TES was engaged in the implementation and monitoring of a wetland mitigation area as part of permittee responsible mitigation for a large industrial client in Harris County, Texas. As part of the agreement with the United States Army Corps of Engineers Galveston District (USACE), TES successfully completed the mitigation project by initiating a strong control program to reduce Chinese tallow (Sapium sebiferum) to less than 10% aerial coverage in an approximately 30-acre forested wetland. Per the USACE mitigation plan, TES monitored and provided reports to the USACE for 5 consecutive years. In February 2016, the USACE made a final site visit and verified the project was a success and provided project closure documentation.

After completing environmental assessments, TES applied for Municipal Setting Designations (MSDs) for three sites in Northeast Texas. In early 2016 the Texas Commission on Environmental Quality granted MSD Certificates for these properties. This designation allows for the restriction of groundwater for potable use on an affected property. Preparation of an MSD application involves a great deal of documentation on the current and historical state of the property and surrounding area, continuous communication with regulating agencies, property owners, and local government, and clearly informing the community of the potential for this designation. We are very appreciative of the support from the community which was critical to the success of this project.

TES was engaged to determine the benzene emissions generated from four glycol dehydrators located at a large gas compressor station in Louisiana. TES utilized the GLYCalc 4.0 program to evaluate emissions from the glycol units under varying operating conditions. Through consultation with the plant management, TES established a reasonable worst-case operational scenario and evaluated anticipated benzene emissions with and without the downstream incinerator. TES mapped offsite receptor locations and elevations and utilized the SCREEN3 model developed by the U. S. EPA to predict maximum ambient air concentrations of benzene at the closest offsite receptors. TES presented the emission calculations and modeling results to senior management via a PowerPoint TM presentation. The modeling revealed that the compressor station did not pose a health risk to individuals living and working nearby under reasonable worst-case operating conditions and failure of the incinerator combined with poor meteorological conditions.

TES was engaged to modify a Louisiana Pollution Discharge Elimination System (LPDES) permit for an industrial park which houses several diverse industries. TES prepared and submitted the amendment application which resulted in the issuance of a new LPDES permit authorizing discharges from a treatment system serving several industrial facilities.

TES has installed more than twenty groundwater monitoring wells and prepared Annual Closure Progress Reports at a former RCRA TSDF. TES obtained approval of the use of Monitored Natural Attenuation as the site remedy. TES prepared and submitted an application for a Post Closure Order that has since been approved. TES provides turnkey post-closure care of this facility.

TES was engaged by a facility that engages in foundry activities to obtain coverage under the TPDES industrial stormwater general permit and to prepare a SWP3. During work on the stormwater issue, TES discovered that the facility had not registered for coverage under the TCEQ’s Permit-By-Rule provisions to authorize emissions from metal melting, metal grinding, and combustion units. TES prepared and submitted the documents necessary to obtain both the stormwater and air emission authorizations.

TES was engaged to obtain concurrence from State and Federal regulatory agencies that materials produced by a company engaged in the production of potassium hydroxide from oil refinery scrubber liquids were not solid wastes. TES prepared correspondence and supportive materials regarding the regulatory status of products produced from spent materials and by-products generated during the petroleum refining process. The negotiations concerning the status of the products produced by the TES client took place over a 14-month period. After meetings in EPA’s Region VI office and teleconferences with the Office of Solid Waste in Washington, D.C., TES was able to obtain the Agency’s concurrence that the spent materials and by-products emanating from the refineries were not “solid wastes” as defined in 40 CFR Part 261 and would not, therefore, be subject to regulation as hazardous waste, even if the materials expressed a hazardous waste characteristic. TES was able to obtain written concurrence of the Agency’s position from the Pennsylvania Department of Environmental Protection, the California Environmental Protection Agency, the TCEQ, and the Louisiana Department of Environmental Quality (LDEQ). Subsequent to obtaining concurrence from the regulatory agencies, the client constructed facilities to accept refinery by-products in Illinois, Louisiana, Georgia, and Pennsylvania. TES was engaged to obtain the regulatory authorizations necessary to construct and operate all five of the constructed facilities.

TES was engaged to review the Spill Prevention Control and Countermeasures Plan (SPCC) for a large paper mill in Louisiana. The mill had many large oil storage vessels which triggered the evaluation of the need for a Facility Response Plan. TES revised the SPCC plan to meet current standards and consulted with corporate environmental staff on provisions to avoid the need for a Facility Response Plan.

TES fulfilled the role of Federal Energy Regulatory Commission (FERC) Environmental Inspector for an interstate pipeline company during the construction of a 10 mile pipeline segment and 17 additional injection/withdrawal wells. Duties included environmental training of all on-site personnel and daily inspections at construction sites including management of any minor environmental concerns encountered. Daily reports were provided to the corporate office via email. Particular areas of emphasis included protection of water resources through management of hazardous chemicals and petroleum products utilized during drilling and control of soil erosion. For this project, a TES inspector was made available for emergency response 24/7. Following completion of construction, TES monitored the project for three years as required by FERC.

TES was engaged by an automotive parts manufacturing facility to modify an existing air permit to include emissions related to anticipated installation of additional manufacturing equipment. Additionally, TES was engaged to obtain authorization for stormwater discharges pursuant to the Texas Pollution Discharge Elimination System (TPDES) general permit for industrial stormwater discharges and to modify the facility’s Stormwater Pollution Prevention Plan (SWP3). TES submitted the necessary documentation to obtain both the air permit modification and the stormwater discharge authorization. As a result of its efficiency in completing these two tasks, TES has been retained to provide services that assure that all routine environmental compliance and reporting issues are properly handled.

TES was engaged by the owners of a small specialty refinery facility to resolve issues related to the cleaning and closure of a tank system. The previous owner of the refinery had entered into an Agreed Final Judgment (AFJ) to resolve allegations that it had illegally stored hazardous waste in four tanks located within a tank battery that contained twenty tanks. Unfortunately, the new owners of the facility made their purchase without a full understanding of the tasks, level of documentation, and related expenses necessary to complete the requirements of the Ordering Provisions contained within the AFJ and the evolving requests of the TCEQ staff. TES negotiated the specific requirements of the TCEQ with regard to satisfactory documentation of tank system closure and the absence of releases from the associated secondary containment structure. TES met with TCEQ representatives in Austin and negotiated a dramatic reduction in the number of soil samples and monitor wells required to obtain concurrence that releases from the secondary containment had not occurred. TES engaged a drilling contractor, supervised drilling activities, and collected samples of soil and water from borings and monitor wells. TES prepared a report to document that the sampling and testing done on environmental media collected from the site supported a conclusion that no releases from the tank system occurred, and a subsequent report on background levels of metals in soils along the Intracoastal waterway. TCEQ concurred with the reports and granted closure of the tank system with no further action.

TES was engaged to review the regulatory compliance status of four TSDFs and 14 used oil processing facilities located around the country on behalf of a prospective purchaser. The TSDFs and used oil processing facilities were owned by one of the nation’s largest waste management firms. The company which engaged TES to perform the review is a large multinational company which owns and operates water and wastewater treatment facilities around the world. After reviewing permit and compliance related documents, TES provided a preliminary report to the prospective purchaser, which described the compliance status of the facilities and any outstanding or anticipated regulatory issues. Subsequent to the report by TES, the prospective purchaser decided not to sign a Letter of Intent that would have furthered the acquisition process. The purchaser’s decision was primarily based on the inability to negotiate a favorable purchase price for the facilities.

TES conducted an environmental regulatory audit and Phase II ESA at an industrial water treatment facility on behalf of a potential buyer. TES performed sampling to identify affected soils and delineate areas requiring clean-up. TES directed clean-up efforts and provided on-site X-ray fluorescence analysis of metals in soil to determine when clean-up targets had been reached, thereby minimizing excavation and disposal costs.

TES performed a complete audit of a Treatment Storage and Disposal Facility (TSDF) located in Arizona. The TSDF was preparing to submit a Part B application and engaged TES to prepare portions of the application. In anticipation of heightened scrutiny by EPA Region IX, the facility engaged TES to perform a comprehensive regulatory audit of the facility covering RCRA, CERCLA, EPCRA, CAA, and NPDES related issues. TES completed the audit and was engaged to modify facility plans related to management of stormwater related to industrial activities. TES was engaged to provide regulatory support for issues which might arise during public meetings, public hearings, and the permitting process. TES participated in one “open house” held by the applicant and Region IX representatives.

TES was engaged to prepare and submit an application to gain certification as an “innocent owner/operator” pursuant to the TCEQ’s program for owners and operators of property or facilities impacted by environmental contamination emanating from offsite sources. TES researched the historical operations and environmental sampling and testing data maintained by the client to assure that the applicant facility was not a potential source of the contamination discovered in groundwater under the facility. TES researched the historical operations of facilities and landowners adjacent to the client’s property. In support of the client’s application for certification pursuant to the Innocent Owner/Operator Program (IOP), TES prepared a Site Investigation Report (SIR) detailing the probable source of the contamination and the inability of the applicant to be the source of the contamination. TES submitted the SIR along with the IOP application and certification was granted within months. In 2006 the facility was purchased by another entity and TES was engaged by the purchaser to assist with demonstration of closure of waste management units at the site

TES Performed a Phase I Site Assessment on seven current oil and gas well locations located on more than 7,000 acres of lease property. During the course of the site visit at the oil and gas well locations, TES personnel identified potential Asbestos Containing Material (ACM), locations subject to SPCC (40 CFR § 112), and improperly maintained water wells. Based on records review, TES identified 14 additional locations where oil and gas related activity had occurred on the lease. TES provided the prospective purchaser maps of likely jurisdictional wetland areas to aid in site selection for later oil and gas activity. TES also reviewed State and Federal Threatened and Endangered Species, and noted areas of potential habitat.

TES characterized and closed a historical affected property. Petroleum-contaminated soil was discovered during Phase I and II ESAs. TES conducted a soil and groundwater investigation, spot cleanup, and non-TRRP closure of the site prior to construction of a multi-million dollar industrial facility at the location.

TES provided environmental monitoring of air and water during and following a blowout of a gas well located in East Texas. TES personnel monitored oxygen and salinity levels in a 160 acre lake affected by the release, as well as various water wells and locations within the area of concern.

TES has worked with several clients to simplify air permitting requirements. These adjustments resulted in reduced recordkeeping and reporting requirements while limiting the potential for environmental non-compliance.

TES obtained water rights permits for the use of state-owned water at various locations in Texas. TES worked with clients to identify sites in close proximity to the place of use, with flow rates sufficient to supply peak hour withdrawal rates. In certain projects, TES identified existing water rights holders who were able to meet water demand. TES also assisted clients plan construction of storage reservoirs to avoid waters of the State of Texas.

TES utilized aerial photography and other geographic data sources, as well as on-site evaluation, to plan the placement of well sites, roads, and pipelines in various locations across Texas and Louisiana. Clients avoided wetlands and minimized impacts to the extent practical, which enabled rapid completion of many projects without filling of Preconstruction Notifications. Where impacts were unavoidable and Preconstruction Notification triggers were met, TES assisted clients in obtaining Section 404 permits quickly. TES assisted in selecting cost effective mitigation options which provided security for future projects at favorable rates.