Industrial Manufacturer

SCOPE OF WORK: Environmental Consulting Services, facility compliance and environmental permitting


Omni Environmental Group provides environmental consulting services to an industrial manufacturer in western Massachusetts operating a cotton bleachery with a steam generating facility and waste water treatment plant (WWTP) handling municipal waste and process water from the bleachery. The facility withdraws water from an abutting river for manufacturing. The water is then treated in the WWTP and returned to the river.

Our services to the Client have included:

  • National Pollutant Discharge Elimination System (NPDES) Permit Renewal with the USEPA and MassDEP for the discharge of facility WWTP effluent to surface water.  
  • A successful appeal of the NPDES Permit with the Environmental Appeals Board to allow for a Site-specific copper toxicity and bioavailability study.
  • A Quality Assurance Project Plan (QAPP) outlining the quality assurance objectives and procedures for “clean metals” sampling of facility effluent and the river for use in applying the biotic ligand model for Site-specific copper criteria development.
  • Multi-Sector General Permit (MSGP) Annual Reports to the USEPA detailing the facilities compliance inspections, monitoring any necessary corrective actions for stormwater discharges associated with industrial activity.
  • A facility-specific Stormwater Prevention Plan (SWPP) required under the MSGP which identifies sources of pollution potentially affecting stormwater discharge quality at the Facility and
  • Best Management Practices (BMPs) to minimize pollutant discharge in stormwater and ensure compliance with the MSGP and NPDES Permit.
  • Annual Tier II Reporting detailing the hazardous substances used at the facility including locations, type(s) of storage, amounts (pounds), vendors, methods, and routes of delivery.
  • A Spill Prevention Countermeasure and Control Plan for the storage of petroleum oil-based products which could be released in harmful quantities into navigable waters, in accordance with 40 CFR Part 112.
  • Quarterly emissions reporting and greenhouse gas reporting for facility air discharges resulting from industrial operations and to display compliance under the federal Clean Air Act and state Air Pollution Control regulations.
  • Approval of Suitability Renewal for dewatered biosolids (e.g. sludge) generated from the WWTP at the facility to allow for beneficial use as a Type II residual material under 310 CMR 32.00.