Do Tracer Environmental professionals ever slow down? The SCS Tracer professionals at SCS Engineers were busy publishing new articles last month in addition to Operator Training. We’ve compiled several of them along with the most popular in our SCS library for your convenience. Select a title and start reading. Enjoy!
How to Properly Complete an IIAR 6 System Safety Inspection Checklist Form? When filling out the ANSI/IIAR 6-2019 Ammonia Refrigeration Safety Inspection Checklists, located in appendix B, some of the information required may not always be readily accessible. This comprehensive article takes readers step-by-step through the process.
Epic Fails, Part Deux Failures that come together, form a picture. The author discusses how we can begin to learn from these Epic Fails and start to take steps to prevent them in our plants.
Ammonia Pipe and Equipment Labeling – Part I Recognized and Generally Accepted Good Engineering Practices (RAGEGEP), an overview of many of the standards and guidelines that are relevant to the ammonia refrigeration system labeling, and guidance on how to apply them.
Ammonia Pipe and Equipment Labeling – Part II Options facilities have when choosing their RAGAGEP for pipe and equipment labeling.
It’s All in Your Past, RETA Breeze Investing in the knowledge and development of your personnel is the first step towards making your management system world-class in the safe operation and maintenance of your ammonia refrigeration system.
Employee Training Under PSM/RMP FAQs about designing a training program that is part of your facility’s PSM and RMP programs and provides a defensible position during inspections while ensuring that your facility operators and maintainers perform their jobs safely.
Mechanical Integrity, Documentation Discrepancies Checks, and verification prevent big problems.
Managing Organizational Change: How it Impacts Your Ammonia Refrigeration System During periods of organizational change, we must keep in mind the potential impacts on our facility’s PSM/RMP or ARM programs, and on the operation of the ammonia refrigeration system itself.
PSM/RMP Compliance Audits: Who Should Perform Them? What to look for in an auditor for hire? For starters, more than a consultant familiar with PSM/RMP regulations.
Management of Change: Have We Captured All of the Impacts of a Change? It is vital to ask as many questions as possible regarding equipment changes under consideration. With more information, you may find that the proposed changes could impact safety.
The U.S. Environmental Protection Agency (EPA) has identified 1, 2, 3 – Trichloropropane (TCP), which does not occur naturally in the environment, as an emerging chemical of concern that can threaten drinking water supplies. It states that TCP is a persistent pollutant in groundwater and has classified it as “likely to be carcinogenic to humans.” California State Water Board member Steven Moore called TCP an “insidious chemical” because it persists in the environment, sinks in water and is harmful in even tiny doses. Currently, there is no federal maximum contamination level (MCL) for TCP; however, there is a federal non-enforceable health-based screening level of 0.00075 ug/L.
Since 2012, TCP has been on the emerging Contaminant Candidate List (CCL), which is a watch list of unregulated contaminants that are known to, or anticipated to, occur in public water systems and may require regulation under the Safe Drinking Water Act (SDWA). The EPA has required, under the Unregulated Contaminant Monitoring Rule (UCMR), that large water systems test for TCP every five years with a minimum reporting level of 0.03 μg/L. This rule allows for the EPA to monitor contaminants suspected to be in drinking water that are unregulated under the SDWA. As a result of the testing, TCP has been identified across the US in drinking water sources. Currently, there is no federal maximum contamination level (MCL) for TCP; there is a federal non-enforceable health-based screening level of 0.00075 ug/L.
The author continues the paper with an examination of what TCP is and how it impacts our environment and our health. She then discusses regulatory policies and how California’s mandatory TCP standard could be a blueprint for other state water agencies currently investigating how to enhance their own drinking water protections from emerging contaminants.
Lyn covers some of the legal aspects, risks to businesses, detection, and treatment options to conclude her white paper. She also provides plenty of resources to start the journey toward sustainable treatment solutions that communities can afford.
About the Author: Lynleigh Love is a Senior Project Geologist with SCS Engineers. She has been a professional geologist for more than 22 years with extensive technical expertise in environmental assessment, remediation, and regulatory compliance. Her experience includes groundwater/soil vapor monitoring, excavation work plans, and remedial action plans.
PFAS are also key components in aqueous film-forming foam (AFFF), which is used to fight petroleum-based fires at aviation and manufacturing facilities. For decades, AFFF containing PFAS has been used extensively at airports throughout the world to protect the safety of passengers, crew, and others. The FAA requires that commercial airports train with, calibrate equipment with, and use the best performing AFFF fire suppression systems. AFFF is required to be used at airports and must be certified to meet strict performance specifications, including those mandated by the U.S. Department of Defense Military Specifications.
Lynleigh Love and Chris Crosby of SCS Engineers discuss the risks and issues with PFAS-based firefighting foam used at airports. The authors cover the regulatory climate, contamination investigations, operational and environmental management and litigation, along with alternatives to using traditional AFFF. There are some possible alternatives that can mitigate health risks in your community.
Read this article to help inform your mitigation plan and strategies to minimize risk.
Article published in the January 2020 edition of Waste Advantage Magazine.
At the Federal level, GHG emission reporting has become part of the standard regulatory requirements; however, on the west coast, GHG programs continue to develop and evolve from reporting to reduction programs beyond federal requirements. Solid waste facilities can be impacted by all of these reporting mechanisms directly as a landfill located in the state in question, opting in for C&T as part of the LCFS in California, or in limbo, as the courts work out the legality of Washington’s Clean Air Act. More stringent federal GHG requirements are unlikely with the current administration, however, that could change with the 2020 election. In general, GHG rules and legislation keep developing and updating to account for and reduce GHG emissions.
Read, share, or download the full article here.
Cassandra Drotman Farrant is Project Manager with SCS Engineers. She has nine years of experience in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. Cassandra has participated in many GHG verification projects throughout the U.S. and has completed approximately 70 Phase I Environmental Assessments (ESAs) in California, Oregon, and Washington. Phase I projects included research and review of geologic and hydrogeologic conditions at project sites and in the surrounding areas and evaluating the potential for soil and groundwater contamination from on and offsite sources. Cassandra has completed emissions estimates and inventories and has prepared numerous permit-to-construct/operate permit applications. She prepares compliance reports, which includes reviewing and maintaining records and regulatory deadlines.
SCS Engineers provides engineering, consulting, operations and monitoring services to report and reduce greenhouse gas emissions. Select a service category to learn more.
Reprint of USEPA Press Release dated today.
WASHINGTON (Dec. 19, 2019) — Today, the U.S. Environmental Protection Agency (EPA) took another key step in implementing the agency’s PFAS Action Plan by announcing a new validated method for testing per- and polyfluoroalkyl substances (PFAS) in drinking water. This new validated test method complements other actions the agency is taking under the Action Plan to help communities address PFAS nationwide.
“EPA’s important scientific advancement makes it possible for both government and private laboratories to effectively measure more PFAS chemicals in drinking water than ever before,” said EPA Administrator Andrew Wheeler. “We can now measure 29 chemicals, marking a critical step in implementing the agency’s PFAS Action Plan—the most comprehensive cross-agency plan ever to address an emerging chemical of concern.”
EPA’s new validated Method 533 focuses on “short chain” PFAS, those PFAS with carbon chain lengths of four to 12. Method 533 complements EPA Method 537.1 and can be used to test for 11 additional PFAS.
Method 533 accomplishes a key milestone in the EPA PFAS Action Plan by meeting the agency’s commitment to develop new validated methods to accurately test for additional PFAS in drinking water. Method 533 also incorporates an analytical technique called isotope dilution, which can minimize sample matrix interference and improve data quality.
Voting for the Old Dominion Chapter’s 2020-2021 Board of Directors ended December 13, 2019. After tallying the votes, the following professionals were elected as new Directors, including:
Congratulations!
Ryan Duckett is a Project Professional working out of SCS’s Midlothian, Virginia office. He is responsible for Sustainable Materials Management, or SMM, solid waste facilities and municipal planning solutions. Ryan also supports environmental engineering projects related to permitting, compliance, regulatory reporting, landfill gas modeling, construction quality assurance (CQA), and pollutant emission inventories at solid waste management facilities. Ryan is an active member of the SCS Engineers Young Professional Program that connects our young professionals with others providing community support, altruistic efforts, mentoring, networking, and social activities.
Virginia’s Solid Waste Association of North America (SWANA) organization works to advance environmentally and economically sound municipal solid waste management in Virginia. The “Old Dominion” Chapter as it is known consists of over 300 professionals actively working in the solid waste field throughout the Commonwealth. The membership represents the largest cross-section of solid waste managers, operators, and consultants in Virginia.
The Chapter seeks to foster networking and cooperation among solid waste professionals, including regulators and provides educational opportunities to enhance members’ expertise in the solid waste management field. Members carry out a variety of activities and programs to establish innovative research programs in the publics’ interest, scholarships and technical assistance. Learn more about membership on their website – http://www.swanava.org/.
REPRINT OF USEPA PRESS RELEASE
WASHINGTON (Dec. 3, 2019) — Today, the U.S. Environmental Protection Agency (EPA) is announcing several actions to clarify and improve New Source Review (NSR) permitting requirements. These Clean Air Act actions are part of a suite of measures EPA is taking to modernize and streamline the NSR process, without impeding the Agency’s ongoing efforts to maintain and enhance the nation’s air quality. These actions will improve regulatory certainty and remove unnecessary obstacles to projects aiming to improve the reliability, efficiency, and safety of facilities while maintaining air quality standards.
“NSR reforms are a key component of President Trump’s agenda to revitalize American manufacturing and grow our economy while continuing to protect and improve the environment,” said EPA Administrator Andrew Wheeler. “NSR regularly discouraged companies from investing in and deploying the cleanest and most efficient technologies. Through the Trump Administration’s efforts, EPA is providing clarity to permitting requirements, improving the overall process, and incentivizing investments in the latest energy technologies.”
“For too long, New Source Review permitting requirements stifled job creation, hampered innovation and slowed the ability to modernize critical energy infrastructure. Worse, in previous administrations, the permits were weaponized, so liberal activists could delay key projects,” said U.S. Senator Jim Inhofe (OK). “New Source Review hasn’t been updated in over four decades—making it hard to integrate new technologies into our energy infrastructure. I’ve worked for years to modernize the review process, and applaud today’s action by President Trump and Administrator Wheeler to streamline the NSR permitting process.”
“One of my consistent frustrations with New Source Review is what seems to be a perverse incentive away from innovation. Thank you to Administrator Wheeler and the Trump Administration for recognizing this and finalizing these positive reforms,” said U.S. Senator Kevin Cramer (ND). “The EPA’s actions provide certainty while restoring the proper scope of the Clean Air Act.”
“I applaud the EPA for taking further steps to reform the New Source Review permitting program. NSR’s burdensome process can impede upgrades that would actually increase efficiency and improve air quality. The EPA is moving toward a better NSR program that streamlines the process without sacrificing environmental protections,” said U.S. Representative Morgan Griffith (VA-09).
“I applaud Administrator Wheeler for implementing a strong regulatory reform agenda at the EPA. Today’s actions are a solid first step in the right direction to reform the NSR permitting program. I look forward to continue working with the Trump Administration to further reform NSR and allow America’s industry to make their units more reliable and efficient, while maintaining strong environmental standards,” said U.S. Representative Andy Biggs (AZ-05).
“President Donald Trump continues to deliver on his promise to cut burdensome regulations that strangle American manufacturing and energy development. These improvements to the New Source Review (NSR) permitting requirements will protect our air quality, while incentivizing businesses to grow and expand. I look forward to continuing to work with President Trump and Administrator Wheeler to cut needless regulations and create American jobs,” said U.S. Representative Alex X. Mooney (WV-02).
“This Administration is clearing the path for manufacturers to invest in more energy efficient technologies that conserve energy, reduce emissions, and keep U.S. manufacturers competitive,” said Portland Cement Association President and CEO Mike Ireland. “For energy-intensive industries like cement, strategic investment in energy efficiency and emissions reduction are key components of any long-term climate and sustainability strategy, and EPA’s New Source Review reforms announced today help unlock new opportunities for sustainable operation.”
Final Guidance: Revised Policy on Exclusions from “Ambient Air”
After considering public comments, EPA is issuing final guidance, identifying the sort of measures which EPA may take account of in determining whether a source owner or operator has precluded the general public from having access to its property. Where access is precluded, the portion of the atmosphere above that property is not considered “ambient air” for the purpose of conducting air quality analyses under the Clean Air Act. The guidance updates EPA’s policy to recognize that a variety of measures may be considered effective in keeping the public off a source owner/operator’s property. These measures, which account for advances in surveillance and monitoring, depend on site-specific circumstances and continue to include, but are now not solely limited to, fences or other physical barriers. State, local and tribal permitting authorities have the discretion to apply this guidance on a case-by-case basis. The regulatory definition of “ambient air,” as stated in 40 CFR § 50.1(e) to mean “that portion of the atmosphere, external to buildings, to which the general public has access,” remains unchanged.
Final Guidance: Interpreting “Adjacent” for New Source Review and Title V Source Determinations in All Industries other than Oil and Gas
EPA has also recently issued a final guidance that revises the agency’s interpretation of when multiple air pollution-emitting activities are located on sufficiently “adjacent” properties to one another that they should be considered a single source for the purposes of permitting. To determine what activities comprise a single source under the NSR and Title V air permitting programs, three factors must be satisfied: the activities must be under common control; they must be located on contiguous or adjacent properties; and they must fall under the same major group standard industrial classification (SIC) code. In this guidance, for all industries other than oil and natural gas production and processing for which there is a separate set of rules and to which this guidance does not apply, EPA adopts an interpretation of “adjacent” that is based on physical proximity only. The concept of “functional interrelatedness” would not be considered by EPA when determining whether activities are located on adjacent properties. This interpretation should help clarify and streamline the permitting process.
Additional NSR Proposals
EPA also recently issued a proposal to address minor errors that have accumulated over time in four NSR regulations. While these minor errors, such as outdated cross references and typographical errors, have not materially impeded the effective operation of the NSR program, EPA believes that it is important to remove such errors from the regulations in order to provide regulatory certainty and clarity. The proposed corrections are all considered to be non-substantive and are intended to provide clarity and precision to the NSR regulations without altering any NSR policy or changing the NSR program as a whole.
EPA is also proposing to remove from the NSR regulations various provisions, such as certain “grandfathering” provisions, that, with the passage of time, no longer serve any practical function or purpose. EPA will be taking comment on this proposal, which will be published in the Federal Register.
More information on these actions and other NSR improvements are available at: https://www.epa.gov/nsr
Coming Soon: Revisions to Petition Provisions of Title V Permitting Program
EPA is currently working to take final action on a 2016 proposal for revisions to the title V regulations. This proposal would streamline and clarify processes related to the submittal and review of title V petitions.
The proposed rule would bring more certainty for all stakeholders, including the sources required to obtain and maintain title V permits; more focused petitions; better title V permit records which are expected to result in fewer petitions; and reduced administrative burden in the EPA’s review of petitions in a tight timeframe.
Background
Congress established New Source Review as a preconstruction permitting program in the 1977 Clean Air Act Amendments. The program intended to ensure the maintenance of air quality standards around the country and that state of the art technology is installed at new plants or existing plants undergoing major modifications.
Under the NSR program, before constructing a new stationary emission source or major modification of an existing source, the source operator must determine whether the new source will emit or the project will increase air emissions above certain thresholds. If so, the operator may need to get a permit from a state government or EPA that may require installation of pollution control technology or other measures.
Contract your SCS project manager, or if you have questions about the impact of these recent actions.
REPRINT OF USEPA PRESS RELEASE
EPA Moves Forward on Key Drinking Water Priority Under PFAS Action Plan
WASHINGTON (Dec. 4, 2019) — Yesterday, the U.S. Environmental Protection Agency (EPA) sent the proposed regulatory determination for perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) in drinking water to the Office of Management and Budget for interagency review. This step is an important part of EPA’s extensive efforts under the PFAS Action Plan to help communities address per- and polyfluoroalkyl substances (PFAS) nationwide.
“Under President Trump, EPA is continuing to aggressively implement our PFAS Action Plan – the most comprehensive cross-agency plan ever to address an emerging chemical,” said EPA Administrator Andrew Wheeler. “With today’s action, EPA is following through on its commitment in the Action Plan to evaluate PFOA and PFOS under the Safe Drinking Water Act.”
The action will provide proposed determinations for at least five contaminants listed on the fourth Contaminant Candidate List (CCL4), including PFOA and PFOS, in compliance with Safe Drinking Water Act requirements.
Background
The Safe Drinking Water Act establishes robust scientific and public participation processes that guide EPA’s development of regulations for unregulated contaminants that may present a risk to public health. Every five years, EPA must publish a list of contaminants, known as the Contaminant Candidate List or CCL, that are known or anticipated to occur in public water systems and are not currently subject to EPA drinking water regulations. EPA publishes draft CCLs for public comment and considers those prior to issuing final lists.
After issuing the final CCL, EPA determines whether or not to regulate five or more contaminants on the CCL through a process known as a Regulatory Determination. EPA publishes preliminary regulatory determinations for public comment and considers those comments prior to making final regulatory determinations. If EPA makes a positive regulatory determination for any contaminant, it will begin the process to establish a national primary drinking water regulation for that contaminant.
For more information: www.epa.gov/ccl
Background on the PFAS Action Plan
PFAS are a large group of man-made chemicals used in consumer products and industrial processes. In use since the 1940s, PFAS are resistant to heat, oils, stains, grease, and water—properties which contribute to their persistence in the environment.
The agency’s PFAS Action Plan is the first multi-media, multi-program, national research, management and risk communication plan to address a challenge like PFAS. The plan responds to the extensive public input the agency received during the PFAS National Leadership Summit, multiple community engagements, and through the public docket. The PFAS Action Plan outlines the tools EPA is developing to assist states, tribes, and communities in addressing PFAS.
EPA is taking the following highlighted actions:
Highlighted Action: Drinking Water
Highlighted Action: Cleanup
Highlighted Action: Monitoring
Highlighted Action: Toxics
Highlighted Action: Surface Water Protection
Highlighted Action: Biosolids
Highlighted Action: Research
The agency is also validating analytical methods for surface water, ground water, wastewater, soils, sediments and biosolids; developing new methods to test for PFAS in air and emissions; and improving laboratory methods to discover unknown PFAS.
Highlighted Action: Enforcement
Highlighted Action: Risk Communications
For more information, article, and treatment options visit SCS Engineers.
According to the U.S. Geological Survey Circular 1344, the United States uses 79.6 billion gallons per day of fresh groundwater for public supply, private supply, irrigation, livestock, manufacturing, mining, thermoelectric power, and other purposes. This blog is intended for businesses that must meet groundwater monitoring regulatory compliance according to EPA and state mandates, which are becoming increasingly stringent.
Have you had a regulatory compliance issue due to the condition of your groundwater monitoring wells or adequacy of your monitoring network? Are you confident compliance issues won’t arise in the future? Groundwater monitoring networks—including wells and dedicated sampling equipment—are often:
What if you managed your groundwater monitoring network like your other equipment assets? By taking a systematic asset management approach to maintaining your groundwater monitoring network you can:
Not concerned? Consider the likely results of the “if it ain’t really broke, don’t fix it” approach:
Regulatory Non-Compliance: Failure to comply with state and federal monitoring well regulations may result in a notice of non-compliance, fines, or legal action.
Repair and Maintenance Costs: Ignoring minor repairs and maintenance can lead to significant well repair or replacement costs. Simple repairs like lock replacement or ground surface seal repair are quick and low cost. Don’t let these minor items put you at risk for notification of non-compliance due to neglect. Other repairs such as protective casing or near-surface well casing repair may cost more but are a fraction of the cost of replacing a well that becomes unstable due to neglect.
Well Replacement Costs: Abandoning and replacing a single well that can no longer be repaired can cost $3,000 to $10,000+ depending on the depth and construction of the well.
As with many assets, you save time and money in the long run by addressing problems before they arise. So what does monitoring well asset management look like? It doesn’t have to be complicated, costly, or time-consuming. We recommend starting with a simple inventory following these basic steps:
1. Identify needed repairs and replacements of existing wells
2. Develop a plan to repair, replace, or abandon wells as needed
3. Identify deficiencies in the coverage of your well networks
Schedule inventory Steps 1-3 yearly. Download SCS Engineers’ useful well inspection checklist to record monitoring well conditions, identify well maintenance needs and identify the regulatory status of each well. Your trained staff or your environmental consultant can perform the yearly well inventory.
Contact SCS at for a groundwater expert near you.
About the Authors: Tom Karwoski, PG, has 30 years of experience as a hydrogeologist and project manager. He has designed and managed investigations and remediations at existing and proposed landfills; and industrial, Superfund, military, and petroleum sites. Mr. Karwoski was a hydrogeologist with the Wisconsin Department of Natural Resources prior to becoming an environmental consultant.
Meghan Blodgett, PG is a project professional with over eight years of experience in the environmental consulting field, including soil, groundwater, and soil vapor investigation and remediation; brownfield redevelopment; and solid waste landfill development. She is experienced in planning and performing soil and groundwater contamination investigations, monitoring well design and installation, hydraulic aquifer testing, and soil and groundwater sampling.
REPRINT FROM THE EPA PRESS RELEASE
EPA Finds That Financial Risks from Petroleum and Coal Products Manufacturing Industry Does Not Warrant Additional Federal Requirements
WASHINGTON (Dec. 4, 2019) — Today, the U.S. Environmental Protection Agency (EPA) is proposing to not impose burdensome and potentially duplicative financial responsibility requirements for the petroleum and coal products manufacturing industry (the industrial sector that transforms crude petroleum and coal into usable products) because the financial risk to the federal government from those facilities is already addressed by various existing federal and state technical and financial requirements and modern material management practices. EPA’s proposed action would not drop existing federal requirements, rather it is a proposal to not impose additional requirements.
“After a thorough evaluation, EPA has determined that the petroleum and coal manufacturing industry’s current practices, along with existing federal and state regulations, adequately address potential financial risks to the federal government and American taxpayer,” said EPA Administrator Andrew Wheeler. “As part of President Trump’s commitment to protecting our environment and growing our economy, we are committed to responsible regulation while not imposing additional and unnecessary requirements on key sectors of the economy when the current regulatory framework is working.”
In the 39 years since the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted, a comprehensive regulatory framework has developed. Existing monitoring and operation standards have consistently worked over time to decrease the risk in this industry that if a hazardous waste cleanup is needed, the federal government will have to bear the cost of cleanup.
Further, this proposed finding does not affect, limit, or restrict EPA’s current authority to take a response action or enforcement action under CERCLA at any facility in this industry, to include requirements for financial responsibility as part of such response action, or to take appropriate action under various other federal environmental statutes that may apply to individual facilities, such as the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and Toxic Substances Control Act. These existing regulations, including financial responsibility requirements, continue to apply to facilities in this industry.
This proposal is consistent with the analysis EPA undertook in developing its final action for the hard rock mining industry. In that case, EPA’s approach was unanimously upheld by the D.C. Circuit Court of Appeals in July 2019. EPA has evaluated the degree and duration of risk of the possible cost to cover the cleanup of hazardous substance releases associated with the production, transportation, treatment, storage, or disposal of hazardous substances in the petroleum and coal products manufacturing industry. EPA also examined the industry’s economic trends and the financial health of the sector and found the industry to be in a relatively stable financial position with low default risk. EPA’s evaluation showed that existing regulatory programs and voluntary practices reduce the need for federally financed response action at facilities in this industry.
Background
Section 108(b) of CERCLA, also known as Superfund, directs EPA to develop regulations requiring classes of facilities to establish and maintain evidence of financial responsibility to cover the costs associated with releases or threatened releases of hazardous substances from their facilities.
In December 2016, EPA described its plan to consider financial requirements under CERCLA for the electric power industry, the petroleum and coal products manufacturing industry, and the chemical manufacturing industry. On July 2, 2019, EPA proposed to not issue financial responsibility requirements for the electric power industry. EPA is currently working on a proposal for the chemical manufacturing industry.
Today’s proposal for the petroleum and coal industry will be published in the Federal Register, and EPA invites stakeholders and the public to provide comments during the 60-day public comment period.
For more information, visit: https://www.epa.gov/superfund/superfund-financial-responsibility, or contact SCS Engineers at for help.
