Owner’s Representative Advisory Services · Industrial & manufacturing · EPA Region 4
Every party on a cleanup is paid to do more, not less — and none of them is paid to tell you when the work has gone past what the site actually needs. ORAS Consulting works for the owner: defining the scope before it goes out to bid, running the procurement, and checking every change order and invoice against what was actually done.
A release at an operating plant starts several clocks at once, and none of them wait for you to finish assessing the damage. Reportable-quantity releases require immediate notification to the National Response Center. States run their own clocks on top of that, and they are not the same clock.
Meanwhile the decisions that will drive the total cost of the cleanup — who gets called, what scope they're given, what gets documented, what gets committed to in writing — are made in the same few days, usually by people whose actual job is keeping the facility running.
That's the gap we fill. Not the technical opinion, not the excavation. The owner's side of every conversation, from hour one.
Representative notification clocks
A release at or above its reportable quantity in any 24-hour period requires immediate notice to the National Response Center, 800-424-8802. Where EPCRA §304 also applies, a written follow-up goes to the state and local emergency planning bodies.
Petroleum discharge of 25 gallons or more on pervious surfaces — or any discharge to surface water — to the State Watch Office or FDEP's Office of Emergency Response, as soon as possible and no later than 24 hours.
Hazardous substance discharge: notify DEQ immediately. Petroleum at 25 gallons, causing a sheen, or within 100 feet of surface water: 24 hours.
A property owner must notify the EPD Director within 30 days of discovery of a release above the applicable reportable quantity criteria.
Illustrative only. Requirements vary by substance, quantity, medium and program — confirm the applicable rule for your site and incident.
None of these are fraud. They are the ordinary, predictable ways a remediation budget drifts when nobody on the owner's side has run a construction project before — and they are the reason an owner's representative pays for himself. Forty-one years of watching contractors bill is the qualification that matters here.
| Where it leaks | How it shows up | The check |
|---|---|---|
| 01Over-scoped assessment | More borings, wells and lab work than the release actually warrants, and an investigation that keeps expanding because nobody ever defined what “done” looks like. | Scope written to a defined endpoint before the work is bid, sized to the release rather than to the consultant's comfort. |
| 02Time and materials with no ceiling | Open-ended authorizations that run for months, with hours nobody reconciles against a schedule or a deliverable. | A not-to-exceed on every T&M authorization, tied to a specific deliverable — and a conversation before it's exceeded, not after. |
| 03Standby, idle equipment and repeat mobilizations | Rigs, excavators, frac tanks and treatment units billed while waiting on access, approvals or weather — and the same crew mobilized three times for work that fit in one trip. | Daily verification of what actually ran, and work packaged and sequenced so the site is ready before the crew arrives. |
| 04Change orders for original-scope work | Conditions that were in the contract documents from the start, re-presented as differing site conditions once the crew is mobilized and the owner has no leverage. | Every change order read against the contract, the approved scope and the field record — before it's signed, not after it's invoiced. |
| 05Disposal profiled high | Soil and water hauled and disposed at a higher waste classification, and a higher rate, than the analytical data actually supports. | Profiles and manifests checked against the lab results, and disposal facilities priced competitively rather than by habit. |
| 06Oversized or over-long treatment | A system specified for the worst-case plume, then operated years past the point of diminishing return because shutting it off is nobody's job. | Remedy options presented side by side with capital cost, duration and annual operating cost — and exit criteria agreed before the system is bought. |
| 07Monitoring with no end date | Quarterly sampling that continues indefinitely because no one asked the agency, early, what would actually close the file. | Closure criteria raised with the agency at the front of the project, and a monitoring program built to reach them. |
| 08Markups and pass-throughs | Subcontractor costs, rentals and lab work marked up past what the contract allows, on invoices nobody has the time to read line by line. | Invoices checked against rate schedules, unit prices and the contract's own markup terms. This is the part that most often pays the fee by itself. |
Most of your vendors are competent and most of them are honest. That isn't the point. The point is that nobody on that site is paid to spend less of your money, and left alone, a cleanup will find its own budget.
Every one of these is project management applied to an environmental incident — the same discipline that keeps a construction program on budget, pointed at a cleanup instead of a building. They are listed in the order they move the number.
The single biggest lever on total cost. We write the scope to a defined endpoint before anything goes out to bid, run a real competitive process, verify qualifications and insurance, and structure the contracts so the owner holds them directly rather than inheriting somebody else's terms.
A budget built at the start, tracked against actuals, and forecast to completion every month. Invoices checked line by line against work in place, rate schedules, unit prices and the contract's markup terms. Owners routinely find this is where the fee pays for itself.
Change orders are where remediation budgets go. Every one gets read against the contract, the approved scope and the field conditions that supposedly justify it — before it's approved, not after it's invoiced and the leverage is gone.
We serve as the owner's point of contact with state and federal environmental staff: coordinating correspondence, tracking commitments and deadlines, attending inspections and meetings, and making sure what gets said matches what's in the file.
Most of our clients still have a plant to run. Sequencing cleanup activity around production, access, utilities, shutdowns and shipping is straightforward construction management — and it is rarely anyone else's priority. Bad sequencing is paid for twice: once in standby, once in rework.
One coherent, contemporaneous record: daily reports, photographs, correspondence, submittals, cost detail — built to the standard learned on nuclear sites. It's what supports a pollution-liability or cost-cap insurance claim, and what an attorney needs if the matter ever turns adversarial.
Driving the team and the process toward the state's final instrument — and raising closure criteria with the agency early, because a cleanup with no agreed endpoint is a cleanup that bills forever.
Where a site closes with conditions, someone has to actually maintain the engineering controls, honor the restrictive covenant and keep the monitoring current. We set up the handoff so it doesn't quietly lapse — or quietly run forever.
Environmental cleanups are staffed by four different professions, and owners get burned when the boundaries blur. We are direct about ours: the consultant owns the technical opinion, the contractor owns the execution, the attorney owns the legal position — and we own the owner's interest across all three.
| Role | Signs & seals regulatory submittals | Performs the physical cleanup | Advises on legal position | Manages owner's cost, schedule & contracts |
|---|---|---|---|---|
| Owner's representative ORAS CONSULTING |
No | No | No | Yes — this is the whole job |
| Environmental consultant of record | Yes — licensed professional | No | No | No |
| Remediation contractor | No | Yes | No | No — manages their own |
| Environmental attorney | No | No | Yes | No |
ORAS Consulting is a construction and project management firm. We do not perform site assessments, design remedies, determine cleanup target levels, prepare or certify technical submittals, or provide legal advice — those belong to your licensed consultant and your counsel, and in several Region 4 states the law requires it. We hire, manage and hold accountable the people who do.
These steps really are sequential, and each one constrains the cost of the ones after it. The earlier we're involved, the more of the sequence is still open.
Confirm what has to be reported, to whom, and by when. Stand up the incident record on day one — photographs, field notes, correspondence log — because it will be read years later by an insurer, an agency, or a court, and it can't be reconstructed after the fact.
Your consultant delineates the release. We define and procure their scope, keep the investigation proportionate to the actual risk, coordinate site access around operations, and hold the schedule. Over-scoped assessment is one of the most common and least visible sources of cost on these projects.
The consultant recommends; the owner decides. We put the options in front of you with real numbers — capital cost, duration, operating cost, long-term obligation — then run a competitive procurement and paper the contract so the risk sits where you agreed it would.
Boots on your site. Daily coordination with the contractor, verification that billed work is work in place, change-order review before approval, and a running forecast to completion so a problem shows up in a report rather than in an invoice.
Florida issues a Site Rehabilitation Completion Order, conditional or unconditional. Tennessee and North Carolina issue a No Further Action letter. Alabama issues a Letter of Concurrence. Georgia runs on a Compliance Status Report and Corrective Action Plan against the Hazardous Site Inventory. We manage the team through to whichever one applies — and then set up the ongoing obligations that come attached to a conditional closure. Programs differ within a state, too: a North Carolina brownfields site closes on a Brownfields Agreement rather than an NFA.
Region 4 is administered from the Sam Nunn Atlanta Federal Center in Atlanta, and covers these eight states and seven federally recognized tribes. Each one runs its own remediation program with its own vocabulary, its own thresholds, and its own closure document. Knowing which set of rules you're standing in is half the job.
Founder & Principal
Forty-one years of construction and project management, and more than $150 million in projects managed across the United States. Four decades of running scopes, schedules, budgets and subcontractors on work where the cost of a bad week is measured in six figures — and of reading the invoices that came out of them.
The arc runs from project superintendent in Los Angeles — seventeen condominium projects, nine apartment buildings, three restaurants — through twelve years holding his own California general contractor's license and running hundreds of projects, to multi-state project management across telecommunications and power infrastructure including TVA and Entergy nuclear sites, to general construction manager on hotel programs of up to $11 million a project across the Carolinas.
The through-line is distressed projects. Fire-damaged and structural-collapse buildings. Renovations inside occupied multifamily. Jobs that were behind, over budget and adversarial by the time he walked onto them. Taking over a project that has stopped behaving and finishing it is, more than anything else, what those forty-one years have actually been spent doing.
That matters on a cleanup for one specific reason: he has been the contractor. He has held the license, carried the risk, priced the work, run the equipment and written the invoices. When a remediation contractor bills standby on an excavator or reprices approved work as a differing site condition, the only question that counts is whether anyone on the owner's side of the table has ever been on the other end of that conversation.
His work has also run the length of the hazardous-materials spectrum — environmental cleanup, hazardous waste remediation, asbestos abatement, and lead and mold — and includes seismic retrofit construction in California, where he is certified for Class 4 seismic retrofitting by the Association of Bay Area Governments.
ORAS Consulting exists because owners in the middle of an environmental incident are usually the least-represented party in the room. Everyone else has a professional whose job is to protect their position. This firm is the owner's.
"The plant manager shouldn't have to become an expert in remediation contracting at the worst possible moment. That's what I'm for."
Engagement profile
We are typically brought in one of three ways: in the first days after an incident, partway into a cleanup that has stopped behaving, or before an acquisition where the environmental condition of the asset is the open question.
Licenses, certifications & clearances
Disciplines
Also: hands-on operation of excavators, track hoes, dozers, skid steers and lifts — which is how you know whether a piece of equipment actually ran on the day it was billed. English, Spanish and Greek.
Every firm in this business says it is honest. These are the specific structural commitments that make it true here — each one is written into the engagement, and each one is verifiable.
We accept no fee, commission, referral, rebate or other consideration from any consultant, contractor, laboratory or disposal facility working on your site. Not now, not on the next job. An owner's representative with a financial relationship on the other side of the table isn't representing anyone.
You pay our fee. You pay your vendors what they invoice, after we have checked it against work in place. We do not rebill, mark up, or take a percentage of their work — which means nothing about our compensation improves when your project gets more expensive.
If the honest answer is that a project doesn't warrant an owner's representative, or that it's far enough along that our fee won't earn itself back, you will hear that before you sign anything. A referral we didn't take is worth more than an engagement we shouldn't have.
Daily, contemporaneously, whether or not anyone has asked for it — because a file assembled after the fact is worth very little to an insurer and less to a court. Forty-one years of construction, including nuclear work, teaches you that nothing is accepted on a handshake.
A construction and project management firm — not your engineer, not your geologist, not your attorney. Where the work requires a licensed professional, we say so and we hire one. The scope boundary is published on this site precisely because most firms leave it vague.
At a large owner's-rep firm, the person with forty-one years of experience sells the engagement, and someone two years out of school runs it. Here they are the same person. That is the entire argument, and it is the one thing a big firm structurally cannot match.
The person you meet is the person on your site, in the agency meeting, and on the invoice review. No account team, no handoff after the contract is signed.
We take on few engagements at a time by design. Oversight that isn't physically present isn't oversight — it's a monthly report.
A large firm has to staff your project to its own utilization targets. We staff it to what the project actually needs, which is usually less.
When the agency calls on a Thursday afternoon, or the contractor hits something unexpected in the excavation, you are not in a queue.
Before this firm, Foti worked inside nuclear generating stations — cleared and approved for site access by both TVA and Entergy, and TWIC-certified. That is less a line on a résumé than a description of a working culture.
Inside a nuclear facility, nothing happens without a procedure and nothing is accepted without documentation. Access is controlled, work is witnessed, and deviations are written up while they are happening rather than reconstructed later. The record is not paperwork about the job. The record is the job.
An environmental cleanup has very nearly the same structure and almost none of the same discipline. The file built during a remediation gets read years afterward — by a state agency deciding whether to close the site, by an insurer deciding whether to pay, and occasionally by a court. It is worth very little if it was assembled after the fact out of four inboxes and a contractor's daily logs.
So that is the habit this firm brings to a cleanup: the record gets written as it happens, whether or not anyone has asked for it. Not because environmental work demands nuclear rigour — it doesn't — but because somebody who learned to work that way does not really know how to work the other way.
Cleared for work inside Tennessee Valley Authority generating facilities.
Cleared for work inside Entergy nuclear facilities across the Gulf South.
Transportation Worker Identification Credential — a federal background investigation and biometric card.
Multi-state work across power generation, telecommunications and university campuses.
Four places, in roughly this order of size. Scope — defining what the work has to accomplish, and where it stops, before it goes out to bid. Procurement — a real competitive process instead of whoever was already on site. Change orders — reading every one against the contract before it's signed. Invoices — checking billed work against work in place, rates, unit prices and allowable markup.
None of that requires catching anyone doing something wrong. It requires someone whose full-time job is your side of the ledger, which is a role that usually doesn't exist on these projects. The specific patterns we look for are listed under where the money leaks.
No, and we won't be. Your consultant is a licensed professional who carries technical liability, signs and seals the regulatory submittals, and in states like Florida is legally required to do so. We don't compete with that role.
We help you choose that firm, define what they're being paid to do, hold them to schedule and budget, and make sure their work product actually serves your objective rather than just satisfying the file.
A day rate, plus expenses at cost. Days are agreed in a written monthly schedule before they are worked; anything beyond that schedule needs your authorization in advance, not an explanation afterward. Expenses are reimbursed at the IRS mileage rate and the GSA standard per diem, with receipts attached to every invoice and no handling fee or markup of any kind.
What we do not do is take a percentage of project cost, mark up a vendor's invoice, or accept a fee from anyone else working on your site. There is no arrangement under which a bigger remediation budget earns this firm more money. The full rate sheet goes out on request — ask for it and you will have it the same day.
Forty-one years and more than $150 million in projects managed across the United States — as project superintendent, project manager for a major national general contractor, regional construction manager and multi-state project manager. The work includes environmental cleanup, hazardous waste remediation, asbestos abatement and lead and mold; earthquake and seismic construction in California; multi-state telecommunications and cellular build-outs; and nuclear power plant projects. He is lead and mold certified and seismic certified.
Two parts of that matter more than they might look. The abatement and hazardous-materials work is where a contractor's scope, a regulator's expectations and an owner's budget collide hardest — either you know what a reasonable price and schedule look like there or you don't. And nuclear work sets the documentation standard: it is the environment where nothing is accepted on a handshake and every decision has to survive being read years later. That is exactly the habit an environmental file needs.
No. The remediation contractor performs the physical work. We write and administer the contract they work under, coordinate them with the rest of your operation, verify what they bill, and review every change order before it's approved.
No — and if you don't have one on a significant matter, that's usually our first recommendation. Liability position, agency negotiation strategy and insurance coverage disputes are legal questions.
What we do is make your attorney's job cheaper and more effective, because the factual record they're working from is organized, contemporaneous and complete instead of assembled after the fact from four inboxes.
Because he has been the contractor. Twelve years holding his own general contractor's license in California, running hundreds of projects — pricing the work, carrying the risk, operating the equipment and writing the invoices that owners then had to decide whether to pay.
That is a different kind of knowledge from having read a lot of remediation budgets. When a line item says standby on an excavator, or a scope gets repriced as a differing site condition, the useful question is whether the person reviewing it has ever sat on the other side of that conversation.
Because of who actually shows up. At a large owner's-rep firm the senior person with decades of experience wins the work and a much more junior one runs it day to day — that's how the economics of a big consultancy work, and it isn't a criticism, it's just the model.
Here, the person with forty-one years and $150 million in projects behind him is the person reading your change orders. We take on a limited number of engagements at a time so that stays true.
No. A large share of owner's-rep work starts mid-project, when the schedule has slipped, the change orders have started stacking up, or the agency correspondence has gotten adversarial. The first step is a fixed-scope review of where the project actually stands against its contracts and its budget — what has been approved, what has been billed, what was actually built, and what of it is still recoverable. Nothing else changes until you've seen that.
It varies enormously, and anyone who quotes a number before the release is delineated is guessing. For scale only: a 2004 EPA analysis of petroleum-contaminated site cleanups put the mean for its 95 service-station sites at roughly $243,000 (median $180,000), while its much smaller sample of six industrial sites ran far higher. That study is two decades old and the industrial sample is too small to budget against — what has held up is the cost driver it identified: sites that impact drinking water supplies cost two to four times as much as sites that don't.
The useful takeaway isn't the number. It's that the spread between a well-managed cleanup and a poorly managed one on the same site is very large, and it's decided early.
Pollution legal liability and cost-cap policies pay against documented, substantiated cost. Coverage fights turn on notice, on the pollution exclusion, and on whether the owner can actually prove what was spent and why.
Contemporaneous cost and field documentation is a natural byproduct of how we run a project. Your carrier and your coverage counsel handle the claim itself; we make sure the record underneath it holds up.
All eight states of EPA Region 4: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina and Tennessee.
And if nothing has happened yet, that's the better call to make. A thirty-minute conversation before an incident is worth considerably more than the same conversation three weeks after one.
Active incident
Federal reporting for a release at or above its reportable quantity runs to the National Response Center, 800-424-8802, immediately. Make that call and any applicable state notification first. Then call us.
Initial consultations are without charge and without obligation. If the right answer is that you don't need an owner's representative on this one, that's what you'll hear.