Environmental - EnPros

Environmental Services

We Know Environmental

Environmental Assessments

Enpros provides cost effective environmental assessments specifically focusing on the needs and goals of clients. Our experience and knowledge helps bring quality and insights to any project, from the relatively simple to the most robust.

Assessment Type and Scenarios

Phase I Environmental Assessments

Preliminary assessment of environmental conditions to identify potential contamination and/or liabilities for:

Phase II Environmental Assessments

Detailed investigation following Phase I to confirm and delineate the extent of contamination.

Same scenarios, plus:

Phase III Assessments

Supplement to Phase II investigation

Remediation Closure

Component

(as appropriate to client and scenario)

Review and revisit Phase I components as appropriate
Field measurements for contaminants
Soil, surface water, groundwater, air, sediment and site material sampling and laboratory analysis
Risk and exposure assessment, including regulatory requirements and exceedances
GIS and Visual presentations
Preliminary delineation of impact
Preliminary assessment of response or mitigation options, including costs and timeline

Additional sampling and analysis, including well installations, as appropriate
Delineate lateral and/or vertical impacts and risks more thoroughly
Dose/Exposure modeling
Evaluate/propose/begin remediation/mitigation
Gain regulatory approval/concurrence
Apply to State/Federal Programs: VCP/OCP/Brownfield
Prepare more accurate costs and timeline

Experience and Knowledge Matters

Environmental assessments and remediation projects can be simple or more complex. What appears straight forward or of little consequence initially can increase in complexity and impact on a seemingly small or subtle detail. What is not uncovered can be magnitudes costly in the long run. In the end, experience and knowledge can improve the likelihood that facts and conditions are identified, the unforeseen is avoided, and projects goals and constraints are met.

Success can be greatly improved when project teams possess understanding and experience specific to the site and to assessments, such as:

Phase I assessments and projects

The above also lead to improved:

Phase II projects and subsequent

Field measurement techniques
Regulatory and compliance requirements
Legal landscape
GIS and aerial photo interpretation tools
Delineation methods and their limitations
Sampling and laboratory analysis science
Contaminant transport and exposure pathways to onsite and offsite
Concepts and evaluation of risks to human health and the environment, including quantitative modeling
Reliability and limitations of data when interpreting effects and costs
Statistical methods for background, site specific PCLs, and COC trends
Remediation projects and associated methods, limitations, regulatory standards and expectations, timelines, risks, and costs
Environmental project management, risk and constraint monitoring
Project Management IT tools such as data base systems and software

Remediation Assessments, Planning & Project Management

Enpros provides comprehensive services for various remediation needs, including:

Types

Contaminants

Purpose

Assessments tailored to immediate and future needs

Emergency response actions such as source containment and removal
Reporting and notifications
Bulk fluid/hydrocarbon recovery
Identifying contaminants of concern (COC) and protection levels (PCL)
Identifying sensitive areas, environmental receptors, and public receptors
Review of public data sources regarding wells, receptors, surface and subsurface lithology, topography, etc.
Lateral and vertical contaminant delineation, including
- Sampling plans and approvals, including statistical methods as appropriate
- Field and onsite testing and/or soil sampling and laboratory analysis
- Groundwater testing
- Hydrogeological assessment
- Background concentrations via sampling, public data, and/or statistical methods
Regulatory response, delineation, data, documentation requirements
Remediation planning, monitoring, and closure

Remediation Selection and Planning

Site current and future use
Stakeholder constraints and goals
Potential techniques
Containment and protection confidence
Regulatory acceptability and technique reliability
Design, construction, operations and maintenance costs
Monitoring requirements
Science and technology unknowns
Project risks
Time to completion and total costs

Project Management

Operations and maintenance
Monitoring
Statistical methods for background, site specific PCLs, and COC trends
Exposure pathway, human health, and environmental modeling, including quantitative methods
GIS and visualization tools
Status evaluations
Project revisions
Cost tracking and reporting
Forecast updates
Regulatory reporting

Groundwater Investigations, Monitoring, Remediation

Enpros specializes in groundwater services, including:

Source and release investigation
Hydrogeology and plume profiling
Plume impact and offsite risk assessments
Remediation option analysis and planning, including natural attenuation and/or extraction remediation
Groundwater well installation, coring, and sampling
TCEQ and RRC Groundwater remediation programs, including VCP, OCP and risk based programs
Groundwater sampling, analysis, and reporting
Groundwater remediation project management

Risk Based Assessments & Cleanup

Remediation projects seek to reduce contaminant concentrations to levels that protect humans and the environment. The actual concentrations that must be achieved are either set and predetermined or are based on actual quantitative risks. Risk based cleanups pose unique challenges and requirement. Enpros has extensive experience and capabilities with risk based assessments and cleanups, including evaluating:

Contaminants of concern
Land use scenarios (current and final): residential, recreational, commercial, industrial
Potential receptors: workers, the public, wildlife, ecology
Exposure pathways: ingestion, inhalation, dermal, immersion
Types of hazard: chemical, physical, radiological
Levels (doses) at which adverse effects can occur
Toxicology and epidemiology science and the underlying assumptions
The quality and limitations of data and laboratory methods
Methods to calculate or model the risk hazard
Unique site conditions
Proposing and negotiating alternative cleanup criteria

The below approach was utilized to gain alternative cleanup criteria for a Louisiana NORM lake bottom remediation. Negotiating NORM Cleanup and Land Use Limits: Practical Use of Dose Assessment and Cost Benefit Analysis

NORM

Enpros provides world class NORM expertise and experience, having:

Project managed or consulted to the remediation of > 250 NORM sites, including > 225,000 bbls
Surveyed and assessed > 2500 sites via four (4) industries
Disposal of > 400,000 bbls NORM
1000s of sample taken; 1000s of NORM gamma spectroscopy analysis
Supported 6 cases as expert and forensics witness
Supported > 300 clients
Authored > 100 licenses, worker protection, or waste management procedures
Established numerous laboratories, and trained > 1000 workers, surveyors, and RSOs
Designed NORM storage, decontamination, facilities, and mobile pipe cleaning systems
Acted as new rule advisory committee member to Mississippi Oil and Gas Board

Particular to NORM assessments and remediation, the challenges are unique and require an understanding of:

Atomic science, including Isotopes and their energy
Instruments limitations – or survey results will be misinterpreted and decisions led astray
- Instrument vs Isotope energies
- Instrument proximity and response requirements
- Target radiation types and their behavior
- Differences between instruments
Field and laboratory methods
The character of radiation in environmental or industrial settings
Nuances of regulatory requirements and exemption levels
Industry practices for waste management, equipment cleaning, and site operations

For remediation projects, Enpros services include:

Consultation on goals, risks, and constraints
Compliance and requirements consulting
NORM facility and land surveys, surface and subsurface sampling, and analysis
Contamination delineation
Volume estimates of (1) current in situ theoretical volumes and (2) probable post remediation volumes
Remediation planning and alternate methods
Transportation, Disposal, and Total Costs
Documentation and reporting

Site and Facility Closures

Site and facility closures are a specific type of assessment and remediation for which Enpros also has provided services, including:

Pit Closures
G Facility and Wellsite Closures
VCP/OCP Closures
Fuel stations

Environmental Sampling

Environmental sampling can be more challenging than first thought. Too, advanced sampling methods can provide opportunities for more accurate site information which can lead to approved cleanup levels specific to the site not based on general and more constricting assumptions. For any stage in the assessment-remediation cycle, Enpros can implement simple grab samples or complex, statistically based, composite sampling plans to provide you the accurate and thorough sampling, and parameter results you need.

Statistically and non-statistically based sampling
Grab, composite, biased, random, and systematic sampling
Soil, water, sludge, scale, and air sampling
Sampling plans derived field measurements lab analysis
Reliably representative sampling
Effective sampling of heterogeneous or homogenous sources
Surface, subsurface, tank, and equipment sampling
Professional representation of sampling efforts and results, and
Negotiation assistance with regulatory agencies for sampling plan development.

Environmental Modeling

When establishing environmental and cleanup limits for contaminants, regulations must by their nature be written to apply to a portion or complete swath of industry such as an entire state or nation. Not all portions of a regulated community, however, have the same conditions, such as background concentrations or processes by which their wastes are generated. The difference between a regulation’s ‘generalized’ limits and the limits at a specific site can differ though they both intend to protect public and environmental health.

Environmental models and advanced quantitative and statistical methods can be adopted by clients to calculate site specific limits which are often less strenuous and costly to implement while also providing greater proof that environmental protections are met. These site specific calculations are also similar to expectations for risk based assessments and cleanups and also the fault slip modeling when permitting injection-disposal wells to ensure seismic faults are not created by which injected fluids can migrate into underground sources of drinking water.

Enpros actively adopts environmental modeling and risk methods so that client projects achieve less costly and yet more reliable, defensible proof of protection. We have performed modeling and advanced statistical analysis for various scenarios, including:

NORM Remediation and Radium Exposure Pathway Analysis
Site specific background determinations for lead, TPH and barium in soil and TPH in groundwater
Fault Slip Modeling for Injection-Disposal Well Permitting
Air emissions modeling for Class II SWD and Class I industrial fluid storage tanks

Negotiating NORM Cleanup and Land Use Limits: Practical Use of Dose Assessment and Cost Benefit Analysis

Due Diligence and Transaction Services

Enpros supports several aspects of the due diligence and transaction process. Environmental reviews and assessments are approached as both due diligence input to the decision on whether to proceed with the transaction (go-no-go) and also as input to the transaction phase where upgrade or capital costs, risk to operations, valuation, business assumptions, and transition and implementation plans become relevant. Overall, Enpros provides unique experience based input to both the environmental and the business diligence and transaction aspects of a potential purchase or sale.

Environmental Diligence
- Site Visits and Environmental Assessments
- Compliance Reviews
- Permit Diligence
- Health & Safety Diligence
Operation Diligence
Organizational Diligence
Market Diligence
Strategy Diligence

Environmental Due Diligence

Enpros works closely with clients to determine goals and uses of the environmental diligence phase so we can add optimal value. Generally, environmental due diligence services include:

Site Visit and Environmental Assessment

Phase I and II environmental assessments
Identify environmental conditions and evidence of leaks, spills, releases, disposal, discharges
Assess impacts onsite and offsite to soil, surface water, groundwater
Q&A with staff
Do conditions present risk to regulatory compliance action?
Assess quality of environmental controls, such as related to: waste storage, containment, and controls; Stormwater and run on/run off
Are conditions and systems sufficient for current and planned clients?
Do any conditions pose the risk of litigation?
Mitigation options and costs
Recommendations for additional investigation, if appropriate
Documentation based on client needs

Compliance Reviews

Public records, reports, aerial photographs
Compliance status and history
Are all required programs in place?
Do programs meet the regulatory requirements and that of current and planned clients?
Q&A with staff
Are reporting and documentation systems adequate?
Do any non compliance conditions warrant regulatory action and risk to operations?
Recommendations for follow-up and/or upgrade

Permit Diligence

Given business services, are required permits in place to authorize operations?
Are permit capacities sufficient for current and planned business strategy?
Are permit requirements being met?
If additional permits are needed, at what cost and time frame?
Do current systems support permit changes or are system or facility upgrades needed?

Health & Safety Diligence

While often concurrent with environmental diligence, health & Safety diligence differs somewhat with the skills needed and the focus.

Are all regulatory, industry, and client programs in place?
How are HSE practices integrated into operations?
What is the safety organization, reporting/approval, and funding process?
Are programs sufficient and the requirements met, in particular to:
- Hazard identification and personal protection
- Job Safety implementation
- Emergency procedures; Investigations; Reporting
Is the facility compliant with HSE programs?

Documentation based on client needs

Injection Disposal Well Due Diligence

Enpros has specialized expertise with injection disposal due diligence. Our operating, geological permitting, engineering, formation analysis, and investigation experience helps us thoroughly and reliably assess the status, risks and reliability of injection and disposal wells. We take a thorough, detailed view of:

Permit, File, and Records
Well and formation health
Pressure-Volume Analysis of well, formation, and locally/regionally
Well engineering, completion, casing, cement, etc.
Mechanical Integrity Tests and Maintenance History
Onsite operating practices (Site Visit highly recommended)

Transaction Services

Transaction services are provided separately or ideally integrated into the environmental and business due diligence efforts. Based on client goals, at this stage our services focus on:

Valuation

Mitigation or upgrade costs associated with:
- Environmental contamination
- Material condition of facility and systems
- Operational readiness and capacity of systems
- Permits (in place and sufficient to support planned capacity)
- Compliance programs and Health and Safety
- Reporting, compliance and workflow systems
Risks and threat to operations
Legal risks and threats
Needs for additional staff

Risks

Threats to operations and/or capacity from:
- Missing permits
- Regulatory non-compliance
- Material condition not sustainable
- Operating systems insufficient
Offsite environmental contamination and long term impacts
Legal risks

Integration and Change Planning

Managing the change in ownership, personnel and culture, operations, standards, and compliance practices can warrant consideration and planning. Enpros can provide valuable input on how to bridge the gap successfully from one organization to a new one.

Litigation and Data Forensics Services

Enpros has provided legal services to industry on NORM, environmental, and waste issues. We’ve been both plaintiff and defense experts and we understand the legal process. More importantly, we understand the science and standards that underlie these issues and the interpretation of liability. Our expertise, however, includes not just the domain of environmental issues but also the science of data systems and data. We provide services in:

Environmental, NORM, Groundwater, and Waste
Compliance and Regulatory standards and practices
Data and forensics consultants
- Investigate and interpret the source of submitted data including (1) original measurement systems and locations and (2) data system used to store and present data
- Interpret the quality and limitations of the data
- Understand what data is telling you and what it cannot
- Identify areas where misinterpretation arises
Turnkey Data Packages
- Data research, assimilation, QC, reporting, and code and GIS based analysis
- O&G Focus
  - O&G Production
  - Drilling and Completions
  - Injection Facilities, Rates, Volumes and Permits
  - Waste Facilities

Permits, Plans, Authorizations

Permits, authorizations, technical approvals and/or scientific support for various industries and applications. For more information …

Air
Pits
NPDES/LPDES
Soil Remediation
Groundwater Remediation
Environmental Sampling
Waste Acceptance Plans
SPCC
NORM
Industrial and Medical Radiation
Critical Infrastructure

Waste Management & Operations Plan
Responsible Carrier Plans
Integrated Contingency Plans
US Coast Guard Operations Manuals
Pollution Prevention Plan
Facility and Vessel Response
Facility and Vessel Security
Facility Security Assessments
Emergency Plans
Safety Plans

Project Scoping

Permitting projects can impact a business in many ways. Our project scoping is effective in prioritizing, understanding, considering, assimilating, developing and integrating a host of issues. By doing so, project success is enhanced greatly.

Prioritize business goals
Understand stakeholder concerns and expectations;
Assimilate compliance landscape and risks;
Consider all risks and unknowns;
Uncover areas for additional research;
Integrate company goals, constraints, and risks;
Identify costs and timelines
Develop a systematic, thorough process; and
Manage the complexity for business success and stakeholder confidence

Compliance Consulting

Enpros are compliance specialists who assist companies to understand compliance requirements and prudently select and implement appropriate practices, procedures, or programs. Enpros helps clients adopt compliance practices appropriate to their company, culture, goals, cost and personnel constraints.

Compliance and audit services are used to support:

Programs and procedures for compliance with specific regulations
Due Diligence and/or transaction needs
Preparing for client audits
Vendor auditing
Responding to regulatory violations or visits
Annual compliance reviews of companies, facilities, or specific operations or programs
Starting a new company, service, or facility in a new location

When assimilating requirements, we consider:

Regulations
Permits
Guidance documents incorporated by reference in regulations
Industry Standards
Client specific requirements
Expectations from contract management safety sites
Insurance considerations
Participation in regulatory programs such as VCP/OCP, Brownfield, Superfund

Compliance topics depend on the business services and operations, however, they can include:

Regulatory requirements based on business service and practices
Permit requirements
- Air, water, waste, discharge
- Monitoring, reporting, and recordkeeping
- Out of spec instances
- Instances and responses to violations
Waste practices such as storage, containment, and run on/run off, disposal
Waste acceptance procedures (for waste service companies)
Safety Program Compliance and Management
- Organization structure, reporting, and funding
- Hazard ID and industrial hygiene practices in place
- Written programs in place based on potential hazards
- Operational implementation of safety controls
- Safety statistics and events
- Engineering design compliance
- Inspection and testing requirements
- Electrical, flammability and combustibility compliance
- Emergency Procedures
- Training program

Audit Services

Enpros facilitates audits and audit preparations for the following purposes and criteria:

Regulatory Reviews and Approvals

Client and Contract Approvals

Evaluating Facility and/or Company Readiness and Risks

Compliance Software (ComFlow)

State of the Art Compliance Management and Work flow (ComFlow) for Compliance Confidence and Program Excellence

Customer and regulatory expectations can amount to very significant work loads. Compiling, tracking, and ensuring successful completion of literally 100s or 1000s of specific tasks is not insignificant. We have developed a state of the art compliance management system (ComFlow) that provides 100% compliance confidence and serves as a springboard to excellence. As a tool, ComFlow is provided to clients or implemented as a service to:

Identify programs and compile and categorize associated requirements
Assess and select best management practices
Assign the task a frequency and to particular person or role
Implement compliance tasks via a Monthly Task list sent to the assigned person
Track and follow up actions are based on specific company culture, staffing and goals

Monitoring and Reporting

Monitoring and reporting are expectations for many companies and facilities, especially arising from permit requirements. Enpros provides services related to:

Quarterly, Semi Annual and Annual permit reporting
Groundwater well monitoring
Facility perimeter monitoring for NORM and radiation
Emissions monitoring
Industrial hygiene monitoring

In addition, Enpros prepares reporting systems to help compile, organize and present information as needed to fulfill reporting requirements.

Environmental, Waste, Reporting Software

Enpros provides specialized software and data systems for environmental, waste, operations, compliance and science workflows. We have the domain, topic understanding and the data and software expertise to build targeted, effective systems that greatly improve work efficiencies and success:

Remediation Team Workflow System
Waste acceptance systems for verifying O&G operators, leases, and wells
Waste load Tracking and Reporting
Compliance Management
Project Archiving and Reporting System
Field and waste shipment verification of H2s Potential
Laboratory Analysis