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TeTon Environmental, PLLC
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Water-Related Programs - Environmental Regulatory Compliance
Spill Prevention Control and Countermeasure (SPCC) Plans
To meet the requirements of 40 Code of Federal Regulations (CFR) Part 112, "Oil Pollution
Prevention,” and applicable State requirements, we have developed numerous SPCC Plans,
providing procedures and measures for minimizing the potential for discharges of oil from
storage and transfer activities into navigable waters of the United States.
Storm Water Pollution Prevention Plans (SWPPPs)
Certain facilities (including construction activity) must manage their on site activities to reduce
or eliminate exposure of certain materials or pollutants to storm water. The purpose of a
SWPPP is to identify sources of pollution that may potentially affect the quality of storm water
discharges and to ensure implementation of measures to minimize and control pollutants in
storm water discharges. Consistent with the requirements of the federal storm water permitting
regulations (40 CFR Part 122.26) and EPA’s Multi-Sector General Permit (MSGP-2000), we
have developed numerous SWPPPs for clients in a wide variety of industrial sectors.
Integrated Contingency Plans (ICPs)
Program requirements that may be addressed by ICPs include (but are not limited to) the
following: SWPPPs; SPCC Plans; Preparedness, Prevention and Contingency (PPC) Planning
for hazardous waste; and Occupational Safety and Health Administration (OSHA) Emergency
Action Plans (EAPs). ICPs offer clients a consolidated and effective strategy to manage several
programs in one document.
Facilities for which we have prepared SPCC Plans, SWPPPs and/or ICPs include:
• Food preparation and processing facility, Portsmouth, NH;
• Metal finishing facility, Hooksett, NH;
• Lamp manufacturer, Manchester, NH;
• Printing and publishing company, Manchester, NH;
• Metal finishing facility, Franklin and Laconia, NH;
• Plastic materials and resins manufacturing facility, Manchester, NH;
• Medical equipment manufacturer, Jaffrey, NH;
• Textiles manufacturing facility, Manchester, NH;
• Wastewater treatment facility, Merrimack, NH;
• Printing and publishing company, Hanover, NH;
• Municipal highway garage, Merrimack, NH;
• Chemical manufacturing/packaging facility, Exeter, NH;
• Metal finishing facility, Nashua, NH;
• Vehicle parts remanufacturing facility, Bedford, NH;
• Wastewater treatment facility, Milford, NH;
• Electric power generating facility, NH;
• Solid waste transportation and disposal facilities, multiple NH and MA locations;
• Chemical manufacturing company, Seabrook, NH;
• Cable manufacturing facility, Manchester, NH;
• Wastewater treatment facility, Concord, NH;
• Two residential site development (construction) projects, NH; and
• Oil distribution facility, Manchester Center, VT.
Industrial Wastewater Discharge Permitting
Obtained and consolidated information necessary to characterize industrial facility operations
pertaining to wastewater discharges to satisfy the repermitting requirements of municipalities.
Tasks included performing facility inspections to identify regulated waste streams, analyzing
incoming and outgoing water use (process and non-process), performing water mass
balances and raw material inventories of materials that may be present in the facility’s
wastewater, performing representative wastewater sampling programs and reviewing analytical
data for compatibility with discharge to POTWs, and preparing completed applications,
including updating facility process flow schematics. Facilities where we have industrial
wastewater discharge permitting experience include:
• Lamp manufacturer, Manchester, NH;
• Printing and publishing company, Manchester, NH;
• Plastic materials and resins manufacturing facility, Manchester, NH;
• Electric power generating facility, NH;
• Textile dyeing facility, Manchester, NH;
• Automotive component manufacturing company, Manchester, NH;
• Groundwater Remediation Project Wastewater Discharge Permitting, printed circuit board
facility, Derry, NH;
• Electrical instrument manufacturing company, Manchester, NH;
• Automotive component manufacturer, Seabrook, NH;
• Plastic resin manufacturer, Seabrook, NH;
• Hospital, Manchester, NH;
• Superfund site, Milford, NH;
• Brewing company, Milford, NH;
• Leather finishing facility, Seabrook, NH; and
• Electrical connector manufacturing facility, Seabrook, NH.
Wastewater Monitoring and Reporting
Numerous industrial wastewater monitoring and reporting projects for clients included
implementing representative sampling programs, collecting preserved grab and/or composite
samples, reviewing industrial discharge permits and local limits, reviewing analytical results for
quality assurance and compliance with federal and/or local requirements, tabulating laboratory
results, and completing periodic compliance reports. Our project experience in wastewater
monitoring and reporting includes work for the following types of facilities:
• Lamp manufacturer, Manchester, NH;
• Printing and publishing company, Manchester, NH;
• Textiles manufacturing facility, Manchester, NH;
• Plastic materials and resins manufacturing facility, Manchester, NH;
• Automotive component manufacturing company, Manchester, NH;
• State university, Durham, NH;
• United States Postal Service, multiple NH locations;
• Textile dyeing facility, Manchester, NH;
• Matchbook manufacturing facility, Jaffrey, NH; and
• Electrical instrument manufacturing company, Manchester, NH.
Wastewater Evaluations/Investigations and Other Related Projects
We have conducted on-site wastewater surveys and evaluations identifying all wastewater
discharging to the sanitary sewer system, initiated and conducted appropriate sampling
programs, reviewed and analyzed flow and analytical data and Material Safety Data Sheets,
provided evaluations and recommendations regarding pretreatment requirements and
reducing and/or eliminating wastestreams, and reviewed appropriate actions and permitting
requirements with regulatory authorities. Representative project experience includes the
following:
• NPDES-Required Cooling Water Toxicity Testing and Supplemental Investigation,
synthetic materials and resins manufacturing facility, Manchester, NH;
• Regulatory and Wastewater System Evaluation for Sources of Lead, multinational
computer manufacturer, Augusta, ME;
• Wastewater Oil & Grease Study, printing press equipment manufacturer, Dover, NH;
• Industrial Wastewater Evaluations, industrial equipment manufacturer, Salem, NH;
• Leachate Impact Evaluation, municipal landfill, Exeter, NH;
• Groundwater discharge registration, carpet cleaning company, Goffstown, NH;
• Wastewater Mercury Evaluation, high pressure sodium and mercury vapor pressure lamp
manufacturer, Manchester, NH;
• Industrial Wastewater Pollutant Source Evaluations, leather finishing facility, Seabrook,
NH; and
• Development of a Toxic Organic Management Plan (TOMP), metal finishing facility,
Hooksett, NH.
On-Site Environmental Compliance and Management Assistance
Provided “out-source” style on-site environmental and project-specific services at a large
manufacturing facility. Worked at the facility one to two days weekly performing the following
tasks: implemented and managed all elements of the facility’s ISO 14001 Environmental
Management System (EMS); collected process wastewater samples and reviewed analytical
results for quality assurance and compliance with applicable discharge limitations; initiated
and managed corrective and preventive actions for regulatory and EMS nonconformances;
communicated with regulators on behalf of the client; tabulated wastewater monitoring results
and completed all permit reporting and discharge permitting requirements; performed routine
facility inspections; managed the facility’s voluntary Radiation Monitoring Program; completed
all National Pollutant Discharge Elimination System permitting, monitoring, and pollution
prevention planning activities; and completed client’s Emergency Planning and Community
Right-to-Know Act Section 312 Report (Tier Two Report).
Aboveground Petroleum Storage Tank (AST) and Electrical Transformer Registration
Consistent with the requirements and obligations to comply with the New Hampshire
Department of Environmental Services (NHDES) AST regulations for storage of petroleum
products, we have performed the following work tasks: conducted facility reconnaissance
activities to identify ASTs and electrical transformers requiring registration with the NHDES,
determined applicability of NHDES AST regulations, calculated secondary containment
volumes, identified spill prevention requirements (e.g., overfill protection and permanent “tank
markings”), and completed AST registration forms.
