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Manufacturing

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MANUFACTURING

Manufacturing sites including machine shops are increasingly being monitored for compliance, because of the huge costs involved in environmental remediation and legal expenses towards environmental liability.

Federal law requires the manufacturing site owners or operators that manage hazardous waste to register on which a manufacturing facility has been brought into service, acquired by a new owner, operator, or property owner, or had a modification (includes an upgrade and replacement).

Golars offers wide range of services for properties with current or former manufacturing facilities.

Golars offers full-service compliance management services to assist clients in keeping up with constant changes in the regulatory environment. Sign Up for more details.

  • Has your site been inspected by the state, local or federal regulator?
  • Have you ever received a violation from the regulator?
  • Have you ever been denied coverage for remediation?
  • Have you ever signed an enforcement order?

If any of these matters sound familiar to you, we can help!!!  We are experts in drycleaner compliance.

Dealing with federal, state and local agencies is very hard, they have their own way of doing things.  Golars’s experienced staff works with several agencies on a regular basis and we know what they look for and we provide the right information. Effectively working with regulators is important for a regulated site.

Golars is leader in compliance management and assist clients in meeting their regulatory obligations.

  • Hazardous Waste Management

    Primary Violations for Hazardous Waste Sites include the following:

    • Lack of a proper waste determination
    • Satellite containers of hazardous waste not properly managed
    • Containers not marked with the words “Used Oil”
    • Hazardous waste containers not marked with the start of accumulation date
    • Lack of training or training documents
    • Containers not marked with the words “Hazardous Waste”
    • Lack of a proper contingency plan
    • Satellite containers not properly marked
    • Release of contaminants
    • Hazardous waste containers not closed

    Areas where Golars can assist you:

    • Obtaining a RCRA Identification Number
    • Waste Management – Analytical Data Deliverable Requirements and Guidance
    • Antifreeze Regulation under the Hazardous Waste Rules
    • Containment System Guidance for Permitted Container Storage Areas
    • Contaminated Wipes and Reusable Cloth Items and and Proper Storage & Disposal
    • Hazardous Waste Contingency Plans
    • Hazardous Waste Personnel Training
    • Satellite Accumulation of Hazardous Waste by Generators
    • Staging Policy for Permitted Hazardous Waste Management Facilities
    • Tank Inspections
    • Generator Documentation
    • Treatment of Hazardous Waste On-Site by Generators
    • Universal Waste Rule Compliance
    • Used Oil Filters – Used Oil Rule Compliance

    Common Regulatory Forms:

    • Hazardous Waste Self Audit
    • Requests for an ID Number or updates to an existing ID number

  • Solid Waste Management

    PRIMARY VIOLATIONS

    • Buriat Burning, and Dumping Violations
    • Composting and Yard Waste Violations
    • Landfill Violations Compliamnace and Monitoring Violations
    • Processing and Transfer Facility Violations

    SOME OF THE AREAS WHERE GOLARS CAN ASSIST YOU

    • Storing, classifying, and disposing Municipal Solid Waste, including Residential, Commercial, institutional and Industrial Non-Process Waste
    • Storing, classifying, and disposing Non-Municipal Solid Waste, including Construction and Demolition Debris, Foundry Waste, Coal Ash, Flue Gas Desulfurization Byproducts, Reuse material for landfills, as well as other types of solid waste
    • Storing, classifying, and disposing Industrial Waste
    • Storing, classifying, and disposing Restricted Waste
    • Contaminated Wipes and Reusable Cloth Items and and Proper Storage & Disposal – Universal Waste Rule Compliance – Used Oil Filters – Used Oil Rule 329 IAC 13 Compliance

    COMMON REGULATORY FORMS

    • Permitted Solid Waste Facility Quarterly Reports
    • Solid Waste Disposal Fee Report – Solid Waste Management Fee Return – Landfill Capacity Annual Survey Report – Registered Composting Facility Annual Report

  • Storm &Waste Water Management

    PRIMARY VIOLATIONS

    • Illegal chemical discharge into State waterways
    • Record-keeping violations
    • Documentation violations
    • Chemical contaminant exceedances
    • Monitoring frequency violation
    • Reporting inadequacies and/or violations

    SOME OF THE AREAS WHERE GOLARS CAN ASSIST YOU

    • Develop, submit, and review Construction Plans
    • Sample storm water, prepare and submit Rule 5 and Rule 6 letters and plans
    • Floodplain management
    • Storm water  management plans
    • Waste water  management  plans
    • Permit applications
    • Regulatory Correspondences

    COMMON REGULATORY FORMS

    • Construction/Land Disturbance Storm Water Permits (327 IAC 15-5, Rule 5)
    • 401 Water Quality Certification Program (IDEM, Office of Water Quality)
    • Construction in the Floodway (Department of Natural Resource, Division of Water)
    • Industrial Wastewater Permits (IDEM, Office of Water Quality)
    • Rule 6: General Permit Annual Report
    • Rule 6: Industrial Storm Water Discharge Monitoring Report
    • Rule 6: Notice of Intent (NOi) Letter
    • Rule 6: Storm Water Pollution Prevention Plan (SWP3)
    • Rule 6: Notice of Termination/Exclusion (NOT/E) Letter

  • Drinking Water Management

    PRIMARY VIOLATIONS

    • Not meeting operator site visit requirements
    • Record-keeping violations
    • Documentation violations
    • Chemical contaminant exceedances
    • Monitoring frequency violation
    • Reporting inadequacies and/or violations

    SOME OF THE AREAS WHERE GOLARS CAN ASSIST YOU

    • Autonomous reporting and monitoring reminders to stay in compliance
    • Drinking water sampling audits to assure compliance
    • Provide assistance with regulatory form updates and completion
    • Provide emergency support in case of chemical exceedances to assist with regaining compliance
    • Provide support with specialized issues
    • Provide support with regulatory form compilation and submittal
    • Wellhead Protection Plans and Updates

    COMMON REGULATORY FORMS

    • Wellhead Protection Plans
    • Application for Construction Permit For Public Water System
    • CCR Certification in Drinking Water
    • Chlorine, Chloramines Residual, Inorganic chemicals, Total Co li form . Synthetic Organic Compounds (SOC’s), Trihalomethanes (TTHM), Volatile Organic Compounds (VOC’s), Haloacetic Acids (HAAS), Lead, and Copper Reporting
    • Filter Backwash, record keeping, and monitoring
    • Monthly Reporting for various chemicals
    • Monthly Report of Water Treatment Plant Operation
    • Monthly Total Organic Carbon Removal Reporting
    • Notice of Intent to Construct a Water Main Extension
    • Stage 2 Reporting  – Including  Disinfectants  and Disinfection Byproducts      Rule, Distribution System, Source Water, Summary, Operational Evaluation, and Treatment Process
    • Water Quality Parameters & Source Reporting

Golars specializes in assisting clients with financing real estate.  Environmental reports play a major role in financing of all regulated properties.

Several clients have incurred thousands in loan expenses only to realize they have environmental condition at their property and could not get their loans processed.

Golars offers low-cost desktop screening to identify potential environmental conditions on the property.  This is limited in nature but can be helpful in identifying environmental conditions in advance.  Golars recommend clients having the environmental data before proceeding with financing, to avoid unforeseen delays at a later stage.

This is typically done prior to completing Phase I Environmental Site Assessment by the lending agency.

Golars perform Phase I Environmental Site Assessment (ESA) throughout the country on every conceivable property type from raw land to industrial, office, retail, multi-family, and mixed-use buildings.

The purpose for having the Phase I ESA performed is to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations on CERCLA liability (hereinafter landowner liability protections or LLPs).

The scope of Phase I ESA will include records review, reconnaissance, interviews, and preparation of a report.

Our experienced staff can assist clients in minimizing the legal, financial, and environmental liabilities and manage regulatory compliance in real estate transactions.

A Phase II Environmental Site Assessment (ESA) is usually required when an environmental condition is discovered during a Phase I Environmental Site Assessment or when additional environmental testing is recommended because of site conditions.

The intent of the assessment is to screen soils and groundwater for potential contamination due to the historical use of the property.

The following activities are performed during Phase II ESA:

  • Underground utilities locating
  • Installation of soil borings and groundwater monitoring wells
  • Field screening to identify contaminants of concern
  • Soil and groundwater sample collection for laboratory analysis
  • Documentation, report preparation and recommendations

Phase II ESA plays a major role in determining the path forward for the property.

Golars has teamed up with several private investors specializing in acquisition of commercial properties containing dry cleaner facilities.  We assist several private investors in performing due diligence for their acquisition.

Over 1,000,000 sq.ft of commercial space was acquired through 2019 where Golars performed diligence.  Because of continued demand in commercial, logistics and warehousing space their appears to be large appetite in acquiring real estate.

Golars assists property owners in ensuring they maximize the value of the real estate, this is what makes Golars a unique company in the market.

Regulated facilities may have environmental conditions, mostly historical and unknow to the current property owner.  However, it is an expensive affair because of the huge costs involved in environmental remediation and legal expenses incurred towards environmental liability.

Third party funding plays a very crucial when the facility has environmental contamination.  Golars has recovered over $500 Million in third party funding for several clients and we continue to pioneer in this field.

There are three types of clean-up funds:

  • Insurance Recovery

    Golars is market leader in insurance recovery, we are in fact the best in the industry.

    Digging up the details of historical insurance coverage is a critical first step in minimizing the company’s direct exposure and securing valuable coverage that may be far more than just a thing of the past.  Companies may be able to seek recovery from their historic insurance policies to help provide defense and indemnity coverage for claims they face.  These policies can be a significant contingent asset, but, if an appreciable amount of time has passed, a policyholder may lack sufficient information about the policies to make a valid claim.

    Our experts conduct insurance archaeology research to identify and locate the policies or evidence of those policies.  Our approach begins with the most cost-effective tasks and, as necessary, proceeds to include additional effort.  Information sources include other policies, accounting and financial records, various archives, and employees. Our efforts often can locate policies or other evidence of coverage, which can place a policyholder in a stronger position to make use of the insurance asset.

    Many companies and organizations face mass tort and complex liabilities that significantly affect their financial outlook.   Allegations surrounding these types of liabilities can span decades and include “long-tail” exposures.

    Golars is a trusted adviser to help you reduce environmental risk and achieve your business goals

  • Environmental Clean-up loans

    Potential environmental problems on collateral property represent one of a commercial lender’s largest risk exposures. The discovery of previously unknown contamination can cause a property’s value to plummet, while simultaneously entailing remediation costs far in excess of any remaining value derived from the property. These costs can quickly become the lender’s problem when the borrower defaults on the loan and the lender takes title to the property.

    Golars Capital, LLC is a sophisticated lender with the ability to “box in” the potential environmental risks and close deals that other lenders would be unwilling to touch.

    Golars Capital, LLC provides below-market low-interest loans of up to $100,000 to conduct preliminary environmental site assessments and up to $1.5 million for the cleanup or removal of hazardous substance or petroleum site where redevelopment likely to have a beneficial impact on the property values, economic viability and quality of life of a community.  Eligible borrowers include all potential responsible parties.

  • Federal, State, and local funds

    In some states, there are grants available for investigation and remediation of contaminated properties.  Some grants are specific to property types and some are brownfield grants.

    • Risk-Based Corrective Action, Mitigation & Closure
    • Contaminated Facility Closure and Decontamination
    • Soil Management Plan Development and Oversight
    • Waste Characterization, Profiling and Disposal
    • NFA letters, Comfort letters, Environmental
    • Restrictive Covenants (ERCs)

     

Releases from Dry Cleaners are not uncommon in the industry. Golars expert engineers, geologists and scientists can respond to the specific needs of the project, managing the environmental investigation and remediation with minimal disturbance to the existing operations, and assist in the following areas:

  • Initial release action and reporting
  • Emergency response
  • UST system removals and closure
  • Soil and groundwater investigation to delineate on-site and off-site subsurface contamination
  • Corrective action of soil and groundwater contamination
  • Third party funding

Golars personnel have extensive experience in providing consultation with federal, state and local regulators, voluntary remediation programs, and Brownfield programs, and provide site investigations, health risk assessments, risk prioritization and analysis of Brownfield cleanup alternatives to maximize public-private investment dollars.

Golars engineers provide clients with a wide spectrum of remediation strategies and corrective action plans with cost effectiveness. Some of the technologies that we use are excavation and disposal of source material, Pump and Treat of impacted groundwater, Soil Vapor Extraction (SVE), In-situ Air Sparging, High Vacuum Dual-Phase Extraction (DPE), In-situ Bioremediation ORC and Monitored Natural Attenuation.

Golars is experienced with the design and implementation of several industry-accepted remediation strategies while considering important soil, groundwater and contaminant characteristics in the selection of an appropriate remediation strategy.  Some of the services we offer include the following:

  • Remediation System Design, Installation & Implementation
  • Remediation System Operations & Maintenance (O&M), Performance Evaluation and Decommissioning
  • Groundwater Modeling and Remediation
  • Soil Vapor Extraction/Air Sparging/Dual-Phase Extraction
  • NPDES Permitting and Monitoring

Vapor Intrusion (VI) is the migration of volatile chemicals from the subsurface into overlying buildings with a potential for health risk due to exposure. Our staff is experienced in addressing VI issues through multiple lines of evidence, including sampling groundwater, soil gas, sub-slab air and indoor air, and considering building construction model, site geology and site historical data.

Exposure risk can be mitigated through soil remediation, groundwater remediation, vapor barriers and/or vapor mitigation systems which remove the harmful chemical vapors from the indoor environment.  Some of the services we offer include the following:

  • Vapor Intrusion Investigations
  • Indoor and Outdoor Air Sampling
  • Soil Gas Sampling
  • Data Evaluation and Interpretation
  • Sub-slab Port Installation and Sampling
  • Vapor Barriers and Mitigation Systems

When there is an emergency Response, Golars is available to help.  It may be a minor spill or major leak, Golars can help.

Call us at 317-500-0000 or email at [email protected]