Correcting the Regulators — Reducing the Burden
Environmental Compliance Violations

Specialty Printing Operations
This client, who has a specialty printing operation, was allegedly found to be not in compliance with its permit conditions by the state regulatory agency during an inspection. The agency issued the company a notice of violation and levied a substantial fine. The permit conditions were based on the classification the company had received from the agency. ERL reviewed the notice of violation and all relevant state regulations, and then studied the company's operation and practices, and evaluated all the chemicals and substances used in processes by the company. ERL subsequently determined that the regulatory classification of the company was different than that which was designated by the regulatory agency. Thus, the company was subject to a different and less onerous set of environmental compliance requirements. ERL assisted the company in complying with the appropriate regulations and, in concert with the company's attorney, was able to get the company's regulatory classification changed to the appropriate one. As a result, the original high-five-figure fine was reduced by 80% and the company was subject to less burdensome and less expensive compliance requirements.

Wastewater Compliance & Hazardous Waste Management

Manufacturing Facility
This manufacturing facility, located on a river, retained ERL to assist with a range of compliance issues regarding both its wastewater discharge and hazardous waste management. ERL was responsible for the characterization of wastewater streams, a POTW impact study, assisting with the conceptual design of its wastewater treatment system, and development of a water conservation plan. ERL prepared the wastewater discharge permit applications and was involved in extensive permit negotiations with the state regulatory agency and local municipality to obtain the permits. ERL also performed a hazardous waste audit, hazardous waste training for facility personnel, as well as preparing contingency and spill prevention plans, a facility inspection plan, and an employee training program to address ongoing compliance obligations.

Long-term Environmental Relationship

International Food Producer
ERL is proud of its excellent long-term relationship with this major international food producer corporation. Particularly through its special arrangements with the corporation's environmental insurance policy holder on behalf of their client, ERL has provided environmental engineering, risk assessment, and environmental site assessment services to the corporation since 1991, at almost all of the corporation's facilities in the U.S., Canada, and Mexico. The environmental risk assessment surveys include a review of facility location and relationships to neighbors, processes and operations, regulatory status and environmental management structure including training, safety, staffing, and emergency planning. Additional work, either for the corporation directly or through its insurer, has included:

• Clean Air Act Amendment Audits to evaluate Title V compliance status of a plant
• Phase I site assessments and compliance audits for the corporation's Law Department of a number of facilities for due diligence during an acquisition.
• A Phase I ESA of a warehouse and Phase I and Phase II work for another corporation owned property.
• Preparation and submission of the wastewater discharge permit for a new production line and updating and P.E. certification of the Spill Plan for an established plant.
• Preparation of the Off-site Consequence Analysis portion of the Risk Management Plans for two of the corporation's facilities.