ETTL News & Views
Volume 12 • Fall 2004 Newsletter
The second issue of the new electronic version of ETTL's Newsletter … Keeping you up to date on what's happening at ETTL Engineers & Consultants … typical current projects … how we can be of service to you … links to our web site, people … and more!

MORE THAN NUMBERS
AND REGULATIONS!

Darrell Flatt
President
of ETTL

Jeannie Odom
P.G., C.P.G.
Geologist

John D. Howell
P.G., C.P.G
Project Manager

David Treadway
Project Manager

Daniel Richbourg
Environmental
Technician

Environmental consulting - at least good environmental consulting resulting from years of experience, common sense and good judgment, and backed by a personal and corporate philosophy of protecting client interests - is considerably more than just gathering, reviewing, and evaluating data. Good consulting requires understanding client objectives, an ability to limit liabilities for everyone involved, resourcefulness, and being able to provide solutions that satisfy all relevant parties, including agency personnel.

While the hourly rate of an environmental consultant with such qualifications and abilities should be competitive, it may not seem, at first glance, to point to the most economic solution. But the fact is, competent (good!) consulting can result in significant cost savings over the duration of a project, saving both time and money.

Below, we present some case studies on four typical small projects completed by ETTL. (Indeed, we completed our side of the fourth project almost instantly!) These case studies reflect our work, our ethics, and illustrate our general approach to consulting. Along with meeting the needs of our clients, we also want to build long-lasting relationships.

Case Study No. 1

A scrap metal company, designated as Company A, had inadvertently contaminated soils in three (3) different locations at a site. A complaint was made to the regional office of the Texas Commission on Environmental Quality (TCEQ). Company A hired an environmental consultant whose hourly rates were below typical competitive rates. The project stalled through no fault of Company A and the TCEQ. The TCEQ became very anxious about the lack of progress on the cleanup and informed Company A that the TCEQ-imposed deadline was fast approaching. Failure to meet the deadline would result in possible enforcement action, and the TCEQ regional office would refer the project to the TCEQ Austin central office. Company A then hired ETTL to complete the project in an expeditious manner. ETTL and a representative of Company A met with regional TCEQ personnel to explain the past delays and obtain an extension to prevent the project from being assigned to TCEQ Austin. The regional office was sympathetic and granted an extension, and expressed confidence in ETTL to assist Company A. The very next day, the TCEQ regional office received a memo from Austin indicating that any projects not resolved within a specified period of days must be referred to Austin. The project had already exceeded the specified time period provided in the memo. If referred to Austin, the project would require an Affected Property Assessment Report (APAR), as required under the Texas Risk Reduction Program (TRRP). APARs are very extensive and costly to prepare. Consulting time costs to properly prepare an APAR typically range from approximately $8,000.00 to $12,000.00. Company A and ETTL met with the TCEQ regional office to discuss the new memo from Austin. ETTL argued that referring the project to Austin and preparing an APAR would not benefit Company A (out of pocket approximately $10,000.00), the TCEQ, or the environment, and that the only entity to gain was the consultant (ETTL). Upon arguments made by ETTL on behalf of the client, the TCEQ agreed not to refer the project to Austin, provided the project was completed within an agreed upon deadline. The project was completed on time. Company A was very pleased and has subsequently referred work to ETTL.

Case Study No. 2

A small, rural independent school district in North Texas, which we will designate as XISD, called ETTL and asked that an environmental assessment be made on property the school system was obtaining for future development for use by students. ETTL interrogated the XISD representative and learned that the property was rural, undeveloped, and had been used for growing crops, including cotton, years before. Based upon this information, instead of recommending a routine Phase I Environmental Site Assessment (Phase I ESA), ETTL recommended an ASTM Transaction Screen Questionnaire (TSQ). The TSQ would provide enough information to determine and document any recognizable environmental concerns relative to the subject property, including concerns arising from adjacent or nearby properties, and would save the school system approximately $800.00. ETTL also recommended that limited soil sampling and analysis be conducted concurrent with the completion of the TSQ. Soil evaluation was recommended because the property was to be used as a public facility (used by children) and it had been previously used to grow cotton. Since arsenic was formerly used as a defoliant for cotton, the property's soil was evaluated for arsenic, other heavy metals, as well as pesticides and herbicides. By obtaining information during the initial contact with XISD, ETTL was able to perform these tasks concurrently with the TSQ, saving the school system valuable time and money. Some of the soil arsenic results, evaluated under the Texas Risk Reduction Program (TRRP), were above levels protective of human health. However, based upon ETTL's knowledge and experience with TRRP, which is a relatively new program for evaluating potential risks to human health and/or the environment at sites in Texas, the specific factors in this case for determining levels protective of human health were further evaluated and defined. It was found that the soil arsenic levels at the site actually were below TRRP levels protective of human health with regards to potential ingestion of soil, dermal contact, and inhalation. The limiting factor for arsenic in the property's soil was from potential ingestion of above-ground and/or below-ground vegetables grown in the affected soil. Therefore, the subject property actually was suitable and safe for its intended use, so long as provisions were made that it not be used to grow crops for human or animal consumption without further evaluation and/or permission from the TCEQ. By understanding TRRP and its nuances, ETTL was able to help the client evaluate the property and determine the real risks, if any. Since then, when they've needed environmental services, the school system has called us first. (Click here for a brief review, on ETTL's website, of what a Transaction Screen Questionnaire [TSQ] is, and how TSQ's can serve you. The review is on our website page dealing with ETTL's environmental site assessment services.)

Case Study No. 3

Company B hired ETTL to perform a comprehensive environmental audit for two (2) of their facilities. Company B already had a number of large, national and international environmental consulting firms performing various environmental services at their facilities prior to giving ETTL an opportunity. ETTL performed the audits and made recommendations, which the company followed. In fact, they transferred in an individual to handle their environmental affairs as we recommended. Up to that point, Company B had a poor history with the TNRCC (now TCEQ), but after implementing our recommendations they received their first "kudos" from the TCEQ. It was a welcome change of pace for them. But to us, the most striking outcome of our audit was that one of the prior environmental firms hired by Company B had reviewed and classified all of the wastes being generated by the company. ETTL estimated that at least $30,000.00 had been spent in unnecessary analytical services to classify the wastes. No one knows if it was done purposely to generate money for the consulting firm and/or laboratory, or if it was just a result of unfamiliarity with waste classification procedures: i.e., from not utilizing process and generator knowledge so that only necessary analytical work would be carried out. Either way, it cost Company B $30,000.00 for services that were not necessary. We have continued to perform services for this company.

Case Study No. 4

(While this case study is associated with the operation of our former analytical laboratory, it speaks volumes about our consulting ethics and our concern for our clientele.)

An ETTL consultant was in the ETTL analytical laboratory when a representative of a manufacturing concern (Company C) walked in with some solvent-contaminated rags from the company's facility. He asked us to analyze the rags for TCLP volatile compounds and indicated that cost was not a significant factor. We asked some questions, and he indicated that Company C was spending at least $10,000.00 or more every single month to dispose of these rags as a hazardous waste. He indicated the company considered these costs unbearable. In an attempt to minimize them, they were taking the solvent-laden rags, placing them into screened containers and then setting the containers outside to allow the solvents to evaporate in ambient air. They were hoping to reduce solvent levels to a low enough level to reduce the classification, so they could dispose of the rags in a cheaper manner. ETTL explained that the rags might be a "listed" hazardous waste, and as such, analytical laboratory services would not have a probable bearing on reducing the classification, since the waste was by definition an "F-listed" waste from degreasing operations (rags have always been a tricky subject). Furthermore, the evaporation of the solvent from the rags was (and is) a clear violation of TCEQ and EPA rules.

At this point the Company C representative was clearly frustrated. ETTL then suggested Company C contract with a linen/uniform supplier for rags. Once the rags were used, they would be placed in a container that would not allow solvents to evaporate, and the supplier would come pick up the dirty rags and replace them with clean rags. The supplier would have the proper permits to conduct these types of operations, and it was certainly permissible and legal to do so and, in fact, encouraged by state and federal agencies. The Company C representative was clearly happy to hear all this and rushed off to tell his company the good news. ETTL had just talked itself out of revenue for performing analytical services, and had just offered advice and recommendations that saved Company C at least $10,000 every month. ETTL offered this basic information unsolicited, and it only took a few minutes of our time. Therefore, Company C was never billed. But, it was the right thing to do. In this particular circumstance, the excited individual from Company C left in such a hurry to tell his boss the news that he forgot to even say thanks. We've haven't heard again from Company C, although we do know they immediately hired a linen/uniform company to perform these services. A disposal company specializing in hazardous waste was not, at that particular point in time, very happy with ETTL.

"The bitterness of poor quality lasts longer than the sweetness of cheap price,
which is soon forgotten."

We don't know who first came up with this
quote, but we whole-heartedly concur!

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