ESTIMATING MONETARY COSTS AND LIABILITIES FOR ENVIRONMENTAL MATTERS

W&M experts Andy Adams, CHMM and Gene Murray, P.G. will host a fascinating look at the ASTM E2137-17 guidance on Estimating Monetary Costs and Liabilities for Environmental Matters. The webinar will be hosted by two W&M Environmental Group, a Division of Braun Intertec Corporation Principals with 50 years of combined cost and liabilities estimating experience. Cost and Liability estimating is an essential part of long term environmental investigation and cleanup, but is also used in many mergers, acquisitions, divestitures, and liability swaps. It is an essential piece of the Tiered process for Environmental Site Assessment, from identification through investigation and into remediation/cleanup. The ASTM guidance lays out a framework for cost estimating and provides the user with valuable information associated with environmental liabilities. The webinar will include a review of the ASTM guidance and the basic concept of the tiered process for Environmental Site Assessment, Evaluations, and remediation, and how
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Municipal Setting Designations

What is the most cost-effective way to address groundwater contamination? One cost-effective option is the use of a Municipal Setting Designation (MSD). An MSD is a state-approved deed restriction applied to a Site located within a municipality or its extraterritorial jurisdiction (ETJ) which restricts the use of groundwater for potable purposes. Any water used for drinking, bathing, cooking, or for the irrigation of crops is considered potable water. MSDs are commonly used in areas where shallow groundwater is not used and potable water is supplied by municipalities, and saves money by avoiding costly remediation. Additionally, MSDs may save time by closing sites sooner since remediation activities and subsequent groundwater monitoring could take years. Before pursuing an MSD there are a number of factors to consider that include: Does the local municipality have an MSD ordinance What are the chemicals of concern present in groundwater and what are the concentrations Is potable water
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Design With The Audience In Mind

When working on permits, plans, and reports for clients, we need to keep in mind how that material will be read and interpreted by our clients. They may be seeking environmental services because they don’t have the in-depth understanding of the programs, and, beyond just seeking someone to write reports for them, they need a way to understand and engage the material to upkeep their sites accordingly.  This can be essential to the client’s ability to stay compliant – if forms, documentation, and recordkeeping are essential permit requirements, they need to be user friendly to ensure they are completed accurately. While this may seem like a given, a basic concept that should already be occurring intuitively, we can all think of times we have had difficulty with understanding something because the materials were not designed with the audience in mind.  And the consequences of that poorly designed form, figure, or
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The Dreaded Words…We Are Being Audited!

It happens all the time: you hear about an audit (internal or external) and your brain starts racing and your “to do” list quickly double or triples in length and your blood pressure shoots through the roof. It doesn’t have to be that way. While touring facilities and conducting environmental, safety and health (EHS) audits over several years, I’ve identified several items that routinely appear as non-compliant findings that are things that you can tackle every day. These items, some minor and some major, have either been missed or overlooked or you simply just run out of time. A sample of these observations include:   Mislabeled/unlabeled waste and product containers Open waste containers Releases into secondary containment not removed promptly Missing/incomplete signage at waste storage areas Missing/illegible labels on power tools Improperly stored flammable products Damaged slings/lifting devices Missing/incomplete markings on cranes Improper storage of respiratory protection Prompt access to
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Spill Response – Failing to Plan is Planning to Fail

Releases, spills, and overflows……nobody ever wants to hear those words. However, despite the best precautions, accidents happen or systems fail, and you need to be prepared.  From the initial spill response, to the critical first 24 hours of Site activities, there is a lot to do and a lot to process. Are you prepared? Emergency response, spill response, and rapid response teams are critical pieces to be included in preparation for a potential future spill or disaster that a number of industries may encounter. For oil and gas facilities, metal manufacturing facilities, and even food manufacturers, the potential for a spill or disaster could occur at any moment. There are a number of regulatory agencies that govern spills or discharges in Texas. However, what they all have in common is that spills need to be reported, assessed, and remediated as soon as possible to reduce potential long-term issues or liabilities. When
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Can you hear me now?

That tagline from the phone company was omnipresent a few years ago and still gets some play now and again. But noise in the workplace is a serious thing. OSHA’s (the Federal Occupational Safety and Health Administration) permissible exposure limit (PEL) of 90 decibels (dBA) in an eight-hour day is equivalent to a “Boiler Room” and 10 dBA greater than a Freight Train 100’ away. But, is that level of noise too much? The European Union has been recommending much lower exposure levels based on studies that show that millions of Europeans have suffered irreversible hearing loss. I read the other day that noise contamination is the new smoking (I thought sitting was the new smoking). This observation was based on data that shows hearing loss is pervasive in our society and is, much like smoking, preventable. We are frequently asked to conduct noise surveys in the workplace by companies that
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Don’t Let Your Wastewater Knowledge Go Down The Drain

We all create wastewater every day, and for the most part, don’t give it a second thought. You wash your dishes and the water goes down the drain. You flush the toilet. You wash your car and the water runs off into the street or storm drain. But when a factory or industrial operation creates wastewater, it’s a different matter. Depending on how much wastewater is created and what types of pollutants or solids are involved, the business may need to obtain permits, build some type of wastewater treatment facility, or both. Failure to do so properly could create hazards to your employees, people in the community, wildlife, as well as the surrounding environment. Common types of wastewater and methods of dealing with wastewater issues including: Domestic wastewater from households & rural businesses Municipal wastewater from communities (sewage) Industrial wastewater from industrial activities Businesses call on W&M for assistance in handling the
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Oil On the Rise Means Due Diligence Is Wise

As the price of crude oil continues to slowly recover, topping over $60 per barrel over the last 6 months, increased activity in the Eagle Ford Shale and Austin Chalk is now more noticeable.  With increasing oil prices, opportunities to buy in to established fields are being evaluated and pursued by Oil & Gas exploration companies, operating companies, and investment firms.  A thorough Due Diligence review is a proactive strategy to assess early the assets in the evaluation stage when making a go/no go determination, and to understand future environmental risks. There are many factors that impact the evaluation of purchased property in this field.  A quick assessment can be completed to determine current conditions of equipment, operational history, compliance with regulatory guidelines, impact to natural resources, and tracking of environmental liabilities to name a few.  The completion of a Due Diligence review can identify the specific risks associated with an asset, and help identify a
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Money Laundering: The Legal Way That Makes Sense

OK, this is not a story about Russians or unscrupulous real estate moguls. Instead, we have recently been asked in two separate projects to “launder” money at banks, as in, clean the stacks of cash due to contamination. Most recently there was the case of a bank customer bringing in stacks of cash that were contaminated with fiberglass particles. There’s got to be a back story to that, but we can only guess as to the source of the fiberglass. We are not talking about a few bills, this was thousands of dollars. The fiberglass particles, which were not readily discernable to the staff, became airborne and caused respiratory discomfort to the employees and customers of the bank. We were able to come in and supervise the removal of the fiberglass particles using specialized vacuum cleaners and the bank was able to get back to business right away. The fiberglass
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Stormwater Compliance In Practice

The history of stormwater regulation dates all the way back to 1972 with the passage of the Clean Water Act (CWA) by the US Environmental Protection Agency (EPA). The CWA, and subsequent legislation over the years, is both the precursor and the framework for current stormwater permits today.  The laws were initially passed to create some control over the amount of pollution entering waterways through industrial stormwater runoff.  The EPA has given the Texas Commission on Environmental Quality (TCEQ) the authority to regulate stormwater permits in Texas.  The permit most commonly used by industry is the TXR050000 Multi-Sector General Permit. So what is a “sector?” The TCEQ has broken the TXR050000 permit down into industry specific sectors, from A through Z and on to AD.  Each sector covers a specific industry or group of industries.  You can find which sector you might fall into based on your SIC code.  With
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