It might feel like the July 1 deadline is far away, but it is time to start preparing to report your releases of toxic materials. The U.S. Environmental Protection Agency (USEPA) indicates that printing and related industries are subject to this report. It is an important part of your environmental compliance strategy if you have a facility with at least 10 full-time equivalent employees in a covered NAICS code that exceeded a reporting threshold in the previous calendar year. Reporting releases of toxic materials on an annual basis is one aspect of the Emergency Planning and Community Right-to-Know Act (EPCRA).
Read the article with steps to your report for printing and related industries.
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right To Know Act (EPCRA), Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) and Section 112(r) of the Clean Air Act
Secondary containment is a basic engineering control to prevent a chemical or oil spill. There are misconceptions, though, regarding secondary containment requirements. In terms of oil-based storage, these misconceptions can lead to not enough containment capacity, significantly more containment capacity than necessary, or simply not providing the right level of containment when containers are grouped.
Chris Jimieson of SCS Engineers explains the five most common misperceptions and advises you how to keep your facility in compliance.
Read the article by clicking here.
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.
Fangmei Zhang, P.E., PhD, is a Senior Project Manager in the Miami Office of the Southeast Region. She has 13 years of experience in the environmental and civil engineering field, with 7 years at SCS Engineers. Fangmei received her Bachelor of Science degree from Southeast University (China), her Master from Tongji University (China), and PhD from Case Western Reserve University (Ohio), all in Environmental Engineering.
At SCS, Fangmei manages assessment, remediation, and redevelopment projects for some of our largest clients. Fangmei is also a founding member of the SCS Technical Advisory Group, a newly created group of staff who serve as technical advisors on environmental projects. She also leads the region’s Environmental Services Technical Committee. The intent of this committee, which is comprised of a group of environmental leaders through the region, is to foster a forum for the identification, evaluation, and implementation of new and emerging technologies to enhance technical excellence and to facilitate SCS’s growth as a leader in the environmental engineering and consulting field. Fangmei is also a founding member of the Southeast Region’s SCS Women, a group recently created to provide mentorship and support to empower women to achieve career and personal success.
Fangmei was born in a remote village in east-central China. Growing up in the countryside, Fangmei has unforgettable memories of being close to nature. As a child, she learned how to plant rice in rice paddies, to work with cotton and hem fields, and to plant vegetables. She picked wild vegetables to feed pigs and collected chicken droppings to use as organic fertilizer using tools hand-made from bamboo sticks and river mussel shells. The country life she enjoyed as a child forged her love of nature.
Fangmei also loved going to school. At the time, she was the only girl who attended the village school, and she walked several miles each day to earn her education. After the fifth grade, she continued her education in Jingzhou, Hubei province, where schools were more competitive and provided better prospects for going to college. Eventually, she completed her BS and MS in China. In 2001, she came to the United States for further study, partly because environmental engineering in China did not yet address soil or groundwater contamination. She received her PhD in 2006 with research focusing on bioremediation.
Fangmei chose to come to the U.S. to study because she also loves to travel and see the world. She enjoys traveling to new places and learning about different cultures. She also loves visiting botanical gardens and farms. During her trip to Laos two years ago, she saw poor villages and little girls running around without shoes in the countryside, and it reminded her of her own childhood. Influenced by a friend and her experiences, Fangmei has provided financial support and assisted in other fundraising to help build schools in the villages in Laos and Cambodia, with the hope of providing these children with opportunities for a better future.
To learn more about a career with SCS Engineers, please visit the SCS Careers page.
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 .
Som Kundral is a Project Manager with the Miami office. He is currently managing a 500-acre C&D landfill redevelopment project involving multiple engineering disciplines. Som serves clients in the region by providing design and construction oversight of groundwater remediation and landfill gas management systems. He says redevelopment on old landfills pose interesting environmental challenges and can be complex given the heavy involvement of regulatory agencies.
Som was born in 1983 in India, raised in Karnataka, a state in southwest India on the coast of the Arabian Sea. He has two younger brothers, both of whom work in Information Technology. His parents are retired and live in India. He grew up in a typical middle-class family with an emphasis on tradition and culture, where one is taught to respect and obey elders and to protect the young.
As a child, he was curious about how things work and admits to destroying numerous gadgets attempting to reveal their secrets – so engineering was a natural career choice. His father is a Civil Engineer who influenced Som to get a Civil Engineering degree instead of a Computer Science degree. Som has a Bachelor’s degree in Civil Engineering and came to Miami in August 2010, to earn a Masters of Environmental Engineering. While at school, he says he fell in love with the place, the people, and the culture.
Som’s wife, also an engineer, moved from Houston after their wedding in 2012. They enjoy gardening, greenery, and farms. He also collects watches and gadgets. While enamored with motorcycles, once belonging to a biking group as an undergrad, he no longer bikes out of respect for his wife and says he misses it.
Som aspires to become a leader in the industry and wants to grow with SCS Engineers. Som’s mentor is SCS Vice President and Southeast Region Office Director Bob Speed, who states,
I’ve worked with Som for several years. Som accepts tasks regardless of the difficulty and completes each promptly. Our projects usually have numerous stakeholders; Som keeps them informed, so good communications play an important role in keeping our work on-task. I would describe Som as ‘humble, hungry and smart; he truly is an ideal team player for our clients and SCS.
Som is an enthusiastic member of the SCS team. We appreciate his contributions supporting clientele, enhancing our technical reputation, and contributing to our company culture of industry involvement.
