Storm Water Pollution Prevention Plans and Spill Prevention Control and Countermeasures
Benefit: – Prevention of costly remediation of contaminated areas.
Prevents costly fines from accidental releases.
Preventative measures are more economical to implement than remediation, and are better for the environment. Quite often, we have seen clients who wished that they had taken the economical route of prevention. As the old saying goes “an ounce of prevention is worth more than a pound of the cure”.
What we offer is an ability to retrofit current property dynamics, and develop plans that prevent contamination of subsurface soils, groundwater, and sewer systems through storm drains or drywells. We do this through a thorough identifying of current conditions and developing potential solutions, rather than just presenting a problem that needs to be fixed.
We also offer this service in the planning stage of a project. By doing this, problems are solved before they ever happen. This also allows architects and engineers to make adjustments prior to them being forced to do so. By utilizing this service, clients are able to streamline potential environmental issues, present a good environmental package to planning commissions, and demonstrate to lenders due diligence, and show responsibility as members of the communities.
Every company located in Arizona who owns or plans to install a drywell are required to register the drywell with the Arizona Department of Environmental Quality (ADEQ). Drywells are also required to be registered when decommissioning or abandoning. Drywells can only receive storm water runoff or discharges that are exempted by state regulations. If other fluids have been directed to the drywell, it is subject to the aquifer protection permit (APP) program and/or closure requirements and may be considered an underground injection well that requires both ADEQ and USEPA permitting.
If a drywell owner suspects contamination, or based on ADEQ inspection or a complaint, a drywell screening and investigation is required. The drywell investigation is used to determine the presence and extent of the contamination. CES has performed several drywell screens to inform our clients and ADEQ of the concerns revolving around the drywell, while being cost-sensitive to our clients.
Aquifer Protection Permitting
Drywells may be regulated under the Aquifer Protection Permit (APP) program of ADEQ. An APP may be required of a facility when hazardous materials are stored, used, loaded or treated in an area that drains to a drywell, or when a drywell receives discharges other than storm water. The determination as to whether a drywell is regulated or not rests with ADEQ. CES is experienced in supplying the drywell owner/registrant with a comprehensive Determination of Applicability form and accompanying application for submittal to the ADEQ. Also, the APP may require the drywell owner/registrant to develop a Best Management Practices Plan (BMPP) in order to minimize the possibility of contaminating soil, groundwater or surface water from contaminated runoff.
Facilities looking to decommission or abandon a drywell are required to submit a clean closure form to ADEQ. The clean closure application is similar in nature to the drywell investigation and screening report, with additional reporting requirements. CES has developed clean closure applications for companies in several industries, and understands the requirements of the closing processes.
CES has helped many clients achieve clean closure status for their drywells. Our experience with coordinating efforts with the Arizona Department of Environmental Quality (ADEQ) is most beneficial to our clients. CES will be there to submit the initial clean closure application to ADEQ up to the Decision to Grant Clean Closure.
Drywell Projects – Multiple Locations
CES personnel have performed well over 1000 drywell cleanouts, investigations, registrations, closures and APP applications for clients all over Arizona. Several large clients, including the Arizona State University and Kroger’s, have utilized CES’s services for inspection and maintenance services as well as drywell conversions to sumps. Converting to a sump reduces the liability associated with drywells (Class V injection wells) and allows for reuse of storm water, thereby reducing water consumption costs.
Pollution Prevention Activities
CES personnel have developed Pollution Prevention (P2) Plans for several industries in Arizona and California, including semiconductor plants, electroplating facilities, PCB shops and heat treating companies. Proper P2 implementation typically reduces material costs, allows for easier management of hazardous wastes, and reduces the amount of generation fees paid to the Arizona Department of Environmental Quality up to 50%.