Environmental Services Travis Clark Environmental Services Travis Clark

Go Wild! The Benefits of Native Landscaping

Learn about the advantages of turning your yard into a space that supports native plants, animals, and habitats.

The summer heat has taken hold, and you’re probably struggling to keep that lawn at your home or business alive and green. What better time to learn about the advantages of turning all or a portion of that area back into a space that supports native plants, animals, and habitats? Traditional lawns require significant investments of time and resources while providing little in return.

Pollinators, for one, depend on native habitats for survival. According to the USDA, “Three-fourths of the world’s flowering plants and about 35 percent of the world’s food crops depend on animal pollinators to reproduce”. Native flowers in a former lawn space can support insect and bird pollinators with nectar and pollen as a much-needed food source, allowing them to complete their critical pollinating roles.

Once established, native habitats also require significantly less watering and eliminate the need for harsh chemicals and fertilizers. National Audubon Society experts estimate, “the traditional suburban lawn on average has ten times more chemical pesticides per acre than farmland”. Natural areas reduce groundwater penetrating chemicals and conserve our most precious resource, water.

Natural spaces also provide the reward of connecting on a personal level with the outdoors. Researchers at the Mental Health Foundation have observed that “people who are more connected with nature are happier and more likely to report feeling their lives worthwhile.” What better way to promote positive mental health than to create and enjoy a biodiverse area?

Lastly, we see more and more habitat loss and migration spaces being eliminated due to human sprawl and development. To put this in perspective, there are currently more than 63,000 square miles in the US of turfgrass. That’s larger than the state of Georgia (LawntoWildflowers.org). Rewilding even a portion of this massive space would provide much-needed resources for birds, insects, and other living creatures that depend on natural land.  

Hopefully, these benefits have shown you why this summer could be the perfect time to convert your lawn into a native and rewarding landscape.

Resources:

Pollinators | USDA

Why Native Plants Matter | Audubon

Nature: How connecting with nature benefits our mental health | Mental Health Foundation

Bringing your lawn back to life by converting turfgrass to native wildflowers — Lawn to Wildflowers

Travis Clark is a Cornerstone Account Manager with a focus on business development. He manages corporate clients primarily in the industrial sector with a focus on manufacturing and logistics. He counsels clients in the areas of EPA and OSHA regulatory compliance management, quality certifications, and sustainability. He works closely with these operations to provide guidance on minimizing risk and implementation of cost-saving initiatives.


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Environmental Services Dan Smith Environmental Services Dan Smith

Biochar for Environmental Remediation

For thousands of years, innovative farmers have added a charcoal-like substance—biochar—to the soil to improve crop productivity. But what is biochar?

For thousands of years, innovative farmers have added a charcoal-like substance—biochar—to the soil to improve crop productivity. Between 450 BCE and 950 CE, native farming communities of the Amazon basin successfully converted low-fertility, tropical soils to agricultural soils through the amendment of biochar, compost, manure, and other waste. Unknown to these farmers, the physical and chemical properties of the biochar in these terra preta soils (“black soil” in Portuguese) were helping to retain soil nutrients that otherwise would have been leached away during the tropical precipitation. In recent decades, interest in biochar has experienced a resurgence as insightful scientists have looked to those same properties that helped biochar mitigate nutrient leaching for utility in environmental remediation endeavors.

What is biochar? Analysis of the name likely draws up images of a burned forest, perhaps a biological experiment involving fire, or a new product riding today’s wave of environmental interest. In summary, when any carbon biomass (e.g., wood waste, plants, or even animal waste) is exposed to high heat in an oxygen-free environment, this biomass converts to a solid, charcoal-like product known as biochar. In this form, the carbon is resistant to decomposition and is chemically stable. Macroscopically, biochar appears as dusty, black charcoal pieces with grains of generally 0.1 centimeters or smaller. But it’s the microscopic properties of biochar that make it unique. Consider a cross-section of a plant under a microscope with all the plant’s xylem, stoma, cells, and other tissues shown in detail. Then, imagine removing all liquid components and leaving only this skeletal framework behind. This solid, carbon-based matrix makes up biochar and instills it with tremendous surface area. This surface area and its generally negative surface charge are the basis for biochar’s environmental applications.

The high surface area and negative surface charge of biochar enable it to adsorb various substances and chemicals. Within the terra preta soils, nitrogen and other nutrients from manure and other wastes would adhere to the biochar’s surface rather than be leached away during rainfall. This maintained nutrient availability to the crops grown by the Amazonian farmers. Similarly, pollutants (particularly those with a positive charge) cling to biochar and can include organic compounds and heavy metals. Pollutants adhering to biochar are immobilized and prevented from entering the water supply—much as a charcoal filter will screen particles from drinking water. Adding biochar has been shown to help stabilize heavy metals in soil and thus may make it a valuable tool in mine reclamation and the treatment of industrial spills.

In addition to stabilizing metals and chemicals, research suggests that the simultaneous adsorption of organic compounds and microorganisms to biochar facilitates metabolic interaction and expedites the degradation of these pollutants. Bioremediation, the use of microbes to clean up contaminated soil and groundwater, may be enhanced with biochar. One method of bioremediation—bioaugmentation—involves the introduction of a concentrated culture of microbes to the contaminated site. The physical application of these microbes requires mixing them with a carrier medium and amending the area of treatment with this mixture. A slurry containing biochar not only acts as an effective carrier but also provides a protective habitat for the microbes within the pores and rough surface of biochar. As aforementioned, biochar’s affinity for adsorbing organic pollutants helps to bring both the organic pollutants and the microbes into association, thus accelerating the breakdown of these toxins. One study found enhanced bioremediation of polycyclic aromatic hydrocarbons when using biochar as a carrier. Other studies have found similar success when using biochar in bioremediation.

Biochar may also be used to control ongoing pollution from agriculture and large-scale industrial processes. Wetlands and biofilters (engineered filtration systems composed of soil, sand, gravel, and plants) are often constructed to treat agriculture and industrial wastewater naturally. Biochar has demonstrated promise in augmenting contaminant removal of wetlands and biofilters when included among the substrates. Simply put, biochar's unique but consistent properties make it transferrable to various remediation methods.

Thousands of years ago, the Amazonian farmers understood little of biochar, except that adding it to soils improved the success of their harvests. Today, we know the properties of biochar and learn how it can be used in other applications. As our technology advances and our environmental standards improve, our environmental needs will evolve. Meeting these needs will require viewing old technology with a fresh perspective. There is no single solution to our environmental dilemmas. However, the investigation of novel ideas, such as biochar for remediation, can help us along the way.


Dan Smith is an Environmental Specialist for Cornerstone Environmental, Health and Safety out of our Zionsville office. His seven years in environmental consulting include experience in environmental compliance, site assessments, monitoring, remediation, and health and safety. When not at work, he can be found hiking, biking, or engaging in other outdoor activities.


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Environmental Services Jonathon Lewis Environmental Services Jonathon Lewis

The History of Earth Day

After celebrating the 53rd Earth Day this past weekend, it seems like an opportune time to look back at the history of Earth Day.

After celebrating the 53rd Earth Day this past weekend, it seems like an opportune time to look back at the history of Earth Day as many of the rules and regulations Cornerstone works with now came about because of Earth Day.

A Wisconsin Senator by the name of Gaylord Nelson was the one behind getting the very first Earth Day started. He was worried about the shape of the environment in the U.S and, after taking notice of the energy behind the anti-war protests by students, decided that something similar could be done to raise public awareness about air and water pollution. The original plan for Earth Day, before it was even given the catchy moniker, was for a teach-in on various college campuses to the national media on April 22nd; however, that all changed when a young activist named Denis Hayes, who was in charge of organizing the event, decided to promote it across the country. His efforts helped gather a number of individuals, groups, and organizations together and it was decided to change the name of the event to “Earth Day”. 

The first Earth Day took place on April 22nd, 1970 and the response from the American people was overwhelming. Over 20 million people went out to protest, rally, and demonstrate across the nation to bring attention to the environment and its importance. For anyone curious, the population of the United States of America in 1970 was over 200 million people; meaning that about 10% of all Americans turned out for Earth Day and supporting the environment (Census Bureau, 2021). Earth Day was so effective that by the end of the year, Congress approved and the President signed the Clean Air Act into effect as well as the creation of the Environmental Protection Agency; both of which are just as, if not more, effective and relevant today at defending our environment. It could be said that this helped get the ball rolling for other key environmental legislation to be passed, such as the Clean Water Act, Safe Drinking Water Act, Resource Conservation and Recovery Act (RCRA), and Toxic Substances Control Act (TSCA).

Earth Day later went on to become recognized around the world, with groups from a wide variety of countries taking part in the efforts to raise awareness about the importance of protecting the environment. Earth Day has even taken on the effort to raise awareness about the need to address the growing issue of climate change. Even after 50 years, Earth Day is still observed by about 1 billion people across the Earth.

Some people participate in Earth Day through more political means by joining marches, protests, letter-writing campaigns and other public demonstrations to raise awareness and show support for the environment. Others volunteer for various environmental projects, cleaning up trash from their local beach or park, planting trees and/or other native plants, cutting down invasive species, and even educating others in their local community about the importance of the environment. You don’t have to solve the climate crisis to take part in Earth Day.


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Environmental Services Bill Hess Environmental Services Bill Hess

Is Your Environmental Program Getting the Recognition It Deserves?

Companies have made significant strides over the past decades to achieve regulatory compliance. As of late, more and more businesses have been highlighted in the media for going above what is asked of them in an effort to become stewards for environmental consciousness. One of the most effective means to accomplish this goal is to implement an Environmental Management System (EMS). An EMS provides the framework to develop your system for maintaining compliance with environmental regulations by establishing a set of policies and procedures to follow. The EMS reduces the guesswork and unwanted actions that sometimes occur in daily operations which can lead to non-compliance issues.

Many state agencies promote regulatory compliance through voluntary programs that provide instruction on how to implement an EMS and encourage participation in a range of recognition programs. For example, Indiana sponsors the Environmental Stewardship Program (ESP) and a Governor’s Award for Pollution Prevention. These are separate programs, but both are intended to recognize regulated entities that go above and beyond current environmental regulations.

Applications for these programs can be tedious and time-consuming and can get lost in the shuffle of your other daily routines and responsibilities. Cornerstone’s team can assist in exploring these state-specific recognition programs and, after working with your team to determine which program best fits your needs, scoping the project to keep it manageable. Additionally, we can assist in completing and submitting the application for a recognition program in your state.

Our Division of Quality Management Services has decades of experience in every aspect of developing an ISO 14001 EMS as well as other comparable programs. In addition to full-service implementation consulting, we offer the following services:

  1. Aspects and Impacts – Conduct onsite evaluations and written findings.

  2. Policies and Procedures – Drafting and oversight of policies and procedures.

  3. Application Submittal – Completing and submitting applications for approval.

  4. Audits – Conducted at specified intervals for program compliance by a third party.

  5. Projects – Sustainability projects with carbon footprints, energy audits, waste to energy, and solar.

Contact Cornerstone for support in meeting your Environmental Recognition Program and be the leader in your state.

Bill Hess is Cornerstone’s Manager of Business Development, Northern Midwest Region. He has been on a career path in Sustainability for more than 40 years and just celebrated 22 of those years with Cornerstone. He specializes in ensuring our clients have the resources they need for Environmental Management, Safety Culture Improvement, Loss Prevention, ISO Services, Safety Training, Industrial Hygiene Services, and SDS (MSDS) Management.


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Environmental Services Cindy Madrick Environmental Services Cindy Madrick

The Role of ESG and EHS in Mergers and Acquisitions

To say the past two years have been difficult for manufacturers – big and small – would be a huge understatement! In addition to the unprecedented challenges presented by COVID-19 during 2020 and 2021, businesses must now deal with supply chain issues, labor shortages and surging inflation.

How can an organization balance all of these challenges? Throughout the business world, management teams are working and reworking their strategy to deliver shareholder value. Talk in boardrooms includes the need for additional capabilities, access to new markets, improved marketing of products and services as well as scalability. For smaller companies, business owners may be burnt out and start evaluating their next move. With all the uncertainty, owners are exploring mergers or selling. Step in Mergers and Acquisitions (M&A) specialists which could be comprised of banks or private equity groups (PEGs).

The primary goal of a Merger and Acquisition (M&A) specialist is to help companies grow. The M&A market had impressive increases in the number of transactions in 2021 as compared to 2020. Activity outpaced expectations with record-setting volume and value. Most banks and PEGs expect another strong year of deal-making since they are sitting on record amounts investment capital and cash.

One of the most compelling reasons for companies to consider M&A is the need for or to share technology and digital assets as well as other resources; however, companies merge for a variety of reasons such as entering new markets or to improve business efficiency as well as gain or maintain market position. Even more as of late, many mergers and acquisitions are stemming from the importance of technology in production processes.

Whether your organization is considering acquiring or merging in the near term, or you are preparing your company for a future transaction, the selling as well as the buying side of M&A must be a strategic process that should include the assistance of subject-matter experts to provide guidance throughout the due diligence phase.

For both buyers and sellers, there is a roadmap that should be followed – a playbook of sorts. The roadmap helps establish clear roles and tasks for the team members involved. While there are multiple steps, the due diligence phase tends to be the most time-intensive and stressful. Due diligence consists of a thorough review of EVERY aspect of the entity, such as products, services, customer base, human resource records, financials and regulatory. For all intents and purposes, it is a process that provides information related to value, liabilities and risk.

One important aspect of due diligence are the topics of environmental, health and safety (EHS) and environmental, social and governance (ESG) which have traditionally been overlooked (or delayed to the 11th hour) by M&A “dealmakers”; however, most are now realizing its inevitable rise in prominence. After all, there is clear evidence that socially conscience investors use ESG criteria to screen investments. M&A groups are challenging their teams to ensure sellers and buyers are considering targets to advance an organization’s plan toward sustainability. Both ESG and EHS due diligence reveals information - track records of behaviors and insight into actions and the status of compliance or lack thereof. The resulting information is an aid to investors to identify material risk.

Looking at environmental and safety concerns, dealmakers are increasingly challenged to assess post-close risks associated with non-compliance, pending government inquiries, potential litigation, contamination/remediation and reputational concerns, which can extend to long term operational burdens. The process begins with evaluating risks and opportunities and, in many cases, ends with review of ESG disclosures. (ESG disclosures; how to measure and manage with no common standard is an important and challenging topic on its own!)

Whether you are contemplating M&A or strategizing on how to build value in your organization, it is prudent to ensure ESG and EHS is part of your strategy. Build a culture of competency, conduct due diligence by having a third-party, subject matter expert audit EHS compliance. After all, to make your way through ESG and set sustainability goals, an organization must start from a solid base of regulatory compliance. ESG is a framework to evaluate the overall health and resiliency of an organization – environmental, health and safety are defined by laws/regulations and are mandatory. Some components of the “E” and “S” involve judgement – making choices about conduct that reflect values. Both are essential for the longevity of business today.


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Environmental Services Kevin Mallin Environmental Services Kevin Mallin

Expedite the Sale of Industrial Property with a Limited Site Investigation

 

Cornerstone has recently seen an increase in client requests to prepare a limited site investigation report for commercial or industrial properties they are preparing to sell. Although it is the responsibility of the prospective purchaser to conduct a Phase I Environmental Site Assessment (ESA) compliant with ASTM E1527-21, when the seller has a limited site investigation in-hand, the process can be accelerated.

Why should a property owner conduct a Limited Site Investigation before selling property?

Companies selling a property often find that making the report available to potential buyers helps to address any obvious concerns an ESA would characterize as a Recognized Environmental Condition (REC), such as an open disclosure of subsurface conditions. When the prospective purchaser is made aware in advance of any potential cleanup requirements, they can estimate the associated costs and evaluate their risk, making the purchasing decision more transparent and faster.

What if the property is clean?

If the report indicates there is no soil, groundwater, or vapor sampling exceeding a regulatory threshold, the seller has an advantage over other potentially contaminated sites the purchaser may be considering. It is still the responsibility of the purchaser to complete a Phase I ESA in order to get the protection of the Comprehensive Environmental Response, Compensation and Liability Act’s (CERCLA) innocent land owner defense under All Appropriate Inquiries (AAI).

What if the report indicates areas of concern?

When the results indicate there may be a need for further site investigation into the nature and extent of an environmental condition, the buyer and seller can negotiate how to proceed and contact a qualified environmental professional for further examination.

Seller companies should note though, if the investigators finds certain levels of contamination in the subsurface, the investigator, the current owner, or the buyer may be required to report the findings to a state or federal agency. If this occurs, the company can consult with their attorney for specific legal guidance or to protect their interests.

Contact Cornerstone

If your company has decided to sell your commercial real estate, you may want to consider conducting a limited site investigation to help expedite the sale process. Contact Kevin Mallin at kmallin@corner-enviro.com or (317) 489-3249 with any questions concerning this topic or other Environmental Remediation concerns.


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Environmental Services Chris Koucky Environmental Services Chris Koucky

Emergency Generator Inspections and RICE MACT Compliance

 

This year was the first in my career in which EPA issued a Notice of Violation to a client due to non-compliance with a facility’s emergency generator maintenance and records.

The majority of my clients have an emergency generator on site. Many maintain them appropriately and keep the required records, but sometimes these requirements can slip through the cracks. Facilities should be aware of the requirements that apply to generators and ensure they are documenting compliance.

The potential consequences of non-compliance include inspection violations, fines, and required reporting in annual compliance certifications.

DOES YOUR FACILITY HAVE AN EMERGENCY GENERATOR?

The first step is to determine if your facility has generators on site. This may seem obvious, but I have seen several instances where a facility’s environmental team was either unaware they had a generator or did not know the specific requirements that applied to the units. I have also seen generators installed without the environmental team’s knowledge. If you are unsure, ask your maintenance department to verify.

ACTIONS TO BE TAKEN IF YOUR FACILITY HAS ONE OR MORE EMERGENCY GENERATORS

  1. Determine what type of engine drives your emergency generator.

    Find out when the unit was manufactured, what type of fuel it uses, and the unit’s horsepower rating. This information is often on the nameplate of the unit.

  2. Determine if your emergency generator must be permitted.

    Depending on your state and its operational activities, your generator may or may not require an air permit. This is a state-by-state determination since each state has its own rules for handling emergency generator permitting. Some states may have a general permit for emergency generators at facilities that would otherwise not have an air permit. Others may have regulations that apply beyond the federal requirements.

  3. Determine what requirements apply to your generator(s).

    Based on the above information, the generator will be subject to parts of 40 CFR 60, Subpart JJJJ, 40 CFR 60, Subpart IIII, and/or 40 CFR 63, Subpart ZZZZ. These regulations are referred to as the RICE MACT (Reciprocating Internal Combustion Engine Maximum Achievable Control Technology).

WHAT ARE THE “NEW” OR “EXISTING” GENERATOR CATEGORIES?

The manufacturer date will determine if your emergency generator is considered “new” or “existing” with respect to the requirements. For example, a generator with a compression ignition (diesel) engine is considered new if it was manufactured after April 1, 2006.

“New” Emergency Generators

For most new units, owners achieve compliance by purchasing an engine that is certified by the EPA and by installing, configuring, operating, and maintaining the engine per the manufacturer’s instructions. To comply with regulations, it is necessary to maintain records of the certification and maintenance conducted.

If a facility that is already classified as a major source installs a generator with greater than 500 horsepower, EPA requires the facility to submit an initial notification to their agency. This is the only type of emergency generator that requires the notification submittal.

“Existing” Emergency Generators

Compliance for “existing” generators can be achieved by adhering to the following requirements and specific maintenance items on schedule:

Maintenance Items (Applies to all emergency generators except >500 HP at major sources)

  • Change oil and filter and inspect all hoses and belts every 500 hours of operation or annually, whichever comes first

    • Alternately, the operator may use oil an analysis program instead of prescribed oil change frequency

  • Compression Ignition (diesel) – Inspect air cleaner every 1,000 hours or annually, whichever comes first

  • Spark Ignition (natural gas, gasoline, propane, etc.) – Inspect spark plugs every 1,000 hours or annually, whichever comes first

Compliance Requirements

  • Operate/maintain engine and control device per manufacturer’s instructions or owner-developed maintenance plan

  • Emergency engines must have a meter and record hours of operation

  • Retain all maintenance records

OPERATING HOURS

Each emergency generator (except >500 HP at major sources) must have a non-resettable hour meter installed. This is critical to accurately record the hours of operation. For each operating event, owners must record the hours and distinguish if the event was used for emergency response or in a non-emergency situation.

  • Each generator may be operated for up to a maximum of 100 hours per calendar year for maintenance checks, readiness testing, emergency demand response, and non-emergency usage.

  • A limit of 50 of those hours can be non-emergency situations.

If either threshold is exceeded, EPA will reclassify the generator as a “non-emergency” unit, causing it to be subject to a different set of regulations including possible performance testing.

MAINTAINING COMPLIANCE

The most difficult part of emergency generator compliance is determining into which category your unit falls. Once you have made that determination, maintaining compliance is rather straightforward. You can conduct the prescribed maintenance at the established frequencies and record the hours of operation distinguishing between types of use.

The key is to maintain sufficient records demonstrating compliance with each requirement. This will help ensure your facility is in compliance with the RICE MACT generator requirements and avoid violations and possible fines in the future.

FURTHER INFORMATION

Contact Cornerstone for help regarding emergency generator inspections and RICE MACT compliance.


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