Environmental Management & Engineering

SMG helps clients address requirements that come from the materials they use, the waste they generate and the effect their operations have on the environment. We have years of experience in air, waste, and water permitting, as well as environmental management and planning services.

1/Existing Facility Permitting – Title V Air Permit


PROBLEM

A major source located in Jefferson County, KY was required to renew and update their Title V Operating permit. The facility’s goal was to streamline permit recordkeeping, monitoring and reporting requirements consistent with the facility’s operational practices. In addition, the facility needed to update emissions calculation methodologies for reporting of actual emissions and determination of potential emissions.


SMG'S APPROACH

SMG visited the site, reviewed available information, and helped gather the required data needed to prepare an administratively complete permit application. We collaborated with facility personnel to integrate information from historical applications and internal documents into a Title V permit application package. SMG identified permit conditions which could be relaxed, revised, or removed while maintaining robust compliance demonstration records for regulations applicable to the stationary source. SMG prepared the Title V renewal permit application, met with APCD personnel to expedite the processing, and provided written comments to the client on the draft Title V operating permit.


RESULTS

Emissions reporting was improved using revised calculation methodologies and emissions tracking systems developed by SMG. The updated environmental management tools minimized the potential for calculation errors in regulatory reports and allowed for detailed analysis of facility emissions through custom aggregation tools. Our comprehensive approach allowed the facility to demonstrate compliance with Federal and local APCD emission standards for affected facilities, annual plantwide criteria pollutant emission limits, and daily pollutant emission limits using facility operations data. The application was deemed administratively complete, and we were successful in minimizing required recordkeeping and reporting for the source. MS Access database reports maintained by the facility for production purposes were easily imported into the environmental management tools developed by SMG thereby allowing the client to easily complete emission calculations for numerous affected facilities. The client used the new tools to quickly prepare semiannual monitoring reports and emission inventory submittals required by the local administrator.

2/New Facility Permitting


PROBLEM

A large alcoholic beverage company was planning to construct a distillery along a lake in Kentucky and use the fresh limestone water for bourbon production. The proposed site was a former farm with historic activities dating back to the 1880s. A water intake structure was required in the lake and along the adjacent shoreline which was owned by others. Several ephemeral and intermittent streams would be impacted by the construction. The client needed a US Army Corps of Engineers (USACE) Clean Water Act (CWA) Section 404 Permit, a Kentucky Division of Water 401 Water Quality Certification, a water withdrawal permit, a permit for construction in and along a stream, and a construction stormwater permit. Additionally, an air permit was required prior to construction for the aging warehouses, distillery equipment, and other emission units. Evaluation for cultural and historic resources and endangered species evaluations were required under the National Environmental Policy Act (NEPA) and Endangered Species Act (ESA).
As the construction proceeded and operations began, a number of operating permits and environmental and hazardous materials compliance plans were required. The project required coordination with the nearby city for drinking water use and industrial wastewater pretreatment and discharge. Recordkeeping and reporting were needed prior to facility personnel being mobilized to the site. Set up and management of environmental systems during the transition to full operations was needed.


SMG'S APPROACH

During the planning and initial construction phases, SMG managed the environmental permitting and environmental compliance for the site. The process involved application preparation and coordination with multiple regulatory agencies including the USACE, Kentucky Division of Water, Kentucky Division of Air Quality, US Fish and Wildlife Services, Kentucky Department of Fish and Wildlife Resources, Kentucky Heritage Council, and local agencies. Permits included stream mitigation, cultural and historic resources investigation, coordination with state and federal Fish and Wildlife agencies, and State 401 water quality certification, and the Section 404 permit, which required wetland and stream delineation. SMG coordinated with the client’s project team to minimize stream impacts and to adhere to the schedule by expediting the permit processing. State stream construction, water withdrawal, and air permits were also obtained. SMG provided onsite observation to assess contractor compliance with the stormwater permit and managed environmental permit reporting.
During the later construction phase, SMG managed the environmental permitting and compliance for the new distillery. The initial environmental and hazardous material compliance plans (GPP, HMPC, and SWPPP) were prepared and applications for operating permits, such as industrial wastewater pretreatment and discharge and industrial stormwater discharge, were readied and submitted. SMG provided training to the initial employees regarding hazardous material management and groundwater/stormwater protection. SMG worked with the new Risk Manager for the site to transition responsibility for environmental and hazardous material compliance.


RESULTS

SMG’s management of the environmental planning and permitting for the facility, successfully supported the construction schedule and managed environmental compliance for the initial site operations. SMG continued to work with the owner to obtain remaining operational permits and to transition environmental compliance responsibilities to the new facility staff to support startup and initial operations. The facility was completed on schedule and provides a significant economic benefit to the surrounding community.

3/Brownfield Redevelopment


PROBLEM

A local Kentucky business was in need of more space, but wanted to stay in the community. The client decided to expand into an old manufacturing facility in town that was shuttered and unused.


SMG'S APPROACH

SMG evaluated the property by identifying potential and actual environmental liabilities through the Phase I and II process. SMG provided options to the Client for development. We brought the Client through the Kentucky Brownfield Redevelopment Program to limit their liability and established a Property Management Plan to guide the client on uses of the property. SMG was also able to assess the property for asbestos and lead paint before remodeling began.


RESULTS

The local company has successfully expanded to the new facility and remodeled and renovated for their purposes. The Client is able to repurpose a contaminated brownfield site that otherwise would have fallen in disrepair and been a burden on the community.

4/Phase I


PROBLEM

A national restaurant chain required quick turnarounds on Phase Is on 15 sites in two states.


SMG'S APPROACH

SMG performed a Phase I environmental site assessment using ASTM Standard 1527-05 as a guideline. SMG evaluated the 15 facilities in 20 days. The work entailed a site visit, site interviews, review of state regulatory agency file information and evaluation of federal environmental databases. SMG prepared appropriate reports to meet the requirements of the client and enable the transaction to be completed.


RESULTS

SMG provided the client with completed Phase Is in time for closing on a multi-million dollar transaction.

5/Phase I Assessment and Compliance Auditing


PROBLEM

A multi-state metal manufacturing company needed Phase I audits of each of their 15 manufacturing facilities for a bankruptcy work out through an international banking entity.


SMG'S APPROACH

SMG performed a Phase I environmental site assessment using ASTM Standard 1527-05 as a guideline. SMG evaluated the 15 metal fabrication facilities located in 14 separate states during a one-month period of time. The work entailed a site visit, site interviews, review of state regulatory agency file information and evaluation of federal environmental databases. SMG prepared appropriate reports to meet the requirements of the client and enable the transaction to be completed.


RESULTS

SMG identified potential environmental liabilities that were considered to be material and established budget costs to address the liabilities identified.

6/US Army Corps of Engineers Permitting/Permission to Construct


PROBLEM

A large energy facility was planning to construct along a river and build a barge facility, water discharge and water intake structure. Additionally, due to the facility’s placement on previously mined and reclaimed land, there were some small stream or wetland areas that might be impacted. The client needed a USACE 10/404 Permit.


SMG'S APPROACH

SMG prepared and managed the preparation of USACE Section 10/404 permits for a coal gasification facility with barge unloading operation on the Green River. The process involved application preparation and coordination, wetland delineation, wetland mitigation, river mussel survey, cultural and historic studies, including archaeological deep-testing along the river bank, coordination with state and federal Fish and Wildlife personnel, state 401 water quality certification, state floodplain construction permit and flood modeling, and assistance with source water baseline assessment for KPDES Section 316(b) permit application.


RESULTS

SMG scheduled each of the contributing studies and consultations, managed the associated public notices, worked with the Corps permit reviewer and responded to questions raised by the Corps and by public comments. The permit application was approved and the permit to construct issued.

7/Money Saver—Environmental Compliance / Due Diligence


PROBLEM

An out-of-state owner of a large multi-story office building called to get help. The building was being refinanced and the lender’s due diligence requirements included an environmental compliance assessment. The multi-million dollar loan closing was only a week away.


SMG'S APPROACH

During the due diligence investigation, lingering underground storage tank issues from a previous environmental clean-up were found. The site had not been properly closed. SMG conducted research of 10 years worth of site records, negotiated with state regulators, conducted field investigations, obtained a satisfactory closure and met the closing deadline.


RESULTS

The successful resolution of the compliance issue within the short time frame allowed the client to complete the re-financing on time and with a significant reduction in cost and expenditures.

8/Site Remediation — Historic Petroleum Contamination


PROBLEM

A site in Louisville, Kentucky had petroleum contamination dating back decades. Traditional techniques hadn’t solved the problem. The site was within an operating public facility and needed to be closed quickly and efficiently.


SMG'S APPROACH

Knowing the history of the site and the frustration of the client, SMG evaluated multiple technologies for chemical and biological degradation. SMG worked with the technology vendor to use soil mixing and hydrogen peroxide to remediate the remaining petroleum release.


RESULTS

SMG was able to achieve a status of no further action at the site within five months from the application. The client was finally through with years of frustration and had a closed site.

9/NEPA Analysis — FHWA Road Project in Gallipolis, OH


PROBLEM

A small community on the Ohio River had a major employer threatening to leave due to lack of road access during periodic flooding. A new road was proposed, but required a review under the National Environmental Policy Act to confirm there would be no significant impact before the community could receive grant money and construction approval from the Ohio Department of Transportation and U.S. Federal Highway Administration.


SMG'S APPROACH

The community had no expertise in NEPA review and did not even understand what was required. SMG was engaged to evaluate the project impact and performed all site evaluations including phase I environmental site assessment, threatened and endangered species evaluation, wetlands survey, noise analysis, socioeconomic assessment, cultural and historic assessment, project need and alternatives review. SMG prepared all required environmental documents for review and approval by state and federal agencies.


RESULTS

After performing the NEPA analysis and working with all stakeholders, both federal and state agencies approved the project as a Level 4 Categorical Exclusion and issued a finding of no significant impact. The new road was constructed and helped save community jobs.

10/ISO 14001


PROBLEM

A Tier I automotive supplier had to implement ISO 14001 at its facility as a condition of its contract with the auto manufacturer.


SMG'S APPROACH

SMG provided initial ISO 14001 training to management and team leaders and emphasized the importance of management buy-in and whole company support. To help the company develop and own their process, SMG provided Environmental Management System planning assistance as the policies and procedures were documented. Following implementation, SMG performed routine compliance auditing and EMS auditing services to help confirm the system was working.


RESULTS

SMG identified potential environmental liabilities that were considered to be material and established budget costs to address the liabilities identified.

11/Phase II and Remediation—Brownfields Redevelopment


PROBLEM

A non-profit community development agency needed to purchase a property that had historic contamination identified on site.


SMG'S APPROACH

SMG evaluated the property by identifying potential and actual environmental liabilities and options for development. We then quantified site impacts (including soil impact with chlorinated solvents and toxic metals); developed risk based remediation and development alternatives, and managed the site remediation in accordance with state approved plans.


RESULTS

Following the remediation and interface with the state, SMG obtained a risk based closure from the state which allowed the agency to proceed with their plans for the site.

12/Environmental Risk Management Compliance Auditing


PROBLEM

A regional coal mining and processing company was under an agreed order with EPA to audit compliance at some of its facilities. They also wanted to know how the rest of their mines were performing on environmental issues across the company.


SMG'S APPROACH

SMG performed an environmental compliance audit of coal mining operations from 19 operating groups in 4 states that evaluated over 100 mine permits. The work entailed a site visit, site interviews, and review of facility inspection history and on site records. Portions of the work were completed as part of a formal consent order within a period of three months.


RESULTS

Compliance status was identified for each operating group for specific items audited as well as across the entire corporation and presented in a manner that enabled corporate and regulatory officials to readily determine areas to focus resources to improve compliance. The company has used the opportunity to periodically revisit each facility’s compliance status.

13/Air Permitting — Keeping a New Energy project out of PSD Permitting


PROBLEM

A new renewable energy facility was planned to use biomass on a small scale to create electricity. The plan was to stay below the thresholds for “Prevention of Significant Deterioration” permitting that would lengthen the permit time frame dramatically. The project had to be on line in less than 3 years.


SMG'S APPROACH

SMG reviewed air permitting options with the client to determine the best approach. SMG worked with the project design engineers to develop a permit application that would enable the facility to be permitted as a synthetic minor permit, enabling the project to achieve final permits much earlier than predicted. SMG’s relationship with the regulators and proactive management of the permitting process saved time and money for the client.


RESULTS

The permit went through significant revisions with the active engagement of SMG with the regulators. A draft permit was issued within two weeks of notice of a substantially complete application. The project is on schedule to reach its goals.

14/Anti-Degradation Alternative Analysis


PROBLEM

A client wanted to renew their NPDES wastewater discharge permit and was asked to do a Socioeconomic Demonstration and Alternatives Analysis (SDAA) (previously known as a high quality alternatives analysis (HQAA)), also known as an “anti-degradation analysis”. Not knowing what to do, they contacted SMG for help.


SMG'S APPROACH

The SDAA is designed to protect high quality waters within the state by preventing additional pollution from harming existing water quality conditions, while not prohibiting essential economic and social development in the region. SMG analyzed alternative and enhanced treatment technologies and source reduction strategies at the project location, and analyzed the project’s impact on both social and economic factors in the region. SMG was able to show that abandonment of the project would result in a significant impact on the socioeconomic development of the region.


RESULTS

The client was approved to continue development of their business with no changes to their operation or other detrimental permit restrictions.

15/Water Resources Management — FEMA Map Revision, Lexington, KY


PROBLEM

Existing buildings on a Brownfield redevelopment site are located in the floodway boundary, preventing the developer from obtaining a construction permit in accordance with local floodplain regulations.


SMG'S APPROACH

SMG discovered that the existing floodway boundary and base flood elevations were based on an obsolete FEMA hydraulic model. SMG used HEC-RAS, the latest river hydraulics model offered by FEMA, to verify the current floodway boundary. SMG converted the original HEC-2 model to the current version of HEC-RAS. The river hydraulics were analyzed using HEC-GeoRAS, which is a utility for processing geometric HEC-RAS output data in ArcGIS. Modeling efforts determined that the base flood elevations are lower than indicated by the original HEC-2 model, allowing the extent of the floodway boundary to be reduced. This change made the property eligible for a construction permit.


RESULTS

A Conditional Letter of Map Revision was submitted to FEMA to request the existing flood maps to be updated to depict the adjustments in the floodway boundary. The project is on schedule to begin construction.

16/Green Infrastructure Design, Lexington, Kentucky


PROBLEM

The owner of a commercial building needs to provide water quality treatment for stormwater runoff from an existing parking lot. The client is interested in using green infrastructure design to provide low maintenance treatment devices without losing many parking spaces.


SMG'S APPROACH

SMG developed a bio-retention cell design that will fit into an eight-foot wide median between rows of parking spaces. This bio-retention cell will have plantings that help to treat pollutants and reduce the volume of stormwater. The plantings are arranged in a manner that enhances the aesthetic environment, giving it the appearance of a landscaping feature rather than a stormwater treatment device.


RESULTS

Preliminary designs have determined that the bio-retention cell will treat stormwater runoff from nearly 40% of the site as well as reduce the total quantity of stormwater that leaves the site. The client has decided to attract attention to their bio-retention cell with a sign describing the utility of the device beyond its aesthetics.

17/NPDES Permitting


PROBLEM

A municipality’s NPDES wastewater discharge permit had restrictive permit limits that were costing the city money in treatment costs. Also, the state’s reasonable potential analysis, prepared during the NPDES permit renewal process, proposed monitoring and limits for additional parameters that the city felt were not justified. Not knowing how to respond, the city contacted SMG for help.


SMG'S APPROACH

SMG determined the basis for the restrictive limits inclusion on the permit. It turned out the limits had been applied based on a regulation that had been since overturned. The state concurred and returned normal secondary treatment limits to the permit.

Next, SMG reviewed the city’s sampling results and compared them with the results of the state’s reasonable potential analysis. SMG found that many of the proposed requirements were based on sampling results from one particular year. A closer look at the data showed inconsistencies, such as effluent sampling results that were significantly higher than influent sampling results. SMG convinced state regulators to agree that the data should be excluded from the analysis. After completing a second reasonable potential analysis using the revised data, the additional monitoring and limits from the proposed permit were removed.


RESULTS

The city no longer had to spend extra money on additional treatment to meet the overly restrictive permit limits. The plant operator could breathe easier knowing that there was a greater margin of error in operating the city’s wastewater treatment plant.

n addition, by proactively challenging proposed permit requirements, the city avoided having additional limits and monitoring added to their NPDES permit and saved money by not having to regularly sample for these parameters.

18/Pretreatment Local Limits


PROBLEM

A city engaged SMG because local industries were complaining about their pretreatment permit limits and the city was not getting economic development inquiries from industry regarding new or expanded operations. Existing local limits appeared to be more stringent than what seemed reasonable.


SMG'S APPROACH

SMG reviewed the city’s Sewer Use Ordinance, influent, effluent, and sludge sampling results, Pretreatment Reports, and the NPDES Permit. In comparing the city’s local limits with other treatment plants’, SMG found:

The city’s limits were more stringent than other comparable plants;

The city’s permit and local limits had not been updated as a result of the closure of a major industry that changed the treatment plant’s industrial loading; and

The city’s treatment plant capacity has been upgraded in the NPDES permit, but this had not been taken into consideration during pretreatment program evaluations.

Based on these factors SMG helped the city re-evaluate their local limits.


RESULTS

SMG re-evaluated and developed technically valid and effective pretreatment local limits. SMG coordinated with city officials and state regulators during the re-evaluation process. As a result, the local limits for many important parameters were made less stringent and several other parameters were removed due to site-specific conditions at the wastewater treatment plant. The city now feels that it can keep its existing industries happy and potentially attract new industry to the area.