Environmental Technology, Inc. (EN TECH) provides a variety of consulting services to our commercial, industrial and governmental clients relating to waste stream management, surface and groundwater protection, and environmental permitting.
Surface and Groundwater Quality Protection
The Clean Water Act (CWA) of 1972 concentrated on point source pollution of waters of the United States. The CWA was further amended in 1977 and 1987 to address non-point sources and broaden the permitting programs. Waters of the United States are defined as surface waters. Groundwater is not regulated by the CWA. Groundwater is regulated indirectly by the Safe Drinking Water Act (SDWA) and the Resource Conservation and Recovery Act. The EPA has established safe drinking water standards including primary and secondary drinking water standards or maximum contaminant levels (MCLs). States have primary responsibility for the protection of groundwater. The State of Arizona established the Aquifer Water Quality Standards (AWQS), similar to the MCLs, for a variety of contaminants and the Aquifer Protection Permit (APP) program for facilities discharging chemicals that may affect groundwater or degrade water quality below the AWQS. In addition, discharges that affect soil may be regulated based on Soil Remediation Levels (SRLs) or Groundwater Protection Levels (GPLs).
EN TECH can provide our clients with site and process inspections and evaluations to determine the need for regulatory compliance and permitting. The facility inspection evaluates site activities and facility processes that generate waste streams that are discharged to the environment. These waste streams may be sampled and analyzed for chemicals of concern and evaluated for compliance with aquifer protection standards. The compliance audit informs the client of areas where engineering modifications and controls, storage practices, housekeeping measures and other process improvements could avoid costly regulatory citations or remedial cleanup costs. In addition, preservation and/or enhancement of real property and business value may be achieved.
Process and System Design Assistance
EN TECH’s staff of professional engineers and environmental scientists can assist our clients in the design, construction and system management for a variety of industrial and commercial processes. EN TECH’s evaluations can assist our clients in waste stream management, waste reduction and regulatory compliance. In working with process engineers, EN TECH’s staff can provide reviews of systems and chemical processes to modify waste streams to reduce or eliminate discharges of target pollutants.
Aquifer Protection Applicability and APP Permits
If process modifications or other engineering controls cannot address particular discharges, a determination of APP applicability may be requested from the ADEQ. This determination provides the business owner with specific information from the regulators on the applicability or exemptions of an activity or process that may affect groundwater quality. EN TECH satisfies the technical capability for site investigation and closure activities pursuant to Arizona Administrative Code A.A.C. R18-9108.B.7. This determination provides the business owner with some assurances concerning compliance under the program or will lead to the preparation of the APP application and permitting process or exemptions where applicable. The APP Permit may require information on system design, waste stream analysis and specifications, and properties of the surface and groundwater settings at the site. The key objective of the APP permitting process is to protect groundwater supplies through Best Available Demonstrated Control Technology (BADCT).
Best Available Demonstrated Control Technology (BADCT)
BADCT is a combination of design, construction and regulatory standards to modify processes and waste streams to reduce pollutant discharges to the surface and groundwater. EN TECH’s team of engineers and environmental professionals can assist in the review and design of new and existing manufacturing, industrial, commercial and mining processes to bring these facilities into regulatory compliance.
Hydrogeological Studies and Compliance Monitoring
APP compliance may require monitoring of the affected aquifer at a specified point of compliance (POC). This could involve the installation of monitoring wells and periodic groundwater sampling and analysis. EN TECH can assist our clients in the performance of these tasks and ensure the validity and acceptability of the data. This provides our clients with the appropriate data to comply with the permit requirements without the unnecessary administrative costs of an internal compliance program. EN TECH’s geologists and hydrogeologists are experienced in the review and interpretation of regional and local groundwater data to develop an understanding of groundwater quality, groundwater flow regimes, aquifer isolation and interactions and aquifer characteristics. This information is used in conjunction with information on the discharging facility to best accommodate discharges while maintaining groundwater quality. Our team of environmental professionals can provide fate and transport modeling and feasibility testing to evaluate the impact and interaction of waste streams and waste stream components on soil profiles and groundwater aquifers. Here the goal is to determine and reduce the risks to human health, the environment and sensitive receptors, such as wetlands and riparian habitats while preserving cost-effective solutions to waste stream management.