Environmental Compliance Projects

Environmental Compliance Projects (2015 – 2020)

Creekside has conducted ten multi-media comprehensive environmental compliance audits for various NW clients in the last five years, including STS Intermodal, Trillium U.S., Premier Jets, Simonds International, JSR Micro, Pioneer Metal Finishing, and A-dec, Inc. Each of the audits have included a thorough review of facility operations, interviews with key staff, file review, site inspections, assessment of current operating practices with respect to established, mandated State rules and regulations; summaries of our findings, conclusions, and recommendations. The projects take about a month to complete and serve as a valuable tool prior to any regulatory audit that may occur in the future.

Waste Stream Determination Update – Stimson Lumber Company, Multiple Facilities in Oregon & Idaho (Oct 2015 – Present)

Creekside was hired by SLC to review existing waste stream determinations and other associated documents and revise and update them to be consistent with current State agency hazardous waste rules and regulations. We are currently in the process of completing this project.

Comprehensive Environmental Compliance Audit – Fujimi Corp., Tualatin & Wilsonville, Oregon (April 2014 & 2015)

Creekside has been conducting multi-media environmental compliance audits for Fujimi’s two Oregon facilities for two years now and it’s resulted in very positive, compliant results with all applicable local, State and federal agency requirements.

Chemical Inventory Reporting (HSIS Survey) – Western Emulsions, Inc., White City, Oregon (May 2015)

Creekside worked with WEI’s environmental compliance manager and the Oregon State Fire Marshall’s office to accurately complete the 2015 hazardous substance information survey (HSIS). The work involved reviewing chemical inventory lists, Material Safety Data Sheets, OSFM’s forms and all of the sections in each form.

Environmental Compliance Planning & Auditing – A-dec, Inc., Newberg, Oregon (January – June 2015)

Creekside has been assisting A-dec for 12 years with preparation of SPCC plans, Storm Water Pollution Control Plans, compliance audits, USEPA Form R planning, Oregon State Fire Marshal planning, TSCA regulatory evaluations, air compliance work, Hazardous Waste Management reporting & recordkeeping, and Toxics Use Reduction & HW Reduction plans. We have worked successfully as a team in achieving A-dec’s goals for environmental responsibility.

Spill Prevention & Storm Water Planning & Reporting – Bimbo Bakery, Beaverton, Oregon (January 2014-April 2015)

Creekside prepared a new SPCC plan and Storm Water Pollution Control plan for one of the largest bakery operations in the US, and we’ve continued to assist Bimbo with additional work to enhance their operations and assist them in achieving their goals related to full environmental compliance with local, State & federal rules and regulations.

Preliminary Environmental Review – Confidential Wood Furniture Manufacturer, Grants Pass, Oregon (October 2014)

Creekside visited the subject site and completed a multi-media environmental compliance audit at a wood manufacturing facility in Grants Pass, Oregon. The audit covered interviews with key production staff, review of existing production and environmental operations including hazardous materials use, chemical inventory reporting, air quality permit files including the Oregon Occupational Safety & Health Administration (OR-OSHA) inspection reports, their Air Contaminant Discharge Permit application, material safety data sheets, an operation & maintenance plan, and emissions worksheets.

Air Pollution Control Discharge Permit Audit & Calculations for Potential to Emit — Rivergate Scrap Metal Recycling Facility, Portland, Oregon (August – October 2011)

Creekside was retained by RSM to conduct a comprehensive air quality audit and to determine compliance with current DEQ air pollution control rules. We were able to negotiate with DEQ and avoid point source stack testing in lieu of producing a well researched comparison study with other documented and permitted facilities with similar shredding equipment that produced similar air emissions. We also agreed to complete several DEQ Air Quality forms and a Land Use Compatibility Statement. The purpose for this project was to provide technical information for DEQ to show that our client (RSM) was in compliance and that their potential to emit was well within DEQ guidelines by using air emissions data from similar facilities with similar pollution generating and control equipment. To satisfy DEQ, Creekside provided technical data from similar air sources and we were able to prove (to DEQ) that RSM’s baghouse and Z-box cyclone could be omitted from future air quality monitoring and reporting.

Implementation of Zero Wastewater Discharge System – A-dec, Inc., Newberg, Oregon (January 2011-July 2012)

Our client decided to avoid obtaining a wastewater discharge permit under EPA’s Metal Finishing Category and hired Creekside to assist in the design, construction, permitting and budgeting for a zero wastewater discharge system at its Newberg, Oregon facility where they manufacture dental equipment (over 500 employees). Creekside’s scope of work involved coordinating with City of Newberg Source Control Supervisor, development and implementation of a work plan, identifying recycling machines that could reuse wastewater and evaporate other liquid wastes, and providing permitting support.

Comprehensive Environmental Compliance Audit – Trillium US, Inc., Clackamas, Oregon (June 2012)

Creekside successfully completed a multi-media environmental compliance audit at Trillium’s Clackamas, Oregon facility. The audit covered a full review of existing production and environmental operations and we provided valuable recommendations in several regulatory programs including hazardous materials use, chemical inventory reporting, hazardous waste stream determinations, air quality emissions, wastewater generation & discharge and storm water management.

Environmental Compliance Assistance – Major Scrap Metal Facility in Portland, Oregon

Creekside conducted multiple environmental compliance audits for hazardous waste storage, waste water treatment, storm water and air discharge, and health and safety protocols at a 500,000 square feet scrap processing facility in Portland, OR. The audits included evaluation of non-contact cooling water, industrial wastewater, storm water, domestic wastewater and hazardous waste and air permitting management issues. After providing onsite training and completing several environmental plans, permit and reports, Creekside assisted in bringing the facility into compliance with CA State and federal regulations and permits. Creekside assisted in implementing improved training and total quality management practices to ensure continued success.

Environmental Compliance Audit & Facility Investigation – Confidential Client, Beaverton, Oregon (April – June 2010)

Creekside conducted a full scale compliance audit at a Beaverton, Oregon manufacturing facility that has been in operation since 1974. Production, processes, hazardous waste and chemical management required adherence with DEQ and U.S. Environmental Protection Agency (USEPA) regulations. The audit included evaluation of air, wastewater, storm water, hazardous waste and chemical management issues. Based on audit findings, Creekside developed for this company a Personnel Training Plan, a RCRA Emergency Preparedness and Contingency Plan, a Toxic Use Reduction and Hazardous Waste Reduction Plan, and Hazardous Waste Determinations Report. We also conducted a comprehensive environmental investigation at the facility including assessment of soils and groundwater, prepared a report for DEQ and obtained an NFA determination from DEQ for the site in November 2004.

Air Pollution Control Discharge Permit Audit & Source Testing – Adec Manufacturing Facility, Newberg, Oregon (February-Nov. 2010)

Creekside completed a comprehensive evaluation of the A-DEC, Inc. manufacturing processes and associated potential to emit air pollutants based on chemical use, production rates, and pollution control equipment for your Newberg, Oregon operations. The purpose of this project was to evaluate the A-dec operations for compliance with Oregon Department of Environmental Quality (DEQ) Air Contaminant Discharge Permit (ACDP) rules. Based on our calculations, we determined that A-dec did not exceed 2,500 metric tons of carbon dioxide emission equivalents per year. We were also able to demonstrate that gasoline throughput at its onsite fuel station is always below 10,000 gallons per month. As a result, A-dec no longer needs a simple ACDP permit and no longer conducts onsite monitoring.

Environmental Compliance Program Development & Site Assessment – Chemical Tote Cleaning & Storage Operation (KPM), Vancouver, WA (2006-2010)

Project involved conducting full scale environmental compliance audit, preparation of several compliance plans (HASP, Personnel Training Program, Hazardous Waste Management Plan) for WA Dept. of Ecology; arranging for air monitoring, preparation of a formal work plan to conduct subsurface investigation, completion of comprehensive assessment of shallow soils and groundwater, preparation of several reports.

Environmental Compliance Audit – MRP Services, Inc., Portland, Oregon (February – April 2007)

Creekside conducted facility-wide audit, addressing stormwater and wastewater permitting compliance, materials management, spill prevention, housekeeping practices, and record-keeping. Creekside discovered where MRP’s deficiencies occurred (dating back to 2002), and executed appropriate plans to correct them. Created an in-house Compliance Schedule and Calendar, Housekeeping Schedule and Checklist, and created a full environmental record-keeping system for the facility. Also conducted records reviews and agency correspondence, submitted NPDES 1200Z Permit and Wastewater Treatment Permit renewal applications, and updated facility process charts.

Environmental Compliance Audit & Facility Investigation – Tosoh Quartz Facility, Portland, Oregon (April – June 2004)

Conducted the audit at a 1.5-acre quartz glassware manufacturing facility, in operation since 1974. Production, processes, hazardous waste and chemical management programs were successfully evaluated and audited by Creekside. The audit also included evaluation of air, wastewater, storm water compliance. Based on our audit findings, Creekside developed for this manufacturer a Personnel Training Plan, a RCRA Emergency Preparedness and Contingency Plan, a Toxic Use Reduction and Hazardous Waste Reduction Plan, and Hazardous Waste Determinations Report.

Environmental Compliance Water Audit – Blount, Inc., Milwaukie, Oregon (February-April 2007).

Conducted an audit on all water systems at a 370,487 square feet saw chain, accessories (sprockets, bars, etc.) and other outdoor cutting implements manufacturing facility. The audit included evaluation of non-contact cooling water, industrial wastewater, storm water, domestic wastewater and UIC management issues. Based on audit findings, Creekside determined that the facility maintained a high level of sampling and monitoring practices and were in compliance with federal regulations and permits. Creekside assisted in implementing improved training and total quality management practices to ensure continued success at the facility.

Storm Water Pollution Control Plans (SWPCP) – Carlton Chain Saw, Milwaukie, Oregon (September-October 2008)

Creekside designed and helped implement the storm water pollution control plan for Carlton Chain Saw as required by the Oregon Department of Environmental Quality (DEQ) to comply with the National Pollutant Discharge Elimination System (NPDES) General Stormwater Discharge Permit requirements. This involved a survey of the 11.12 acre subject facility to determine the potential impacts to storm water at the site. Additionally, best management practices were evaluated and implemented to prevent any potential of storm water pollution, specifically point source discharges from leaving the property.

Environmental Compliance Assistance – Oregon Sandblasting and Coating, Tualatin, Oregon (May 2009-Present)

Creekside has been hired by Oregon Sandblasting and Coating (OSCI) to help maintain compliance with local city, state and federal environmental laws. This includes updating the storm water pollution control plan (SWPCP) as necessary and filing the annual storm water report to DEQ, filing annual hazardous waste RCRA reports, maintaining compliance with air pollution permits and other related environmental issues.

Environmental Compliance Assistance – Heinz Corporation, Los Angeles, CA (2004-2007)

Conducted multiple environmental compliance audits for hazardous waste storage, waste water treatment, storm water and air discharge, and health and safety protocols at a 500,000 square feet food processing facility near Los Angeles, CA. The audits included evaluation of non-contact cooling water, industrial wastewater, storm water, domestic wastewater and hazardous waste and air permitting management issues. After providing onsite training and completing several environmental plans, permit and reports, Creekside assisted in bringing the facility into compliance with CA State and federal regulations and permits. Creekside assisted in implementing improved training and total quality management practices to ensure continued success.

RCRA Closure, Chemical Distribution Center, Portland, Oregon

Investigated soil and groundwater impacts resulting from a release of chromated copper arsenic solution in a warehouse. Project involved preparing sampling and analysis plans, health and safety plans (with confined space entry provisions), supervising site cleanup activities, evaluating laboratory test results with appropriate regulatory criteria, recommending disposal options, summarizing the project activities in several reports, and negotiating a groundwater test plan with several DEQ managers.

RCRA Closure and Part B Permit Application Preparation

Confidential Wood Products Manufacturer, White City, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Project included evaluation of subsurface soil and groundwater impacted with pentachlorophenol, analysis and interpretation of appropriate and applicable environmental regulations, preparation of a Part B permit application, and negotiating cleanup standards and waste disposal options with Oregon DEQ project manager.

Investigation and Remediation of Lead-Impacted Soil

Confidential Metal Products Manufacturer, Madras, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Investigated soil and potential groundwater impacts at a lead-vinyl products manufacturer from releases of airborne dusts. Project included preparing several sampling and analysis plans, coordinating air monitoring and evaluating air containment systems, supervising site investigation and phase 1 cleanup activities, and corresponding with Oregon DEQ environmental cleanup division (ECD) personnel.

PCB Site Characterization and Cleanup, Oregon

Confidential Pump Service and Distributor, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Prepared a RCRA Closure Plan including liquid and soil removal procedures, a Sampling and Analysis Plan (SAP), and a Health and Safety Plan. Utilized PCB field kits to minimize laboratory costs, compared laboratory test results with applicable regulatory reference criteria (40 CFR 761), supervised site cleanup activities, and received a “no further action” letter from the USEPA Region 10 PCB coordinator upon project completion.

RCRA Closure in Washington

PCB Incinerator Facility in Chehalis, Washington
Owner/Principal Brent Jorgensen Served as Project Manager.

Work involved investigation of Washington Department of Ecology (WDOE) and USEPA closure requirements, coordination of on-site facility decontamination, confirmation sampling, and facility closure certification.

Characterization and Remediation of Chromium and Arsenic in Soil and Groundwater

Confidential Chemical Manufacturing Facility, Portland, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Investigated soil and groundwater impacts resulting from a release of chromated copper arsenic solution in a warehouse at a chemical distribution facility in northwest Portland, Oregon. Project involved preparing sampling and analysis plans, health and safety plans (with confined space entry provisions), supervising site cleanup activities, evaluating laboratory test results with appropriate regulatory criteria, recommending disposal options, summarizing the project activities in several reports, and negotiating a groundwater test plan with the Oregon DEQ.

Environmental Investigation in Rickreall, Oregon

Confidential Agricultural Co-Op, Rickreall, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Assisted the client in emergency cleanup of fertilizer and pesticide fire debris, investigated waste disposal and treatment options, and worked closely with with DEQ in preparation and implementation of sampling, analysis, and closure plans and reports. Project involvement also included preparation of regulatory classification reports, design and installation of a wastewater treatment system, coordination of site cleanup and decontamination with Chemical Waste Management, Inc., and negotiation of site cleanup standards with DEQ. Also worked with Oregon DEQ and USEPA to exempt on-site wastes from RCRA Land Ban Disposal Restrictions. Other activities included:

Preparing a fire debris management plan
Sampling soil and debris contaminated with agricultural chemicals
Submitting samples with chain-of-custody documentation to a certified lab, interpreting the results, and characterizing the debris for disposal
Preparing regulatory classification reports
Identifying waste removal and disposal options
Designing a wastewater treatment system for pesticide-contaminated liquids using carbon filtration
Coordinating site cleanup and decontamination with Chemical Waste Management, Inc.
Preparing a fire debris removal report for the Oregon DEQ

CERCLA Superfund Site – Waste Characterization and Disposal Project

Confidential Hazardous Waste Facility, Portland, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Project included evaluation of drummed hazardous waste solids and liquids including spent solvents, pentachlorophenol, creosote, paint, and acidic solutions; analysis and interpretation of appropriate and applicable environmental regulations; preparation of disposal permits and applications; and identification of cost-effective waste disposal options.

CERCLA Superfund Site Characterization and Remediation of Lead-Contaminated Soil and Groundwater

Bergsoe Metal Corporation, St. Helens, Oregon
Owner/Principal Brent Jorgensen Served as Task Manager.

Assisted in the nvestigation soil and groundwater impacts resulting from multiple releases of lead-contaminated sulfuric acid solution at a lead smelting facility in St. Helens, Oregon. Project involved preparing sampling and analysis plans, health and safety plans, supervising site cleanup activities, evaluating laboratory test results with appropriate regulatory criteria, recommending disposal options, summarizing the project activities in several reports, and preparing a risk assessment and RIFS for the Oregon DEQ.

CERCLA Superfund Site – Disposal of Creosote-Treated Lumber

McCormic & Baxter Site, Portland, Oregon
Owner/Principal Brent Jorgensen Served as Task Manager.

Assisted in coordination of the disposal of several hundred creosote-treated logs at the subject site. Project involved preparing health and safety plans, supervising log disposal activities, evaluating appropriate regulatory criteria for the disposal recommending disposal/resale options, summarizing the project activities in several reports, and working with the Oregon DEQ.

Pacific Northwest Planning Services & Environmental Compliance

Several Major, Confidential Oil Companies and Consortiums, Oregon, Washington, and Alaska
Owner/Principal Brent Jorgensen Served as Environmental Compliance Manager/Project Manager.

Completed several spill prevention control and countermeasure (SPCC) plans, oil spill and emergency response plans, and contingency plans.

Industrial Waste Regulations, California

City of Carpinteria, California
Owner/Principal Brent Jorgensen Served as Environmental Compliance Specialist.

Brent Jorgensen served as the author of the City of Carpinteria, California’s Industrial Waste Regulations Guidance Manual.

Waste Minimization Program, California

Confidential Printed Circuit Manufacturer Newbury Park, California
Owner/Principal Brent Jorgensen Served as Project Manager.

Program utilized: aqueous photo-developing solutions to replace chlorinated solvent developing solutions, and sodium borohydride as a reducing agent to separate dissolved metals in chelated electroplating solutions. The treatment systems and source modifications contributed to a 67 percent hazardous waste reduction within 18 months.

Waste Minimization Program Initiation and Implementation

Confidential Northwest Pesticide Manufacturing Firm in Portland, Oregon
Owner/Principal Brent Jorgensen Served as Environmental Compliance Manager.

Project involved use of membrane filtration, carbon absorption, and baghouse dust segregation. Treated wastewater was used as make up for subsequent batches and excess waste solvent was utilized as a fuel source for off-site incineration. The system helped reduce 54 percent of the annual waste generated.

Hazardous Materials Containment Plan, Portland, OR

Confidential Business Park, Portland, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Assessed the hazardous materials and waste activities and completed containment plans and designs for 10 businesses adjacent to the Columbia South Shore Slough.

RCRA Part B Permit Application Project

Cascade Wood Products, Inc., Southern Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Project involved negotiation with state environmental regulators; evaluation of process, groundwater, and waste characteristics information; and development of an interim measure corrective action plan for groundwater protection.

Remedial Investigation/Feasibility Study, Redi-Strip of Oregon

Review historical assessment and regulatory files, met with Oregon DEQ to negotiate Phase II work plan and remedial measures, prepared an RI proposal and work plan, implemented RI Work Plan (including soil and groundwater sampling and analysis), and submitted a Draft RI Report to DEQ (project is “in progress”).

Environmental Investigation and Facility Closure

Carnation Dairy Site, Portland, Oregon (June – December 2004).

Conducted a comprehensive environmental investigation of onsite soils, groundwater and soil vapors. Project involved writing and implementing a Sampling and Analysis Plan, evaluating laboratory data, and preparing a Risk-Based Closure Report consistent with Oregon DEQ rules and regulations. DEQ issued a “No Further Action” letter for the site in December 2004.

Environmental Investigation and Site Cleanup Involving Chromium

Environmental Investigation and Site Cleanup of Chromium Impacted Animal Hides, Stella Olson Memorial Park, City of Sherwood, Oregon (November 2004).

Project involved preparing a Work Plan which was approved by the Oregon DEQ; collecting soil, sediment, surface water, and groundwater samples; arranging for the samples to be evaluated at a State-certified lab; evaluating the lab data; and developing and implementing a remediation plan for the City (project is ongoing).

Storm Water Treatment Studies and Monthly Monitoring

Kinder Morgan Bulk Terminals, Port of Portland, Oregon.

Collected storm water samples, prepared and initiated a monthly monitoring program, evaluated laboratory test results, conducted treatability tests using neutralizing agents such as sodium bisulfate, attempted bioremediation treatment with tannic acid, and completed and submitted quarterly reports required by the Oregon Department of Environmental Quality (DEQ).

Storm Water Permit Preparation and Environmental File Organization

Texaco Refining & Marketing, Inc., Portland Terminal, Oregon.

Completed eight NPDES storm water permit applications following a corporate ownership change (Texaco to Equilon, Inc.) and reorganized the environmental filing system for Texaco’s corporate environmental engineer.

Stormwater Pollution Control Plan & Spill Prevention Control and Countermeasure Plan

Helser Bros. Transfer Company, Portland, Oregon.

Completed the SWPC and SPCC plans as required by the City of Portland, Oregon DEQ, and EPA. The plans were written consistent with proper regulatory protocols and were accepted and approved by the agencies.

RCRA Spill Contingency Plan, Spill Prevention Control & Countermeasure Plan, and Sampling and Analysis Plan

Short Mountain Landfill, Eugene, Oregon.

This project involved completing the following general tasks: (1) developed a RCRA spill contingency plan, an SPCC and facility response plan (FRP), and a Sampling and Analysis Plan as mandated by the Oregon DEQ and the Environmental Protection Agency (Ref.: 40 CFR Part 112 and the Oil Pollution Act [OPA 90]), (2) developed an environmental training program, and (3) provided training for wastewater treatment operators who were managing a leachate treatment system. Work included reviewing existing OPA 90 spill prevention policies and plans, revising the plans to reflect current practices, auditing the general facility compliance programs (e.g., air, hazardous waste, water quality, etc.), comparing these programs with State of Oregon and EPA requirements, documenting our findings, and preparing comprehensive plans for our client.

Preparation of a Wastewater Discharge Permit Application

Wastewater and Storm Water Monitoring, Great Western Chemical Company, Springfield, Oregon.

Completed the wastewater permit application for the City of Springfield, conducted quarterly monitoring for the Springfield Utility Board, monitored storm water in the truck wells, and prepared applicable reports as required by the local and State agencies. Monitoring and reporting was consistent with proper regulatory protocols and were accepted and approved by the agencies.

Preparation of Wastewater Permit Application, Emergency Notification and Planning, and Evaluation of Chromium and Electroless Nickel Plating Processes

Circuit Technologies, Inc., Redmond, Washington
Owner/Principal Brent Jorgensen Served as Project Manager.

Prepared a permit application which required a comprehensive site and manufacturing process assessment, an inventory of hazardous materials and waste storage, calculation of on-site chemical containment capabilities, preparation of an Emergency Notification and Spill Prevention Plan, spill notification procedures, and Solvent Management Plan.

Toxic Chemical Release Inventory (EPA Form R), 16 Facilities

Bohemia Wood Products, 16 Facilities, Western and Southern Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Project tasks included review of hazardous materials and waste storage, use, and processing; estimation of annual air, wastewater, and land disposal quantities; and preparation and submittal of several Form R reports.

Engineering Code Reviews, Portland, Oregon

Confidential Client, Portland, Oregon.

This project involved completing comprehensive Uniform Fire Code and Uniform Building Code reviews for a confidential developer constructing a new facility in the Portland area.

Toxic Chemical Release Inventory (EPA Form R)

Blue Heron Paper Company, Oregon City, Oregon
Owner/Principal Brent Jorgensen Served as Project Manager.

Air Emissions Inventory & ACD Permits

Great Western Chemical Co. & McCall Oil & Chemical Company, Portland, Oregon (October 2000 – July 2001).

Evaluated air emission sources, reviewed prior air compliance reports & evaluated past to current operations then determined permit requirements and policies enforced by the Oregon Department of Environmental Quality. Also wrote an air emissions inventory report and assisted in preparation of the new Air Contaminant Discharge Permit.

General Environmental Compliance Services, Portland

McCall Oil & Chemical Company, Portland, Oregon.

This project involved updating the existing spill prevention control and countermeasure (SPCC) pland and facility response plan (FRP), as mandated by the Environmental Protection Agency (Ref.: 40 CFR Part 112 and the Oil Pollution Act [OPA 90]).

Environmental Compliance Projects