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Environmental Compliance Approval - Expert Witness - Rubidium Environmental Consultants

Peer Review

Have you been presented with results that just don’t make sense? Think some of the assumptions made are overly conservative? Looking for a second pair of eyes to review your results?

We offer environmental consulting that can help you mitigate costs and risks by reviewing your existing reports. Don’t commit to costly environmental solutions until you are sure they are right for your facility, meet the needs of your property transaction and financing requirements, and/or development project.

Expert Witness

Our experts at Rubidium have experience providing services to our clients and/or their lawyers, to support land, air, odour, and noise disputes. We specialize in environmental consulting and providing our clients with accurate information and data that can be used when challenges arise.

To find out more about our Environmental Peer Review & Expert Witness services, please fill out the form or call us at (905) 635-4063.

When reviewing ESDM or AAR

It’s not uncommon to see conservative estimates used in the preparation of Environmental Compliance Approval (ECA) applications. When reviewing Emissions Summary and Dispersion Model (ESDM) reports or Acoustic Assessment Reports (AAR), we first look at a few key areas:

Does the data make sense?

Flow rates/velocities/temperatures characteristic for that type of equipment
Sound power levels within typical range for that applicable source

How was the estimate made?

Using source testing
- Is it consistent with other facilities (locally or in other jurisdictions)
Using emission factors:
- Is it representative of your facility and operations?
  - One of the challenges is finding the best and most relevant information that accurately reflect the nature of your facility’s operations
- What source was used? Is it reliable, and more importantly is it recent?
  - You’d be surprised how often we see an emission factor for a piece of equipment based on a single set of tests performed over 30 years ago.
- Using supplier data
  - Is the information based off of a supplier guarantee or a cut sheet?
    - Quite often this is general or highly conservative as it relates to contractual obligations, and not actual emissions
    - We have a strong working relationship with many chemical suppliers and can work with them to get the most accurate data for your facility
  - Based off of Material Safety Data Sheets (MSDS)?
    - Compositions given on MSDS’s are provided for safety purposes and are usually nowhere near actual compositions. In some cases, they are inflated by more than 100 times.
      - We run into this issue the most for the composition of steels and other metals in general. In most cases, mill certificates are available, which give the actual elemental analysis. If not available, then various metals association publish values for appropriate ranges in composition for different alloys.

When reviewing ESA reports

It’s also not uncommon to see incorrect methodologies being applied to field work investigations, areas of potential environmental concern not being adequately identified, or unrealistic remedial action plans being provided to Clients that do not present time efficient or cost-effective options during Due Diligence assessments (Phase I ESA, Phase II ESA, Phase III ESA).

Phase I/One ESAs

Does the scope of work meet the applicable regulations and guidelines?
Were all historical records reviewed?
Were previous reports reviewed and properly interpreted?
Were interviews conducted with knowledgeable individuals?
Was a Site reconnaissance adequately completed?
Were all areas of potential environmental concern and associated potentially contaminating activities adequately identified?
How were conclusions made?
- Were further investigations recommended?

Phase II/Two/III/Three ESAs

Does the scope of work meet the applicable regulations and guidelines?
Does the sampling methodology meet the applicable regulations and guidelines?
How were conclusions made?
- Were the appropriate Site Condition Standards selected?
  - Assessment of the physical setting and Site sensitivity
  - Use of wells in the vicinity of the property
  - Stratigraphy
  - Soil texture
- Were impacted areas adequately delineated?
- Were all laboratory results properly reported?
- Were calculations conducted properly using the appropriate factors?
- Were cost-effective suggestions presented for further investigations? Is there something we can suggest that would be better?