Commercial/Industrial Client:After a multimedia inspection resulting from a neighbor’s complaint, the client received a proposed consent order from the NYDEC with a $50,000 penalty and requirements for compliance with applicable air, solid and hazardous waste regulations. LTP Services, Inc.:
ü Performed an audit of the facility and advised the client as to what actions were required to bring the facility into compliance.
ü Reviewed applicable air regulations and determined that registration, rather than full permitting, was appropriate.
ü Prepared the appropriate forms to register the air sources.
ü Arranged for sampling and analysis of various solid wastes.
ü Obtained disposal approval for solid wastes.
ü Negotiated with the NYDEC on behalf of the client. The result of the negotiation was an 80% reduction in the amount of the penalty and a payment schedule that fit with the client’s budget.
Commercial/Industrial Client:As a result of a USEPA inspection program, the client was advised that his septic tank would be classified as a class V underground injection well with attendant permitting and monitoring requirements. There was a significant likelihood that the system would have to be shut down. LTP Services, Inc.:ü Contacted USEPA to review the applicability of the regulations.
ü Determined that the facility qualified for a specific USEPA exclusion.
ü Arranged for sampling and analysis required to qualify for the exclusion.
ü Qualified the client for the exclusion. No additional actions were required.
Commercial Client:The operator of a pre-existing non-conforming use wanted to expand his operation. The scope of the expansion was greater than thresholds established under the New York State Environmental Quality Review Act (SEQRA). LTP Services, Inc. worked with the client and his attorney to provide the lead agency information required to obtain a “negative declaration” and allow the project to move forward. As part of the process, LTP Services, Inc. retained a surveyor, landscape architect and wetlands specialist to gather the information required by the lead agency. The applicant was subsequently issued a special use permit.
Industrial Client:An industrial surface coating operation was inspected by the NYDEC in response to a complaint. The DEC inspector advised the client that he was operating without appropriate permits and that enforcement action would be taken by the agency. LTP Services, Inc. worked with both the client and the DEC engineer to review the operation, including types of coatings used, hours of operation and other factors. After review it was determined that, with certain restrictions on operating hours and coatings used, the operation of the facility was such that a full permit was not required, and that registration would cover the operation. LTP Services, Inc. also worked with the client to implement a record keeping system that would demonstrate compliance with operating restrictions.
Industrial Client:As a result of a NYDEC inspection, a generator of hazardous waste was cited with numerous violations. LTP Services, Inc. assisted the generator with identifying steps that were needed to correct the violations and providing documentation to NYDEC that compliance was achieved.
Industrial Client:The client was leasing a facility. As part of the lease, the landlord had transferred an existing SPDES permit to the client. LTP Services, Inc. reviewed the permit and determined that the operations of the client were substantially different from the previous tenant, and, as such, a SPDES permit was not required. Correspondence was initiated with the agency and the agency concurred that a permit was no longer required.
Industrial Client:The client had responsibility for post closure care of a municipal landfill. An active gas extraction system had been installed and was operational. LTP Services, Inc. reviewed applicable regulations and determined that an active gas extraction system was not required by regulation. After discussions with the regulatory agency, an odor monitoring program was designed and implemented to assure the agency that passive gas venting would not result in unacceptable ambient impacts. After demonstrating that no adverse impacts would occur, passive venting was permitted, resulting in an annual cost savings of approximately $250,000.
Industrial Client:The client had identified an opportunity to utilize a waste material as raw material in the manufacture of a product. LTP Services, Inc. obtained the information necessary to prepare an application for a Beneficial Use Determination (BUD), prepared and submitted the application and obtained the BUD.
Industrial Client:The client required a discharge permit (SPDES) for a proposed water treatment system. LTP Services, Inc. prepared the permit application.
Commercial Client:The client had entered into a voluntary site investigation agreement with the DEC and discovered contamination. The client’s consultant had developed an expensive remediation plan. LTP Services, Inc. reviewed the proposed plan and developed a less costly alternative that was acceptable to the DEC.
Industrial Client:The client had disposed of solid waste illegally on a piece of property he owned. LTP Services, Inc. assisted in developing cleanup plans, documented the cleanup activities, arranged for groundwater sampling and prepared a final report for the DEC. We also assisted in obtaining legal counsel for the client to address criminal charges.
Commercial Client:The client was required to perform a groundwater investigation. LTP Services, Inc. prepared a request for proposal, solicited proposals and assisted the client in selection of a consultant to perform the investigation.
Industrial Client:The client was required to perform a stack test on an emission source. LTP Services, Inc. identified qualified contractors, issued RFPs, and assisted in the selection of a contractor to perform the work.