We excel at evaluating a facility’s environmental compliance status and assisting with improvements.
Report Review and Litigation Support
Recently CAFOs have come under intense scrutiny with respect to groundwater contamination in the West. GGI’s extensive experience with dairies in New Mexico has allowed us to assess the validity of claims regarding the source of nitrate in groundwater and prepare powerful critiques of these claims. Often conclusions are drawn with minimal data or poorly collected data – GGI can help reveal fallacies such as these.
GGI provides expert witness and litigation support in a wide variety of environmental issues. We assist in developing cohesive and practical approaches to complex environmental problems that can occur during litigation. GGI’s extensive technical and research capabilities enable us to address the relevant regulations and prepare a comprehensive package that will satisfy the needs of legal counsel. GGI also has qualified professionals to provide expert-witness testimony for any support package that we prepare.
GGI can produce additional foundations through secondary investigations, the re-sampling of materials, supplemental site inspections, and review of products by other independent consultants or agencies. This includes efforts related to discharge permit applications, due diligence under Phase I Environmental Site Assessments, abatement plans, and Notices of Violations or Noncompliance.
Evaluating Environmental Compliance: Sale or Purchase
GGI can assist in the assessment of operations and facility for the potential buyer, or seller of an existing dairy operation. As part of the due diligence process, GGI can review records and documentation for a operation and provide a summary of the environmental compliance status and potential liabilities.
This assessment includes a site visit to insure that the documentation and records are consistent with conditions at the facility. GGI provides a report that will assist in determining any possible hidden costs associated with environmental compliance. As part of this investigation, GGI staff can also review water rights for the facility to insure that these rights are in good standing.
GGI has extensive experience in the preparation of Stage 1 and Stage 2 Abatement Plans that may be required by the New Mexico Environment Department (NMED), Ground Water Quality Bureau. Once a determination is made by NMED that water quality standards have be exceeded, the permit owner will be directed to submit an abatement plan. The general requirements for abatement plans is to assess the current state of groundwater contaminants, develop a plan for monitoring water quality, investigate the source of contaminants, and provide a plan to abate the water pollution to groundwater standards stated in the 184.108.40.20603 New Mexico Administrative Code.
GGI can support the client through the entire abatement process. Our ability to combine a multiple of professional areas of expertise can provide a practical and economical solution to move the client back into compliance.
GGI can assist the permit owner in preparing a stage 1 abatement plan for review by NMED. This plan includes: reviewing the historical data for an operation; preparing a site investigation for explaining the hydrology and related geology; provide interpretations of the extent of the groundwater contamination; and design a monitoring program (with a quality assurance controls) for sampling the groundwater. GGI interacts with NMED staff on behalf of the client to ensure proper processing and scope of the stage 1 portion of the abatement plan and to implement and complete all parts of the requirements for sampling and reporting.
Stage 2 of the abatement plan includes the development of remedial options based on information obtained in stage 1 of the plan. Stage 2 should include the selected remedial path that the client will follow to bring the operation back within the permit requirements and improve the water quality to the standards. Again, this portion of the abatement plan requires monitoring and reporting to evaluate the success of the remedial option.