Compliance and Permitting

ENW has extensive experience working with regulators to achieve compliance and permitting goals for a wide variety of projects.  ENW’s regulatory knowledge is key to our reputation as a quality environmental consultant and the reason why we are extremely successful in achieving regulatory closure through the ODEQ and EPA.   As mentioned, ENW’s founder Mr. Lynn Green, was a former ODEQ regulator, and as such, has an excellent working knowledge of Oregon’s Environmental Laws and the Administrative Rules that promulgate them.  Mr. Green and ENW’s other principal and senior staff are well-known and respected at ODEQ.  Thus, ENW is able to work through regulatory issues with the ODEQ in a non-adversarial and very efficient way.  Another important aspect of ENW’s regulatory knowledge is that it serves to protect our clients by assuring that these environmental activities are in compliance with environmental law and rules, thereby avoiding the need to redo work with potential associated costly delays and fines.


Storm Water

ENW provides storm water monitoring, mitigation, permitting, and maintenance services for properties throughout Oregon and Washington.  Projects include the creation and implementation of SWPCPs (Storm Water Pollution Control Plans), evaluation of storm water systems along with mitigation plans (as needed), and ongoing storm water monitoring at regular intervals. 

ENW has also has experience assessing and bringing into regulatory compliance dry wells and other underground injection controls (UICs):

  • SWPCPs / SWPPPs (Storm Water Pollution Prevention Plans)/ SWIMP (Storm Water Injection Management Plans)

  • UIC Compliance

  • Mitigation

  • Monitoring

  • Maintenance

  • Permitting


Cleanup and Remediation and Feasibility Studies

ENW has performed cleanup and remediation services on a wide variety of sites including vacant, residential, agricultural, commercial, and industrial properties.  ENW has experience in obtaining regulatory closure through a variety of means including Independent Cleanup Programs, Voluntary Cleanup Programs, Risk-Based Cleanup Methods, Risk Assessments and consent orders.  We have successfully achieved regulatory closure on sites involving, but not limited to, USTs, ASTs, UICs, in-ground hoists, former gas stations, surface spills, subsurface releases, former landfill use, and pesticide/herbicide impacted agricultural land.  As former regulators, our professionals are intimately aware of environmental regulations and the data requirements to satisfy state environmental and natural resource agencies.   Our environmental professionals have a cumulative 20 years on the staffs of state and federal natural resource agencies, and a cumulative 15 years of experience working in the private sector for environmental engineering companies. 

Media impacts at these sites include: soil (both surface and subsurface), ground water, surface water, soil gas, sediment, indoor air and building materials.  ENW has successfully employed a broad array of remediation technologies to achieve cleanup levels and regulatory closure.  ENW’s current remediation projects employ excavation and landfill disposal of impacted soils, in-situ chemical oxidation (ISCO) to enhance natural attenuation of petroleum impacted soil and ground water, reductive dichlorination of ground water impacted with chlorinated solvents, soil vapor extraction (SVE), air sparging (AS), pump and treat (P&T) and sub-slab depressurization to mitigate intrusion of volatile hydrocarbons and radon.  Prior to conducting any remediation, ENW advises our clients to authorize the development of a conceptual site model (CSM), a beneficial water and land use determination, followed by an assessment of human health (and ecological risk, in limited cases) to determine if remediation is feasible and warranted.  If remediation is warranted, ENW carefully delineates the extent of contaminated media, conducts corrective action or RI/FS planning, prepares remediation design plans, prepares bid documents for distribution to subcontractors, guides our clients through the permitting process (including storm water and erosion controls), and assists our clients with waste profiling and presents disposal options. Remediation of contaminated building materials may be included in the work.  ENW is also adept at guiding our clients through the permitting process in accordance with SEPA and NEPA.  ENW frequently provides oversight of remedial and demolition activities and removal of associated hazardous materials.  In preparation for these activities, ENW has experience developing remedial action plans and feasibility studies.

Remedial Investigations / Feasibility Studies are typically conducted on larger cleanup sites, but don't necessary go hand in hand.  ENW has incorporated assessment of risk into its remedial investigations so that feasibility studies are designed to mitigate potential risk. 

Work performed for Remedial Investigations and Feasibility Studies have the following overall objectives: 

  • Identify the hazardous substances which have been released to the environment

  • Determine the nature, extent and distribution of hazardous substances in affected media

  • Determine the direction and rate of migration of hazardous substances, i.e., environmental contaminant fate and transport

  • Identify migration pathways and receptors 

  • Determine the risk to human health and/or the environment

  • Determine risk to ecological receptors

  • Identify whether there are any hot spots of contamination 

  • Develop the information necessary to identify and evaluate potential Interim Removal Measures

  • Conduct pilot tests of various remedial alternatives

  • Perform remedial action planning and implementation under independent cleanup, voluntary cleanup programs, and consent orders

Hazardous and Solid Wastes

As part of a risk-based cleanup project, contaminated media management is a key component in ensuring residual impacted media are properly handled and managed in the future. ENW has prepared numerous such plans that are in use today.

Investigation-derived waste (IDW) must be appropriately characterized, managed, profiled, permitted and disposed. IDW management is a topic of pre-field planning in every ENW investigation and cleanup. ENW recognizes that waste management can be one of the most significant costs in any investigation or cleanup.

NW is a believer in thorough pre-field contaminated media planning, and is adept at addressing topics such as:

  • Constituents of potential concern (COPCs) and how they were generated and released into the environment.

    • Special wastes such as petroleum

    • Federally listed hazardous waste regulated under the Resource Conservation, Recovery and Control Act (RCRA), characteristic hazardous waste, or contained-in hazardous wastes

    • Wastes regulated under Toxic Substances Control Act such as containing PCBs, pesticides or medical wastes

    • State-listed hazardous waste

    • Solid waste (household garbage, soil strippings, construction debris, sludges, etc.)

    • Hazardous building materials containing asbestos-containing materials (ACM), lead-based paint (LBP), mercury-containing lamps and switches, PCB-containing ballasts or transformer, etc.

    • Soil material qualifying as clean fill

    • Affected media, e.g., soil; water; UST, ASTs and appurtenant devices; transformer bodies; and non-hazardous building materials, etc.

    • Volume of waste generated, i.e., banked cubic yards, loose cubic yards, tons, gallons, etc.

    • Characterization data, profiles and permits

    • Storage and containment - length of time and manner of temporary waste storage in accordance with RCRA and other stipulations

    • Coordinating and manifesting transportation via dump trucks, trailers, bins or drums

    • Disposing of wastes at RCRA Subtitle C Hazardous Waste landfills; RCRA Subtitle D landfills; special fill sites, i.e., quarries, under Solid Waste Letter Authorizations (SWLAs) or permit exemptions; and liquid waste recycling facilities

    • Hazardous waste reporting



Compliance Audits

ENW is experienced with all aspects of environmental compliance and conducting comprehensive annual compliance audits and training in:

  • Air Quality Discharge Permitting – Air emissions inventory, air contaminant discharge permitting (general, small and large quantity), and air discharge monitoring.

  • Storm Water Discharge Permitting – General, general industrial (NPDES 1200Z), Storm Water Pollution Control Plan preparation, compliance monitoring, obtaining waivers for storm water benchmarks, and reporting.

  • Spill Prevention Planning – Spill Prevention Control & Countermeasure plan preparation, inspections of AST facilities and containment systems, proper labeling/placarding of every drum, tote and bulk tank with chemical name and NFPA code; and placement of NFPA placards at every exit.

  • Hazardous Materials Contingency Plan & Emergency Procedures – Contingency Plan or Emergency Response Plan preparation, hazardous waste generator classification, and safety guidelines and response procedures development if spills or releases of hazardous wastes occur.

  • Hazardous Waste Management – Annual Reports, hazardous waste classification, accurate labeling, recertification tests, Hazardous Waste and Toxic Use reductions, secondary containment, hazardous waste logs, and document waste characterization and disposal.

  • Wastewater – Wastewater discharge permit (WWDP) applications, zero wastewater discharge (ZWWD) program initiation, assistance to qualify as a Non-Significant Categorical Industrial User (NSCIU), wastewater reduction utilizing chemical treatments, recyclers, filters, evaporators, etc.

  • Chemical Inventory Reporting – Assistance with Form R self-reporting and audit policy eligibility checklist submissions to EPA; assistance with filing Hazardous Substance Survey reports to the Oregon State Fire Marshal.

  • Toxic Substances Control Act – Research EPA’s Toxic Substances Control Act certification status of proprietary lubricants.

  • Quarterly Audits – Assistance with self-imposed quarterly compliance audits.

  • Inspections –State agency audit preparation, e.g., ODEQ, to avoid violations and penalties; environmental action plan submissions documenting corrections in response to warnings.

  • Training – Annual SPCC and Hazardous Response Training to employees of a large medical manufacturing facility.



Permitting

ENW is accomplished in all manner of permitting associated with:

  • Disposal of hazardous and solid wastes

  • UST installation, decommissioning

  • ASTs:

    • Spill Prevention Control & Countermeasure

  • Storm water permits:

    • 1200z

    • UIC registration

    • Construction NPDES

    • SWPCP

  • Air contaminant discharge permits:

    • Simple ACDP

    • Regular ACDP

    • Permit modifications

    • Dust Collector permitting

    • Air dispersion modeling

Industrial/Commercial Wastewater

  • Monitoring - Semi-annual ZWWD reporting

  • Mitigation - Wastewater reduction utilizing chemical treatments, recyclers, filters, evaporators, etc.

  • Permitting – WWDP applications, zero wastewater discharge (ZWWD) program initiation, assistance to qualify as a Non-Significant Categorical Industrial User (NSCIU)


Landfill Management

ENW is experienced with characterizing, monitoring, mitigating and closing illegal dump sites, legacy landfills, construction and demolition debris landfills, filled quarries and log ponds, and municipal solid waste landfills.

  • Investigations - ENW has utilized geophysical methods such as ground penetrating radar, soil gas, drilling and test pitting to investigate landfills. Once the lateral and vertical extents of buried solid waste have been determined, ENW is experienced with various sampling methodologies and the appropriate analyses to characterize landfill gases, soil impacts, ground water impacts and leachate associated with the fill.

  • Monitoring – ENW has overseen installation of temporary well points and semi-permanent gas monitoring wells to monitor landfill gas compositions, and static and differential pressures under extreme weather conditions (e.g., drops of 10 inches of mercury or more) to gauge gas migration potential. Sub-slabs, sprinkler riser rooms, utility closets, and other confined spaces are monitored in nearby buildings and other structures to determine if landfill gases present an explosion or asphyxiation hazard.

  • Closures – ENW has facilitated closure of many different types of landfills. In a closure plan, ENW provides details relating to the landfill cover, security fencing, signage, vegetation, erosion and sediment control facilities and long-term monitoring. Often, a neighborhood association assumes responsibility for maintaining engineering controls and monitoring the closed landfill.

  • Mitigations – ENW has designed and implemented many mitigation plans for building structures on top of, or proximal to, closed landfills, such as impermeable gas membranes (i.e., HDPE liners), active and passive sub-slab depressurization systems, and gas extraction wells. ENW is experienced with maintaining and monitoring these systems.

  • Beneficial Use Survey

ENW has performed numerous complete and streamlined beneficial land and water use surveys in support of remedial investigations, risk assessments and feasibility studies.  ENW has extensive experience researching beneficial uses through research of local, state, and federal regulatory agency records, available resources at the U.S. Geological Survey and Oregon Water Resources Department, and local zoning and planning departments.  ENW has conducted comprehensive door-to-door water use surveys and interviews with property owners, including research with water districts to determine the source of drinking water and potential areas where ground water resources are being utilized and could be at risk.  Where necessary, ENW has employed contaminant fate and transport models to demonstrate and support Locality of the Facility determinations.

Other contamination projects procured by ENW staff include: 

  • Wood treatment plants

  • Service stations and fueling facilities

  • Aviation sites

  • Chemical warehouses

  • Landfills

  • Solvent recycling facilities

  • Lumber mills

  • Abandoned commercial/industrial sites

  • Fleet facilities

  • Metal plating shops

  • Scrapping facilities

  • Bulk Fuel Distribution facilities

  • Medical Equipment Manufacturing facilities

  • Chemical processing, storage, and distribution facilities