This article discusses global air quality and how the collaboration between policy-makers and the scientific community can have a continued positive impact on air quality in the U.S. This collaboration has been the primary cause for the improvements observed in air quality over the past few decades.
U.S. Environmental Protection Agency (EPA) programs, such as the New Source Performance Standards (NSPS), New Source Review, and Maximum Achievable Control Technology standards, have all had a significant impact on improving air quality by lowering the ambient concentrations of NOX, VOC, CO, SOX, and PM.
Some areas, such as southern California, have committed to working toward electrifying the transportation network, implementing more stringent standards on diesel fuel sulfur content, and encouraging heavier utilization of public transportation.
Author: SCS Engineers’ Ryan Christman, M.S., is an air quality engineer and environmental management information systems specialist with experience in the oil and gas industry and the solid waste industry. He is just one of SCS’s outstanding Young Professionals.
Vapor intrusion (sometimes known as soil gas intrusion or soil vapor intrusion) is a potential environmental risk that can occur at a wide variety of properties, from former industrial facilities, shopping malls, and even residential properties. Knowing how to assess the risk and mitigate potential harm from soil vapor intrusion is critical to reducing health impacts and mitigating financial and other liability from potential exposures.
What is Vapor Intrusion?
Developers and the public understand that soil and water contamination can pose a health hazard, but vapor intrusion is an environmental health risk that can be overlooked. It is a hazard that can result from both heavy industrial operations and small “mom-and-pop” businesses so that it can be an issue both at industrial properties, suburban strip malls, and even residential developments.
Vapor intrusion is the migration of soil or water contamination from below structures into businesses or homes as a vapor. Common vapor intrusion contaminants from small businesses include benzene from gasoline and perchloroethylene (perc) from dry-cleaners, while large industrial facilities may have a wide range of industrial chemical contaminants. Less common vapor intrusion hazards are mercury, polychlorinated biphenyls, and pesticides.
Determining Whether Vapor Intrusion is an Issue
Environmental due diligence is key to determining whether vapor intrusion is a likely issue. An environmental site assessment (ESA) is critical in assessing the potential for vapor intrusion issues and the current state of vapor intrusion based on past site history. A Phase I ESA will review the current and historical use of the property and surrounding properties to determine where and when potential sources of contamination were present. Leaky underground gasoline storage tanks and poor chemical handling practices at dry cleaners lead to chemical contamination that can create vapor intrusion issues, so the “corner” gas station or the strip mall dry cleaner can be the source of vapor intrusion hazards.
Vapor intrusion can also come from groundwater plumes that originate outside the property boundary, so it is important that any assessment looks for potential contamination issues from nearby properties as well as on-site.
When the potential for a vapor intrusion issue exists, a Phase II ESA should be conducted to determine whether there is contamination, the extent and magnitude of the contamination, and whether the contamination poses a significant health risk. In the Phase II ESA, samples of soil and groundwater are collected from the property and analyzed for evidence of contamination.
If contamination is present, results are compared to screening levels established by regulatory agencies or a health risk assessment (HRA) can be prepared. Either of these strategies can potentially be used to demonstrate that health risks are not significant for the property’s current or future use or to determine the level of remediation necessary.
Dealing with Significant Soil Vapor Contamination
If soil vapor intrusion poses a significant health risk, there are ways to mitigate that risk. Mitigation can include removal of the contamination, active mitigation of the contamination source, and protection against indoor air exposure. The approaches are not mutually exclusive, and multiple risk reduction strategies may be used.
The most effective way of reducing soil vapor risk is to remove or treat the soil or water that is the source. This remediation is the most cost-effective for small sources of contamination and when that contamination can be easily accessed. It is often not feasible to remove the source when contamination originates offsite and moves onto the property in a groundwater plume. It may also be more cost-effective to mitigate risk through other means when the source of the vapor intrusion is extensive or difficult to remove.
In active mitigation, soil vapor intrusion is mitigating by reducing contamination at the source. Active systems can include soil vapor extraction, in which vapor is collected and removed; in situ treatment, which uses chemical reagents to transform the contamination into less toxic chemicals; and containment of the contamination source by some form of barrier. Under ideal conditions, these methods have the potential to be highly effective in reducing contamination but monitor treatment for effectiveness and to determine that the resulting contamination levels are acceptable.
It is also possible to mitigate indoor air exposure to soil vapor intrusion. Underground vents, membranes, and seals beneath the foundation and slab depressurization can reduce the flow of soil vapor into a building. This type of passive mitigation leaves the contamination source in place, which may limit future uses for the contaminated property, but it may be more cost-effective than active mitigation, especially in cases where contamination originates off the property. Regulatory agencies typically require that properties mitigating the movement of soil vapor into buildings monitor the ongoing mitigation on a continuous basis with sensors and alarms or periodic resampling.
What You Need to Know
Soil vapor intrusion is a potential environmental liability, but it is manageable. Environmental due diligence can significantly reduce unforeseen costs of vapor intrusion by identifying the issue for proactive management before development, which is always easier and more cost-effective than trying to address a problem after development. It is possible to mitigate health risk from soil vapor intrusion on developed sites. Developers should work with qualified environmental consultants to address vapor intrusion through each stage of the process to adequately minimize risk.
A look at the confusion stemming from regulatory uncertainty of new rules limiting air emissions from municipal solid waste landfills by David Greene, P.E., SCS Engineers – Asheville, NC.
The landfill industry continues to work with EPA Administration to get a longer-term stay to work out needed NSPS/EG rule changes. At this time, industry representatives are hopeful both these related goals can be achieved.
While the new NSPS/EG rules became effective back in 2016, the concerns with the rules raised at the time still remain unresolved. Despite this, we can expect resolution though it may take some time to fix. The fog should be lifting, yielding changes that are expected to be more workable for both the landfill industry and state/local regulators. In the meantime, stay tuned and stay informed.
Read the full article with links to the NSPS/EG update in a recently published SCS Technical Bulletin.
Agri-business companies handling large quantities of chemicals and transporting them through all sorts of conditions to different facilities must be prepared for an accidental spill. Accidental spills create environmental problems that can cost your business. However, agri-businesses can control their response to spills and react in ways that limit the environmental impact and help save time and money should a spill occur.
Environmental consultant, Tony Kollasch first discusses, what businesses can do to minimize environmental impacts? He covers the importance of spill response preparedness and REACT; Respond, Evaluate, Alert, Contain, Take.
Read the full article published in Wisconsin Agri-Business News Quarterly.
SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. Our most recent SCS Bulletin summarizes the new rules which took effect on October 28, 2016, with compliance obligations under the NSPS Subpart XXX rule beginning November 28, 2016. Originally, states and local air jurisdictions were to submit their proposed EG rules by May 30, 2017; however, there have been some delays in this process, which we condense and detail in this Bulletin. SCS will continually update coverage of this Rule on our website.
In a Motion filed on November 7, the U.S. Environmental Protection Agency (USEPA) requested remand of five provisions of the Coal Combustion Residuals (CCR) Rule (40 CFR Parts 257 and 261), which would allow the agency to reconsider the provisions. This SCS Engineers Technical Bulletin covers the five provisions and the basis for their reconsideration. Read the full text here.
Oral arguments on EPA’s motion took place on November 20, 2017. EPA had asked that oral arguments be postponed, and all other aspects of the litigation are suspended until it could rule, but the court did not agree. The current provisions in this Technical Bulletin remain in place unless and until USEPA revises or rescinds them in a future rulemaking.
SCS Engineers will continue to track these issues and keep you informed. Join our Technical Bulletin email list by clicking here, or follow SCS on LinkedIn, Facebook, or Twitter .
Using a simple example the authors make apparent the importance of understanding a refrigeration system’s actual performance. An energy balance is a very useful tool to do so.
Not only do PSM regulations require that facilities have this in your PSM program, there is real value in understanding a system’s capacities. Operation and efficiency translates to substantial dollar savings every year. Savings that can be reinvested in your facility.
Calculating the total consequences of an unbalance system is more complex, but there are considerable savings running a properly energy balanced refrigeration system. Savings that can fund maintenance needs and avoid postponing timely repairs.
This white paper, presented at the RETA 2017 Conference in Pennsylvania is available in English and Spanish by clicking here.
Learn more about environmental and engineering services for Process Safety Management (PSM), Risk Management Plans (RMP), and ammonia refrigeration safety at SCS Engineers.
Ann O’Brien of SCS Engineers has pulled together a list of questions that printers should be asking themselves before the environmental reporting season is upon us.
Use Ann’s questions as a guide to find out how ready your company is, and decrease your risk of non-compliance by being more organized.
If you don’t know the answers, ask Ann. She’s one of our air and water permitting, monitoring, and reporting experts at SCS. Ann specializes in printing industry compliance.
Contact and we’ll direct you to an air, storm water, wastewater, or groundwater expert near you and in your industry.
Temporary Landfill Caps
Temporarily capping landfill slopes is becoming a common measure for landfill operators. There are many benefits to closing landfill slopes with geomembrane on a temporary basis. One of the benefits is delaying construction of the final cover. Following is a discussion of the steps that should be taken to determine whether temporarily capping the slope with geomembrane and postponing the final cover construction is a better financial/operational decision.
Cost Burden
Constructing the final cover is costly, and it is considered an unavoidable expense that has no return on the money spent. Therefore, some operators perform a financial evaluation to determine whether the final cover construction costs can be delayed (provided, of course, that such delays are acceptable to the regulating agency). When evaluating whether to delay the final cover, the cost of maintaining the slopes during the postponement period should be considered. The operator must look at the financial aspects of either closing the slopes with a temporary geomembrane or of leaving the slopes open during the postponement period.
Temporary Landfill Capping Option
The benefits of temporarily capping the slopes during the postponement period may include:
The other side of the coin is the expense associated with the temporary cap. There may be repair costs associated with the geomembrane every few years in order to ensure that the temporary cap remains intact.
Leaving Slopes Open Option
The option of leaving the slopes open during the postponement period involves maintenance expenses such as:
The benefits of leaving the slopes open are twofold: first, the operator will save the costs of constructing the temporary cap; and second, the operator will gain additional airspace as waste settles during the postponement period.
Experience with the Temporary Capping Option
As discussed above, both options provide the benefit of gaining additional airspace during the postponement period. Constructing a temporary cap involves the costs of materials and installation, including the geomembrane and the ballasting system that keeps the geomembrane in place. Generally, the financial and non-tangible benefits of a temporary cap that remains in place five years or longer are more attractive than leaving the slopes open; therefore, most operators choose to install a temporary cap. The next step in the financial evaluation should be comparing the costs of the temporary cap to permanently closing the slopes without postponement.
Final Step in the Financial Evaluation
The next question is whether it makes financial sense to postpone the construction of the final cover.
Waste settlement during the postponement period and the resulting airspace are considered the determining financial factor in choosing the right option. If the present worth value of the airspace generated from waste settlement during the postponement period is greater than the cost to construct the temporary cap at the present time, then the temporary cap option would make financial sense; otherwise, the final cover should be constructed without postponement.
It should be noted that the length of the postponement period plays a very important role in this financial equation. Longer postponement periods have the potential for a greater gain in airspace. Another incentive that should be factored into the financial evaluation is the potential return on the money set aside for the final cover construction during the postponement period.
To assist with this financial evaluation, landfill operators are encouraged to discuss these options with their landfill engineers. Settlement models can be performed to calculate the amount of airspace that may be generated during the postponement period as well as the present worth value of the generated airspace. The returns on the final cover construction costs during the postponement will just be “icing on the cake.”
Read the related Advice From the Field blogs from the landfill and LFG experts at SCS Engineers:
Contact the author: Ali Khatami or your local SCS Engineers’ office.
Discovering unexpected pockets of soft soils at the time of construction can delay your project and drive up costs for landfills, support features, and many other types of construction. If you don’t find them, building over them can result in unexpected settlement affecting a structure or building, or cause a slope stability problem for a berm or stockpile. You can avoid both of these scenarios with early investigation and appropriate construction planning.
While landfill development investigations typically require numerous soil borings within the proposed waste limits of the landfill, it’s common to overlook perimeter areas. Pockets of soft soil deposits can be associated with nearby existing wetlands, lakes, or rivers; with wind-blown silt or ancient lake deposits from periods of glaciation; or with fill placed during previous site uses.
The landfill perimeter areas may contain tanks for leachate or fuel, buildings, perimeter berms for screening or landscaping, stockpiles, and other features. A tank or building constructed over soft soils could experience unexpected settlement affecting the performance and value of the structure. The potential for a slope stability problem can increase for a large berm or stockpile built on soft soils.
The first step to avoid these problems and identify problem soils is to include perimeter areas in your subsurface investigation. Perform soil borings or test pit excavations at the locations of the proposed perimeter features such as tanks or berms. If you encounter soft soils, address them like this:
Contact SCS’s geotechnical engineers for more information on how to find and test soft soil areas early in a landfill’s project schedule, so you can effectively address associated construction issues in a way that considers cost and minimizes unexpected project delays.
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