HRP Associates, Inc - International Environmental Services Projects

International Environmental Services Projects

Environmental Liability Assessment & Reserve Evaluation, Sao Paulo, Brazil

Each year, HRP assists this client in evaluating the adequacy of environmental reserves for U.S. manufacturing operations based on new site information or changes in regulatory programs. In recognition of the global economy, HRP now offers this service for international manufacturing operations as well.

HRP conducted an environmental liability assessment at the Sao Paulo facility to establish a basis for reserve evaluation. By using HRP, our client was able to leverage our institutional knowledge of its U.S. operations and risk tolerance, and develop realistic remediation scenarios and reserve costs consistent with those already developed for its U.S. operations. To calibrate HRP’s knowledge of its client’s needs to the local environmental regulatory climate, HRP partnered with a local environmental engineering and consulting firm.

Recognizing that many of the informational resources typically consulted in an ASTM-style Phase I ESA would not be available, HRP developed a scope of work to collect and review, the essential information needed to assess current and historical operations for potential impact to the environment. Prior to conducting the site inspection, HRP and its local partner met to review the scope of activities and the organization and jurisdiction of governmental regulatory programs.

HRP began and ended the multi-day site inspection with a meeting that included the facility’s top management. The meetings explained the objectives and scope of our work and provided our overall impression of their operation. Although details of the inspection and recommendation are not always discussed, HRP believes such meetings are essential in opening lines of communication and overcoming concerns that the facility is “being watched.”

The Sao Paulo facility has been in operation since the early 1960’s. Interviews with several early employees were conducted with our local consultant serving as translator. The site inspection included a detailed review of the facility’s non-ferrous foundry, metal stamping, and injection molding operations. Raw material and waste storage and disposal records, receipts and analytical data were also reviewed.

An inspection of the plant grounds and a "windshield survey" of the surrounding area were used to gain an understanding of local topography, stream drainage, and possible groundwater flow direction. Available information on local/regional groundwater and surface water resources as well as geologic, hydrogeologic, and soils mapping were provided by our local partner. Pertinent facility files, including prior environmental investigations and audits, were reviewed to assess the extent, type and outcome of interaction between the facility and the various environmental regulators and municipal government.

A report is being prepared that describes plant operations and conditions and any practices or areas of concern that indicate soil and/or groundwater may have been impacted. Although a detailed compliance audit was not conducted, areas where best management practices are being used as well as areas warranting further review will be discussed.

The report will be used to develop potential remedial scenarios and associated costs. HRP’s local partner will assist in identifying remedial approaches and techniques that are typically accepted by the local authorities. Remedial costs will be presented in U.S. dollars based on construction costs using local labor.

Environmental Management Information System/Health & Safety Management, Reynosa, Mexico

HRP Associates, Inc. has developed a customized computerized Environmental Health Safety Management Information System (EMIS) for the Reynosa, Mexico facility of an international, multi-facility tool/appliance manufacturer. The EMIS is designed for the organization, management and access of the facilities’ digital Material Safety Data Sheet Library. The system is installed on the corporate intranet and accessed by users at the Reynosa, Mexico facility. All portions of the MSDS Management System, which was developed in English, have been translated to Spanish.

The project involves the following:

Researching and inventorying internal procedures and processes to determine how they might be included in a computerized Environmental Health and Safety Management Information System.
Translation to Spanish of the English version of the existing Environmental Health and Safety Management Information System.
Planning and design coordination with both English speaking corporate and Spanish speaking Reynosa, Mexico personnel.
Customization and installation on the corporate intranet of a Material Safety Data Sheet management system.

The MSDS management system is accessed by all corporate facilities including those in Spanish-speaking countries. HRP staff also carried out the image and data entry related to the Material Safety Data Sheets.

Environmental Liability Assessment & Reserve Evaluation, Mexicali and Nuevo Larado, Mexico

HRP Associates, Inc. was retained by this water heater manufacturing company to assist in the environmental engineering and health & safety compliance efforts in converting their manufacturing operations to a new, innovative process. Specifically, HRP was asked to secure air quality permits for a flammable VOC source, as well as to provide safety management planning according to OSHA Regulation 29 CFR 1910.119 Process Safety Management.

In association with the introduction of the new process, HRP and its subcontractors assisted the company in the electrical/instrumentation, mechanical, ventilation, fire protection, and structural upgrades to existing plant equipment and processes. HRP is conducting this project to meet all requirements of the Mexican authorities including: local/state Fire Marshals, Environmental Regulations, fire codes, electrical and safety codes.

Environmental Liability Assessment & Reserve Evaluation, Scarborough, Ontario, Canada

HRP Associates, Inc. assists this client in evaluating the adequacy of environmental reserves for its U.S. manufacturing operations each year, based on new site information or changes in regulatory programs. In recognition of the global economy, HRP now offers this service for international manufacturing operations as well.

HRP conducted an environmental liability assessment at the Scarborough facility to establish a basis for reserve evaluation. By using HRP, our client was able to leverage our institutional knowledge of its U.S. operations and risk tolerance, and develop realistic remediation scenarios and reserve costs consistent with those already used for its U.S. operations. To calibrate HRP’s knowledge of its client’s needs to the local environmental regulatory climate, HRP partnered with a local environmental engineering and consulting firm.

Recognizing that many of the informational resources typically consulted in an Canadian Standards Association Phase I ESA (Z768-01) would be essential in defining the potential liabilities associated with present and past site uses, HRP developed a scope of work to collect and review the essential information needed to assess current and historical potential for impact to the environment.

Prior to conducting the site inspection, HRP and its local partner met to review the scope of activities, informational resources and the organization and jurisdiction of governmental regulatory programs. The general findings of the evaluation were reviewed with the local partner to assess the likely ramifications of the findings.

HRP began and ended the multi-day site inspection with a meeting that included the facility’s various managers (manufacturing, plating, foundry, etc.). The meetings explained the objectives and scope of our work and provided our overall impression of their operation. Although details of the inspection and recommendation are not always discussed, HRP believes such meetings are essential in opening lines of communication and overcoming concerns that the facility is “being watched.”

The Scarborough facility was constructed in the late 1950’s. Interviews with several long-term employees and present operations managers were conducted to assess present and historical site activities. The site inspection included a detailed review of the facility’s foundry, plating, metal stamping/grinding/machining and plastic injection molding operations.

Raw material, waste storage and disposal records, manifests, employee training materials, receipts and analytical data were also reviewed. Material safety data sheets (MSDS) for each department were reviewed to evaluate the type and volume of materials used at the facility Documentation of the facility’s asbestos containing materials was recorded.

An inspection of the plant grounds and the surrounding area were used to gain an understanding of local topography, stream drainage, and probable groundwater flow directions. Our local partner provided available information on local/regional groundwater and surface water resources as well as geologic, hydrogeologic, soils and other mapping. This data was used to assess the potential contaminant migration pathways at the site and provide a preliminary assessment of likely off-site receptors.

Pertinent facility files, including prior environmental investigations and audits, were reviewed to assess the extent, type and outcome of interaction between the facility and the various environmental regulators and municipal government.

A report is being prepared that describes current and historical plant operations and conditions, and any practices or areas of concern that indicate soil and/or groundwater may have been adversely impacted. Although a detailed compliance audit was not conducted, areas where best management practices are being used as well as areas warranting further review will be discussed.

The report will be used to develop potential remedial scenarios and associated costs. HRP’s local partner will assist in identifying remedial approaches and techniques that are typically accepted by the local authorities. Remedial costs will be presented in U.S. dollars based on construction costs using local labor.

Expert Witness Testimony, Stockholm, Sweden

HRP Associates, Inc. provided expert witness testimony in Stockholm, Sweden on the Resource Conservation Recovery Act (RCRA) regulations. HRP’s testimony, which was presented at a tribunal arbitration hearing, addressed the RCRA Closure and Post-Closure regulations for surface impoundments.

During the early 1990s, HRP completed RCRA Closure and Post-Closure activities at the corporation’s Bethel, CT facility. Two (2) surface impoundments were used from 1960 to 1988 at the Bethel facility for the settling of neutralized acid pickling wastewaters, cooling wastewater, and non-contact cooling water. Degreasing solvents, tetrachlorethylene and trichloroethylene, were also released to the lagoons.

Listed below are the key closure and post-closure activities completed by HRP. All activities were performed in accordance with the RCRA regulations contained in 40 CFR Parts 265.111 through 265.115 and State of Connecticut Hazardous Waste Regulations Section 22a-449(c)-105.

Chemical characterization of the settling lagoons.
Pressure testing of the underground effluent pipeline.
Delineation of the surrounding wetlands.
Design, installation, and sampling of the ground water monitoring system.
Design and installation of a ground water treatment system.
Excavation and removal of sludge and soil identified to be hazardous waste.
Excavation and removal of contaminated soil (non-hazardous waste) to the seasonal high ground water table.
Design and installation of the final cover for the former settling lagoons.

The tribunal arbitration hearing was held to determine which company (former owner or current owner – both Swedish companies) was responsible for the closure and post-closure costs. The hearing panel ruled that HRP’s client (the current owner) was not responsible for these costs. This favorable ruling was largely based on the expert testimony provided by HRP Associates.

For more information, please contact Howard Hurd, LEP, CPG, Andy White, LEP or Walter Gancarz, P.E. at 1-800-246-9021