Discharge Control and Permitting

The client needed to plug and abandon several injection wells that extended into a flooded salt mine.  The problem was that the casing in many of the wells had corroded to the point that standard bridge plugs could not be reliably set.   In many instances, the casing was entirely missing at the depth where the plug needed to extend to satisfy regulatory requirements.  Enter EarthFax who, together with a team of renowned subcontractors, developed a unique plan to achieve the end result.   Read about this and other experiences below.
 
DEVELOPMENT OF AN NPDES DATA BASE. Surface-water and waste-water discharge samples were collected from a rocket-motor manufacturing facility in Utah to develop a data base required for preparation of NPDES permit applications. Grab and composite samples were collected from numerous discharges over a period of one year to characterize the sources. Input was provided into preparation of the NPDES permit applications.

STORM WATER DISCHARGE PERMIT COMPLIANCE REVIEW. Storm water discharges from a potash mining and processing facility were examined to assess the applicability of storm water NPDES permit requirements to the site. The adequacy of existing runoff controls was examined. Special attention was paid to areas where additional controls were required. A baseline monitoring program was recommended to collect the data needed for submission of the permit application.

PREPARATION OF AN NPDES BEST MANAGEMENT PRACTICE PLAN. A Best Management Practices Plan was prepared to meet the requirements of an NPDES permit for an industrial facility in northern Utah. This facility manufactures gas-generate pellets used to actuate air bags in automobiles. Areas of the facility were reviewed and programs were established to control both routine and emergency discharges of treated or untreated contaminants to waste water and storm water. Plans were also developed to address agency concerns in the event of spills, leaks, or other emergency discharges.

STORM WATER INSPECTIONS. Inspections were performed at 14 food-processing facilities throughout the United States to determine the presence or absence of storm water discharges associated with industrial activity. Recommendations were provided to mitigate storm water exposure of material handling activities. The study was designed to aid management's decision to claim an exemption from NPDES storm-water regulations for each facility.

PREPARATION OF STORM WATER POLLUTION PREVENTION PLANS. Storm Water Pollution Prevention Plans were prepared for four facilities in Utah used for the production and assembly of automobile air-bag components. The plans were prepared in accordance with U.S. Environmental Protection Agency guidance and included identification of the pollution prevention teams, materials inventories, identification of significant materials that were exposed to rainfall, lists of previous spills, pollutant source identification, recommended best management practices, and plans for employee training.

STORM WATER POLLUTION PREVENTION PLAN DEVELOPMENT FOR A SUPERFUND SITE. A storm water pollution prevention plan was developed to cover excavation of a repository for contaminated soil to be removed from a Superfund site.The site was contaminated with radioactive materials and selected metals. Construction methods were evaluated and potential sources of pollution were identified. Best management practices were then established, employee training was discussed, and pollution prevention teams were organized.

UNDERGROUND INJECTION CONTROL SERVICES. EarthFax provided technical and field supervisory services related to revisions of an underground injection control permit for a salt and potash solution mine in southeastern Utah. Abandonment plans were revised for several old wells, wireline logging was supervised, and plugging of the wells was supervised. Field decisions regarding appropriate equipment and techniques were made to ensure proper plugging and abandonment. In some cases, working with a team of subcontractors, it was necessary to develop specialty cements that would float in the brine while hardening in order to permit plugging where corroded casing would not allow the use of bridge plugs. Mechanical integrity tests were also selected and testing was supervised in the field. All abandonment and mechanical integrity test data were assessed to ensure that the intent of the regulatory agencies was met. Liaison was provided between the client and the regulatory agencies on permit issues.