what is soil testing? Well, let’s break apart the term. Soil Environmental Monitoring

First, soil is the upper part of the earth’s crust in which plants can sometimes grow. It may be sandy, loamy, clayey, rocky, shelly, or peat-like. Sometimes, it is referred to as dirt. It is what we walk on when we go outside where there is no pavement, decking, pavers, concrete, etcetera.

Second, testing takes many forms. It can be done with the unaided eye, electronic meters after mixing with water, organic vapor analyzers, or laboratory analysis. Testing done on the soil samples in the field is called in situ testing.

Samples can be collected manually or with powered equipment. Manually collected samples can be collected with spoons, augers, or dredges which are then transferred into bottles in the field for in situ testing or into laboratory sample bottles for analysis at the laboratory.

Powered equipment typically includes split spoon samplers or direct push rigs which collect the soil samples from desired depths. The soil is then transferred into the field bottles or laboratory sample bottles. The samples are then either analyzed in the field or at the laboratory.

Whether the samples are collected manually or with powered equipment, generally, they are ultimately analyzed in a laboratory. They can be analyzed for biological, chemical, or physical parameters. In Florida, the laboratory should or must be accredited by the National Environmental Laboratory Accreditation Program, NELAP (www.nelac-institute.org) and be certified by the Florida Department of Health (www.floridahealth.gov). The data will not be accepted by regulatory agencies unless it is generated from one of these laboratories.

Why would you want to test the soil? There are lots of reasons. One is that you want to be proactive because you truly care or for public relations. For example, you may want to produce soil data that show your facility is not polluting the soil below or adjacent to your facility. This could be related to the use or storage and handling of solvents, gasoline, diesel fuel, oil, pesticides, heavy metals, dry cleaning fluids, or many other chemicals. Another reason may be for a soil remediation project, or to meet monitoring requirements under an existing Remedial Action Plan. Additionally, you may have had a spill, discharge, or leak and you are being required or you are volunteering to test the soil for contamination. In that case, you may need to determine if you have impacted the soil or if you have cleaned it up. Finally, you may be planning to introduce a new operation and need to establish current soil conditions so that the operation’s impact can be projected. After the operation is up and running, more testing can be done to determine if your projections were accurate.

If you do end up testing the soil, you will want to make sure that it is done properly and that the data are valid and court defensible. Otherwise, you may end up with credibility problems. Adverse publicity or scrutiny from the media and environmental watchdog groups is not worth it. Even if you truly have no impact on the quality of the soil, it may be perceived that you do because of faulty data.

This is where Environmental Safety Consultants (www.escflorida.com) can help. We have the credentials and experience to properly complete your soil environmental monitoring. We are a Florida-licensed Engineering business with environmental scientists, a Professional Engineer (P.E.), and years of experience testing soil for contamination. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Surface Water Environmental Monitoring

One type of environmental monitoring is surface water testing. This sounds simple enough, but exactly what is surface water testing? Well, let’s break apart the term. Surface Water Environmental Monitoring

First, a surface water is a body of water on the surface of the earth, as opposed to groundwater which is beneath the surface of the earth. Surface waters include ditches, streams, creeks, rivers, springs, bays, ponds, lakes, rivers, gulfs, and oceans.

Second, testing takes many forms. It can be done with the unaided eye, depth measurement tools, Secchi disks, electronic meters, or samples analyzed in a laboratory. Testing done in the water body itself or next to it is called in situ testing.

Samples can be collected manually or with automated samplers. Manually collected samples can be collected directly into laboratory sample bottles or into mechanical collection bottles such as Kemmerer bottles which can collect samples at various depths. The contents are then emptied into laboratory sample bottles.

Whether the samples are collected manually or automatically, they are ultimately analyzed in a laboratory. They can be analyzed for biological, chemical, or physical parameters. In Florida, the laboratory should or must be accredited by the National Environmental Laboratory Accreditation Program, NELAP (www.nelac-institute.org) and be certified by the Florida Department of Health (www.floridahealth.gov). The data will not be accepted by regulatory agencies unless it is generated from one of these laboratories.

Why would you want to test the surface water? There are lots of reasons. One is that you want to be proactive because you truly care or for public relations. For example, you may want to produce water quality data that shows your facility is not polluting the receiving surface water. Another reason may be for an NPDES industrial wastewater permit application, or to meet monitoring requirements under a permit. Additionally, you may have had a spill or discharge and you are being required or you are volunteering to test the surface water quality. In that case, you may need to determine if you have impacted the receiving water or if you have cleaned it up. Finally, you may be planning to introduce a new operation and need to establish current water quality conditions so that the operation’s impact can be projected. After the operation is up and running, more testing can be done to determine if your projections were accurate.

If you do end up testing the surface water, you will want to make sure that it is done properly and that the data are valid and court defensible. Otherwise, you may end up with credibility problems. Adverse publicity and scrutiny from the media and environmental watchdog groups are not worth it. Even if you truly have no impact on the quality of the receiving water, it may be perceived that you do because of faulty data.

This is where Environmental Safety Consultants (www.escflorida.com) can help. We have the credentials and experience to properly complete your surface water environmental monitoring. We are a Florida-licensed Engineering business with environmental scientists, a Professional Engineer (P.E.), and years of experience testing surface water quality. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

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 Permits Florida 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 answer 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!