Paragon Consulting Group provides services to several client sectors; including agribusinesses, industrial facilities, solid and hazardous waste generators, oil and gas producers, petroleum distributors, real estate professionals and investors, private equity investors, and water resources owners and users. Some of our services, such as hazardous waste management, are used by many types of clients. Some services, such as CAFO waste management plans, are unique to particular sectors. Many clients use a number of our services.
Agricultural production of crops and livestock uses both natural resources, such as air, water, and crops, and synthetic inputs, such as fertilizers and pesticides. Concentrated Animal Feeding Operations (CAFOs) deal with the challenges of handling manure and process water, managing nutrients, and controlling odor. Federal regulations addressing air and water quality cover many aspects of the agricultural interaction of natural resources with synthetic inputs, as well as the unique situations and environmental impacts of CAFOs. State and local governments may have additional regulatory requirements for agricultural operations. In some parts of the United States, water rights are a key agribusiness concern.
Paragon staff are well versed in federal, state, and local regulations and have developed excellent working relationships with many state and local agencies, which provides clients with an effective regulatory interface. Paragon has extensive experience developing agribusiness-related compliance programs such as CAFO Waste Management Plans and Clean Air Act 112(r) Risk Management Plans and has particular expertise in the area of water rights. Paragon staff have also been involved as stakeholders during the development of CAFO regulations for decades.
General Industrial Activities
Some other industrial sectors supported by Paragon over the years include pharmaceutical manufacturing, battery manufacturing, chemical manufacturing and blending, label manufacturing, construction supply distributors, metal platers, and aircraft parts manufacturers to name a few. Regulatory issues generally include stormwater permitting, air permitting, contamination assessment and remediation, storage of regulated materials, hazardous waste management, and Emergency Planning and Community Right-to-Know Act (EPCRA) reporting. Due diligence assessments are often performed as part of a sale or purchase of such companies.
Over the last few decades, landfills have come under attack for their potential environmental impacts. Waste minimization techniques, recycling, composting, and incineration all serve to reduce the amounts of waste sent to landfills. But these options can never totally replace landfills; there will always be solid waste that cannot be destroyed or reused. Resource Conservation and Recovery Act (RCRA) Subtitle D regulations outline the steps that must be taken for new landfills, maintaining currently operating landfills, and landfill closures. In addition, each state has adopted or is working to devise its own landfill regulations.
Paragon staff are well versed in federal and state regulations regarding landfills and have extensive experience in the full life of a landfill – siting, permitting, operation, closure, and monitoring. Regardless of the life stage of the landfill, Paragon has the expertise and the professionals to assist with landfill service needs. Paragon staff have also been involved as stakeholders during the development of landfill regulations for decades.
Oil & Gas Production
Oil and gas exploration and production (E&P) are very important industries today. Some elements of the E&P industry include well heads; tank batteries; gathering pipelines; transmission pipelines; compressor and pumping stations; processing facilities; refineries; above and below ground storage facilities; and rail, truck, and marine terminal import and export facilities. Regulatory issues generally include stormwater permitting; air permitting; Spill, Prevention, Control and Countermeasure Plans; spill response, assessment and remediation; and well head and tank battery closures. Due diligence assessments are often performed as part of an asset sale or purchase.
Petroleum Storage and Distribution
Federal and state regulations for underground storage tanks (USTs) and aboveground storage tanks (ASTs) impact today’s fuel storage and distribution industry from initial site planning for a new facility, through renovations of existing sites, to closure and clean-up of old tank sites. Owners and/or operators who fail to achieve required regulatory compliance may experience violations, fines, and loss of business. Facilities management for fueling operations, retail outlets, bulk plants, and maintenance facilities is a complex and ongoing process that requires professional management expertise.
Paragon’s facility compliance and development team provides a wide variety of services for new sites and for upgrades/remodels to existing sites. We also offer a full range of the regulatory compliance services that can be required at any stage in a site’s life. Paragon staff have also been involved as stakeholders during the development of petroleum storage tank regulations and reimbursement programs for decades.
From a liability standpoint, industrial enterprise, developers, government agencies and even small business owners looking to acquire or transfer commercial property should obtain a Phase I Environmental Site Assessment (ESA) prior to completing a real estate transaction. An ESA identifies potential contamination sources that may impact the property. Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) liability can extend to the present owner of a property, along with prior owners, and can include liability for any portion of cleanup costs and penalties for a contaminated site. The ESA is intended to permit a user to satisfy one of the requirements to qualify for the innocent landowner defense to CERCLA liability. Most importantly, an ESA is good business because it provides information regarding potential liabilities of a property enabling the owner to make informed business decisions regarding the transaction.
Paragon staff have performed thousands of ESAs throughout the U.S. for both industrial and commercial sites, consistent with ASTM standards and federal regulations. Paragon also provides property owners with contamination assessment and remediation services. Paragon staff have completed remedial evaluations and negotiated mitigation of environmental impacts on numerous sites. Paragon’s experience in the areas of process design and treatment technology allows for development and implementation of remediation strategies that balance cost-effectiveness and regulatory compliance.
In many areas, increasing population, the requirements of growing municipalities and limited surface water supplies have produced a demand for the exploration and development of new reliable surface-water and groundwater supplies. Groundwater sources must be evaluated for water quality and quantity. Reservoirs and delivery systems require maintenance; many systems are a century old and can greatly benefit from modernization. Water rights owners must continually defend their vested water rights. Impaired water sources must be identified and remediated. Well fields must be well designed and constructed. Water users may be required to obtain wastewater and stormwater permits and produce spill prevention plans.
There is a wide range of water-resources issues affecting water users, ditch companies, and wildlife habitat managers. These issues are related to the development and protection of water resources and water rights as well as the operation of water storage and delivery systems.
Paragon has developed in-house water supply exploration and development expertise. The Paragon team includes hydrogeologists, geologists, modeling experts, civil engineers, and environmental engineers. Paragon’s hydrogeologists have extensive capabilities in determining aquifer yield potential and evaluating water quality according to the standards of the Safe Drinking Water Act. Paragon’s engineers specialize in groundwater exploration, development, and management services. In addition, Paragon staff have extensive experience related to design and operation of water storage and delivery infrastructure as well as water-rights engineering.