Environmental Consulting

The technical and professional experience of our diverse team of engineers, geologists, and environmental scientists allows for superior solutions and services in any industry.

Farmer Environmental Group routinely conducts groundwater monitoring to support site investigations and corrective actions for regulatory compliance. Groundwater monitoring may be a one-time event to assess groundwater for suspected chemicals of concern (COCs), or multiple periodic events to monitor COC concentration and distribution in affected groundwater plumes.

Highest Quality Licensed Professionals

Farmer Environmental Group employs groundwater gauging and sampling methodologies in general compliance with U.S. EPA and TCEQ publications, including EPA/540/S-95/504, and EPA SW-846. We typically utilize low-flow sampling (LFS) groundwater purging and sampling procedures to ensure the groundwater samples are representative of the aquifer being assessed. Groundwater is purged and sampled by a peristaltic pump if possible, or by electric submersible pump or dedicated bailer. Groundwater samples are preserved in laboratory-supplied containers, documented on a properly maintained chain of custody, and delivered to an EPA, NELAC, and state-certified laboratory for analysis.


Farmer Environmental Group’s Geologist, Environmental Scientist, and Project Managers are experts at interpreting groundwater data. With surveyed elevations, groundwater flow direction and gradient can be determined and illustrated on maps made by computer-aided design. COC concentration and distribution can also be depicted on maps and tables and compared to applicable regulatory limits. Farmer Environmental Group’s groundwater monitoring reports are deliverable in hard copy and electronic media.

Farmer Environmental Group conducts hydrogeological investigations using sound, proven assessment methodologies. Our investigations are designed, performed, and interpreted by Geologists, Environmental Scientists, and Project Managers with decades of practical experience. We develop investigation strategies tailored to achieve technical and business-driven objectives. Our experience and sincere concern for the client’s best interests provide concise, economic, and expedient results.

Farmer Environmental Group’s hydrogeological investigations support site characterizations, limited or comprehensive in scope, including:

    • Geoprobe, hollow-stem auger drilling or test pit sampling
    • Temporary or permanent monitor well installations
    • Geophysical surveys by ground-penetrating radar, or magnetometer
    • Sensitive receptor surveys
    • Soil vapor surveys
    • Soil sampling
    • Groundwater sampling

Farmer Environmental Group’s hydrogeological investigations also include aquifer testing by water quality parameter analyses, slug tests, or pump tests to support:

    • Groundwater source determination
    • Groundwater quality and yield per regulatory Class or Category
    • Assessment of groundwater remediation technologies

Phase I Environmental Site Assessments are prepared for real estate and business transactions such as land and building purchases, leases, business acquisitions, new residential developments, and bank loans. Farmer’s Phase I ESA report adheres to the American Society for Testing & Materials E-1527-05 standard and complies with the United States Environmental Protection Agency 40 Code of Federal Regulations Part 312. This type of Phase I ESA report is required by lenders and is highly recommended before purchasing commercial or industrial real estate, or before starting new residential developments.


The primary purpose of a Phase I ESA is to determine the real value of a subject property by identifying the risk of soil or groundwater contamination stemming from previous use or neighboring sites. Soil and groundwater contamination can impact a property’s value and can potentially result in a cleanup liability. This is not something you would want to find out about after you purchase the property.

When conducting a Phase I ESA, Farmer Environmental Group performs and provides the following:

    • Inspection of subject property and surrounding areas
    • Historical review of aerial photographs, Sanborn Fire Insurance Maps, city directories, topographic maps, and historical building permits
    • Review of local municipal agency records/interviews, state and federal environmental database review
    • Analysis of soil, geologic and hydrogeologic conditions
    • Interviews with owners, occupants and neighboring tenants (for abandoned properties)
    • A detailed professional site plan
    • Digital photographs with descriptions
    • Inclusion of the Statement of Qualifications of assessors
    • Conclusions regarding significant environmental liabilities if any
    • Final recommendations

Farmer Environmental Group’s project team has extensive experience conducting Phase I Environmental Site Assessments on all types of facilities, including service stations, dry cleaners, industrial properties, retail centers, auto repair facilities, agricultural properties, office buildings, and residential properties across the US and Canada. Our vast wealth of project experience provides our clients with invaluable resources in the correct evaluation of potential issues on properties of interest.

When a Phase I ESA identifies potential contamination of a site by hazardous materials, a further investigation is typically warranted. The Phase II ESA includes sampling and laboratory analysis to confirm the presence of dangerous substances. Some of the tests that may be performed include:

    • surficial soil and water samples
    • subsurface soil borings
    • groundwater monitor well installation, sampling, and analysis to identify the source, and vertical and lateral dispersion of contamination
    • drum sampling and characterization
    • sampling of floor drains and sumps
    • transformer/capacitor sampling for Polychlorinated Biphenyls (PCBs)
    • geophysical testing for buried tanks and drums
    • testing of underground storage tanks

Depending on the results of the samples, the Phase II ESA should outline additional site investigation needs and potential remedial actions that may be required to clean up the property. Performing an environmental site assessment before acquiring a property can minimize the risk and cost of hazardous waste contamination.

Samples are carefully reviewed

All of our samples are correctly preserved, documented on a chain of custody, and delivered to an EPA, NELAC, and state-certified laboratory for analysis. Our Phase II assessment results are presented in a comprehensive and easy-to-read report, complete with drawings, digital photographs, and recommendations.


Farmer Environmental Group strives to save our clients’ money by reducing the number of samples and sampling points by first researching the conditions at the project site. We use the published data and well reports, site topography, known or estimated groundwater depths, and, if available, existing surrounding sub-surface studies on nearby properties to develop a sampling plan that will narrow and focus the scope-of-work associated with the problems identified in the Phase I ESA.

What If Contamination Is Found?

If we find contamination and the conditions warrant, we will apply to the appropriate regulating agencies for closure with no further action. If necessary, we can also offer consultation, planning, and design services for a Phase III Environmental Site Remediation.

Farmer Environmental Group staffs a team of professional engineers and environmental specialists with extensive experience in preparing, certifying, and assisting with the implementation of Spill Prevention, Control, and Countermeasure (SPCC) Plans for a wide range of facilities.

Rules and Regulations

SPCC Plans are part of the United States Environmental Protection Agency’s (EPA) strategy to prevent oil spills from reaching the United States’ navigable waters.  In 1973, the Oil Pollution Prevention regulation was codified (40 CFR Part 112) to address certain oil spill prevention measures contained in the Clean Water Act of 1972. SPCC Plans must comply with the Oil Pollution Prevention regulation, which sets forth requirements for the prevention of, the preparedness for, and responses to oil discharges at non-transportation related facilities. These regulations are commonly referred to as the SPCC Rule.

The SPCC Rule requires specific facilities to prepare, amend, and implement SPCC Plans. The preparation of SPCC Plans is the facility owner or operator’s responsibility but must be certified by a Professional Engineer unless the facility meets specific criteria. Owners and operators of facilities that store greater than 1,320 gallons of oil-based products in aboveground storage tanks (ASTs) or 42,000 gallons within underground storage tanks (USTs) must prepare, certify, and implement an SPCC Plan. Unlike oil spill contingency plans, which focus on cleanup methods after a spill has occurred, SPCC Plans are preventive measures to assure that a spill is contained, and countermeasures are established to prevent oil spills. Spill contingency plans are required as part of the SPCC Plan if a facility is unable to provide adequate secondary containment measures.

We Can Help Every Step of the Way

SPCC Plans are required to address a specific facility’s design, operation, and maintenance procedures established to prevent oil spills from occurring and detail countermeasures to control, contain, clean up, and mitigate the effects of an oil spill.

Since its inception, the SPCC Rule has been revised and amended several times. Changes to the SPCC Rule have created confusion among facility owners and operators, resulting in the uncertainty of a facility’s compliance status. Farmer Environmental Group personnel are experienced with the current SPCC Rule and constantly monitor regulatory actions that may alter SPCC requirements to ensure our clients comply with applicable regulations.

Farmer Environmental Group’s underground storage tank (UST) and above-ground storage tank (AST) services support property transaction screening and owner/operator regulatory compliance. UST/AST systems can be assessed for regulatory compliance and release determination by our qualified Geologists, Environmental Scientist, and Project Managers. Farmer Environmental Group is registered with the Texas Commission on Environmental Quality (TCEQ) as an LPST Corrective Action Specialist and employs TCEQ registered Corrective Action Project Managers. Our services include:

    • Review of owner/operator and regulatory authority records
    • Storage tank system inspection and tightness/integrity testing
    • Release determination by soil and groundwater assessment
    • UST/AST closure
    • Risk-Based Corrective Action assessment

Before 1988, neither the US EPA nor individual states regulated USTs. An assessment of historical UST facilities is frequently required because they were closed prior to regulations requiring assessment for release determination.

In concert with select UST contractors, Farmer Environmental Group has upgraded or closed numerous storage tank systems. Regulations typically require a release assessment for the closure of a UST system by removal from the ground or abandonment in place. Representative samples of native soil and groundwater, if present, are obtained and analyzed for release determination. The excavated tank cavity fill is analyzed to determine appropriate disposition options, and generated waste, including backfill material soil, water, product, USTs, and ancillary equipment, is appropriately disposed of. The UST closure documentation is then submitted to the appropriate regulatory authority.

When a Detection is Found

If a release is detected, an assessment of soil and groundwater, typically involving the installation of soil borings and monitor wells, may be required. The assessment should delineate the horizontal and vertical extent of the release to applicable regulatory limits. If COC concentrations exceed regulatory limits, Risk-Based Corrective Action (RBCA) principles can be employed. RBCA involves the evaluation of the potential exposure of sensitive receptors in the site vicinity. If the risk to human health and the environment is acceptable, no additional corrective action may be required.

In some instances, the RBCA may indicate unacceptable risk. The extent of COCs exceeding regulatory limits is sufficiently small to preclude RBCA, and corrective action/remediation (Phase III) is selected to achieve regulatory compliance. Farmer Environmental Group’s Geologist, Environmental Scientist, and Project Managers have the experience necessary to employ the most expedient and cost-effective remediation methods to achieve regulatory compliance.

Farmer Environmental Group staffs a team of Professional Engineers and environmental specialists with extensive experience in preparing and assisting with the implementation of SWP3 for a wide range of industrial facilities and construction projects. SWP3 are site-specific documents that:

  1. identify potential sources of stormwater pollution on a specific industrial, municipal, or construction site;
  2. describe stormwater control measures and best management practices (BMPs) that will be used to reduce or eliminate pollutants in Storm Water discharges from the site; 
  3. identify the processes the operator of the site will implement to comply with the terms and conditions of the site-specific general permit.

Specific SWP3 requirements are variable in some states and municipalities. However, most states have adopted the federal SWP3 requirements. Farmer Environmental Group SWP3 requirements are compliant with federal and local requirements when applicable.

SWP3 regulations are associated with the National Pollutant Discharge Elimination System (NPDES) Storm Water Program, which regulates Storm Water discharges from three potential sources: municipal separate storm sewer systems (MS4s), construction projects, and industrial facilities. Most stormwater discharges are considered point sources, and operators of these sources may be required to receive an NPDES permit before they can discharge. This permitting instrument is designed to prevent stormwater runoff from washing harmful pollutants into local surface waters such as rivers, water bodies, or coastal waters.

The NPDES Storm Water Program covers the following types of storm water discharges:

    • MS4s – Operators of large, medium, and regulated small MS4s may be required to obtain authorization to discharge stormwater.
    • Construction Projects – Operators of construction sites that are one acre or larger (including smaller sites that are part of a larger typical plan of development) may be required to obtain authorization to discharge stormwater under an NPDES construction stormwater permit. Where EPA is the permitting authority, operators must meet the requirements of the United States Environmental Protection Agency’s (EPA) Construction General Permit (CGP).
    • Industrial Facilities – Industrial sectors may require authorization under an NPDES industrial stormwater permit for stormwater discharges. Where EPA is the permitting authority, operators must meet the requirements of EPA’s Multi-Sector General Permit (MSGP).

Our Qualified Staff Can Help Every Step of the Way

SWP3 can be constantly changing documents during the course of a construction project and require evolving compliance measures and applicable notifications by site operators.  In order for a for a site to remain in compliance with the NPDES permitting program, SWP3 or a Storm Water Management Plan (SMP), which details the site’s storm water management initiatives, must be prepared and maintained throughout the entire construction project. As the project progresses and goes through changes, the SWP3 or SMP is required to be revised to incorporate those changes. Farmer Environmental Group personnel are experienced with the current NPDES Storm Water Program, review local and regional SWP3 requirements prior to the issuance of any SWP3, and constantly monitor regulatory actions which may alter SWP3 requirements in order to ensure our clients compliance with applicable regulations.

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