Join us on March 4 at 12:30pm Eastern, as Lori J. Gross, Ph.D., PE (Senior Hydrogeologist), and Gary Long (Sediment & Risk Assessment Service Group Leader) of EHS Support discuss the importance of developing robust and effective Conceptual Site Models (CSMs) for sediment sites.A CSM is essential for conveying a clear and complete picture of what is happening at a specific site. The concept of CSMs has been around for decades but integrating complex data and interpretation of data into a cohesive, relatable story can be challenging and highly dependent on the audience, forum for communication, and relevancy to the site or project objectives. During this webinar we will address background information on CSMs, present a detailed sediment-related case study where a robust CSM is critical to the selection of the preferred remedial alternative, and share other examples demonstrating how CSMs can be used to successfully engage stakeholders and lead to favorable outcomes over the lifecycle of a sediment project.Register for the Webinar.Let's block ads! (Why?)

Classified as a likely human carcinogen, 1,4-dioxane has been found at numerous chlorinated solvent-contaminated sites throughout the United States. Combined physical and chemical properties, along with the behavior of 1,4-dioxane, create ongoing challenges for both its characterization and treatment. Over the years, many scientists have searched, but none have found a convincing path to biodegradation of 1,4-dioxane in the absence of oxygen. This lack of evidence has resulted in many experts wondering if anaerobic biodegradation of 1,4-dioxane truly exists.Recent research by Ramalingam and Cupples (2020)1 showed that the long-sought but elusive anaerobic biodegradation of 1,4-dioxane occurs under extreme methanogenic reducing conditions (that’s oxidation-reduction potential (ORP) values of less than -200 mV (against Ag/AgCl electrode).Conventional thinking that usually relies on separate remedies for 1,4-dioxane and its chlorinated solvent counterparts may soon be changing to a new paradigm that involves a single synergistic remedy: anaerobic biostimulation with bioaugmentation. These findings provide hope that chlorinated solvents and 1,4-dioxane in groundwater can be removed at the same time and space with conventional anaerobic biostimulant and cultured bacteria injection strategies. Knowing that an anaerobic counterpart to aerobic 1,4-dioxane bioremediation is finally emerging may help to shape (or reshape) remediation strategies that shift toward less expensive passive remedies and away from more expensive conventional active remedies like pump-and-treat.The research by Ramalingam and Cupples is sure to inspire further research toward isolation and cultured growth of anaerobic 1,4-dioxane-degrading microorganisms. If the history of remediation bacteria cultures containing aerobic 1,4-dioxane-degrading microorganisms (like CB1190) is a guide, then commercial remediation cultures containing anaerobic 1,4-dioxane degraders could be on the way in just a few years.If you would like to discuss 1,4-dioxane remediation in more detail, EHS Support’s team of subject matter experts are here to help:Will Harms, In-Situ Remediation Services PractitionerLaurel Seus, Remediation MicrobiologistJohn Bartos, Senior Remediation Hydrogeological EngineerRich Landis, Senior Innovative Technologies Practitioner1Source: Ramalingam, V., Cupples, A.M. Anaerobic 1,4-dioxane biodegradation and microbial community analysis in microcosms inoculated with soils or sediments and different electron acceptors. Appl Microbiol Biotechnol 104, 4155–4170 (2020). https://doi.org/10.1007/s00253-020-10512-3Let's block ads! (Why?)

Congratulations to the Distilled Spirits Council for launching the DISCUS Academy, the first to be offering curriculum & industry-recognized certifications related to the business of distilling!EHS Support, a proud Partner Member of DISCUS, is excited to participate in the launch of DISCUS Academy.  EHS Support’s own DISCUS Academy Instructors include: Shannon Barr (Building a Safety Program), Amy Bauer (Regulated Waste), and Amy Trautman (Sustainability in Distilling, to be co-presented with Marble Distilling).  EHS Support’s Jerry Hincka is a member of the DISCUS Academy Curriculum Committee.This is just the first round.  We look forward to continuing our partnership with the DISCUS Academy throughout the year.Let's block ads! (Why?)

On January 15, 2021, the United States Environmental Protection Agency (USEPA) issued the 2021 Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The MSGP becomes effective on March 1, 2021.BackgroundThe USEPA established National Pollutant Discharge Elimination System (NPDES) permit requirements for industrial stormwater discharges in 1990 and the agency first issued the MSPG for those facilities in 1995. The new 2021 MSGP replaces the 2015 MSGP, which was issued on June 4, 2015.The MSGP applies in areas of the country where USEPA is the NPDES permitting authority and has made the permit available for coverage. These areas include:Massachusetts, New Hampshire, New Mexico, Idaho, and the District of ColumbiaAll U.S. territories except the Virgin IslandsFederally-operated facilities in Colorado, Delaware, Vermont, and WashingtonMost Indian country landsOther designated activities in specific statesUSEPA held a 90-day comment period for the proposed MSGP from March 2, 2020, to June 1, 2020. A total of 195 total comment letters and 1,895 unique comments were received and considered in the development of the new MSGP. The 2021 MSGP includes new or modified requirements compared to the 2015 MSGP, as outlined below.Significant General Changes in the 2021 MSGPThe following list summarizes the most significant changes to the 2021 MSGP:Streamlining of Permit: USEPA streamlined and simplified the language throughout the permit to present the requirements in a more clear and readable manner.Public Sign of Permit Coverage: MSGP operators are required to post a sign of permit coverage at a safe, publicly accessible location close to the facility.Consideration of Stormwater Control Measure Enhancements for Major Storm Events: Operators are required to consider implementing enhanced stormwater control measures for facilities that could be impacted by major storm events, such as hurricanes, storm surge, and flood events.Monitoring ChangesIndicator Monitoring for pH, TSS, and COD: A new provision requires operators to conduct indicator analytical monitoring for pH, total suspended solids (TSS), and chemical oxygen demand (COD) quarterly for the duration of the permit. This requirement applies to all operators in the following subsectors that do not have sector-specific benchmark monitoring requirements in the 2021 MSGP: B2, C5, D2, E3, F5, I1, J3, L2, N2, O1, P1, R1, T1, U3, V1, W1, X1, Y2, Z1, AB, AC, and AD. This monitoring requirement does not apply to the Wood Products Sector (Sector A).Indicator Monitoring for Polycyclic Aromatic Hydrocarbons (PAHs): This new provision requires certain operations to conduct “report-only” indicator analytical monitoring for PAHs bi-annually during the first and fourth years of permit coverage. This applies to operators in all sectors with stormwater discharges from paved surfaces that will be sealed or re-sealed with coal-tar sealcoat, or operators in sectors A, C, D, F, H, I, M, O, P, Q, R, and S. This requirement includes the Wood Products Sector (Sector A).Updating Benchmark Threshold Values: USEPA modified the benchmark monitoring thresholds in the 2021 MSGP for aluminum; copper and selenium for discharges to freshwater; and cadmium based on revised current Clean Water Act section 304(a) national recommended aquatic life water quality criteria. Additionally, the 2021 MSGP suspended the benchmark monitoring thresholds for magnesium and iron based on a lack of documented acute toxicity.Updating the Benchmark Monitoring Schedule: Applicable operators are required to conduct benchmark monitoring quarterly in their first and fourth years of permit coverage.Impaired Waters Monitoring: Operators discharging to impaired waters without a USEPA-approved or -established total maximum daily load (TMDL) must complete annual monitoring for discharges of certain pollutants to impaired waters. Monitoring is required for one year at each discharge point for all pollutants for which the water body is impaired, after which the operator can discontinue monitoring for the next two years for any pollutant that is not detected.Additional Implementation Measures (AIM): This provides new revisions to the AIM requirements for benchmark monitoring exceedances that were included in the proposed 2020 MSGP. USEPA revised these provisions to address concerns raised in public comments. Both the proposed 2020 MSGP and the final 2021 MSGP maintain a three-level structure of advancement and responses triggered by benchmark exceedances. The final 2021 MSGP AIM requirements reduce costs and complexity from the proposal by creating a stepwise, sequential advancement through the AIM levels with a clear “resetting” to baseline status if benchmark thresholds and responses are met within the required deadlines.2021 MSGP Changes Impacting the Wood SectorSector A – Timber Products of the 2021 MSGP covers general sawmills, planing mills, log storage facilities, and wood preserving facilities. Sector-specific requirements for the Timber Products Sector are provided in Part 8, Subpart A of the 2021 MSGP. Before finalization of the 2021 MSGP, comments were submitted to USEPA on its proposed 2020 MSGP to address concerns of the Timber Products Sector by the Treated Wood Council (TWC) and the Federal Water Quality Coalition (FWQC). Key changes to the MSGP impacting the Timber Products Sector are outlined below.Stormwater Control Measures for Major Storm Events: The requirement to implement enhanced stormwater controls for major storm events has been removed. The 2021 MSGP only requires discharges to consider implementing enhanced control measures for facilities that could be affected by major storm events, such as hurricanes, storm surge, and flood events. USEPA is not requiring operators to implement additional controls if the operator determines such controls to be unnecessary, but USEPA is requiring operators to consider the benefits of selecting and designing control measures that reduce risks to their industrial facility and the potential impact of pollutants in stormwater discharges caused by major storm events.Removal of Universal Benchmark Monitoring for pH, TSS, and COD: Under the 2021 MSGP, the requirement for universal benchmark monitoring for pH, TSS, and COD in the Timber Products Sector has been removed. Instead, there will be non-benchmark monitoring of those parameters required only for those subsectors that currently have no sector-specific benchmark monitoring requirements. Benchmark monitoring for COD and TSS is required under Subsectors A1 (General Sawmills and Planing Mills) and A4 (Wood Products Facilities not elsewhere classified). Additionally, TSS monitoring is required in Subsector A3 (Log Storage and Handling).Modification of Copper Benchmarks: Benchmark monitoring for copper is required under Wood Preserving Subsector A2. The 2021 MSGP updated the Total Recoverable Copper Benchmark for copper discharges to freshwater to 5.19 micrograms per liter (µg/L). The Copper Benchmark for discharges to freshwater were previously hardness-dependent in the 2015 MSGP.Modification of AIM Requirements: The modification of the AIM requirements in the 2021 MSGP addresses some concerns posed by the TWC and FWQC, by ensuring that a discharger has the opportunity to take compliance steps at one AIM level before being moved to the next level. All operators subject to benchmark monitoring requirements begin in the baseline status at the start of their permit coverage. An operator would progress linearly through the three AIM levels (AIM Level 1, Level 2, and Level 3) if an exceedance triggering event occurs and continues. The operator is required to respond with increasingly robust control measures and continued benchmark monitoring with each subsequent AIM level. The following exceptions to the AIM requirements are offered in the 2021 MSGP for an exceedance triggering event at any AIM Level:Natural background sourcesRun-onOne-time abnormal eventDemonstration that discharges of copper and aluminum do not result in an exceedance of facility-specific criteria using the national recommended water quality criteria in-lieu of the applicable MSGP benchmark thresholdDemonstration that the benchmark exceedance does not result in an exceedance of an applicable water quality standardCoal-Tar Sealants: The restrictions on permit eligibility if a facility uses coal-tar sealants have been removed. The 2021 MSGP requires indicator monitoring for PAHs for all facilities in the Timber Products Sector with stormwater discharges from paved surfaces sealed or re-sealed with coal-tar sealcoat, or that use or store creosote or creosote-treated wood in areas exposed to precipitation. The indicator monitoring is a “report-only” requirement in the first and fourth years of permit coverage. No thresholds or baseline values were established for these parameters.What’s Next?The 2021 MSGP is currently frozen for review by the new administration. If approved, the 2021 MSGP will become effective on March 1, 2021.Learn MoreEHS Support’s compliance experts can assist you with preparing your facility for the updates in the 2021 MSGP and can answer any questions you may have about this update. Please reach out to Bruce Martin for:Questions related to changes to the 2021 MSGPCompliance concerns with the 2021 MSGPAssistance navigating new AIM requirementsAny other MSGP related questions!Let's block ads! (Why?)

Annual reporting requirements for chemicals included in the Toxic Release Inventory (TRI) under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) will be substantially expanded to include 172 per- and polyfluoroalkyl substances (PFAS). While this requirement is likely to impact a relatively small number of industrial facilities involved in the manufacture or use of PFAS, it represents a growing trend to monitor for and address PFAS in drinking water supplies, as part of remedial investigations, and in manufacturing settings. This summary provides an overview of the TRI changes and will assist the regulated community in determining if an additional evaluation of the specific chemical inventory at your facility may be warranted.PFAS are included in a group of chemicals used in home and personal, industrial, agricultural, military, and commercial products, including firefighting foam, stain or water-repellant fabric coatings, and non-stick cookware. These chemicals are persistent and extremely resistant to degradation in the environment, properties that make them well suited for their intended uses. Although several PFAS chemicals, such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate acid (PFOS), have been phased out by industry either voluntarily or at the direction of regulatory agencies, many PFAS are still actively used. Since 2000, the United States Environmental Protection Agency (EPA) has reviewed hundreds of new PFAS chemicals. In many cases, the agency used its authority under the Toxic Substances Control Act (TSCA) to impose restrictions on these substances. EPA has a PFAS Action Plan which establishes the steps being taken to address PFAS and protect public health. Related to this PFAS Action Plan, in June 2020, EPA issued a final rule allowing it to prohibit companies from manufacturing, processing, or importing products containing certain long-chain PFAS, which persist in the environment and can cause adverse health effects, without prior EPA review and approval.Background:Section 7321 of the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law on December 20, 2019, adding certain PFAS to the EPCRA Section 313 list of reportable toxic chemicals for the first time. The NDAA established a reporting threshold of 100 pounds for each of the listed PFAS that a company manufactures, processes, or otherwise uses during the 2020 reporting year. TRI reporting for PFAS for reporting year 2020 is due by July 1, 2021.A searchable table of the TRI-listed PFAS can be found here.Threshold Determinations:The threshold quantity for the newly added PFAS is 100 pounds of any single compound, for the entire site, over the calendar year. Reporting is required if the threshold quantity for “manufacturing, processing, or otherwise use” of the compound is exceeded. As with all listed chemicals, the threshold quantity of any listed PFAS is determined by:Evaluating if materials manufactured, processed, or otherwise used contain PFASReasonably estimating the concentration of PFAS in mixturesIncluding the storage of an EPCRA Section 313 chemical if the facility exceeds the threshold for the same toxic chemical elsewhere in the facilityEvaluating any waste received from an off-site source for further waste management (this is considered “otherwise used”)ExemptionsThere is a de minimis exemption in the regulation that allows covered facilities to disregard certain minimal levels of listed toxic chemicals from the reporting requirement that are included in mixtures or trade name products. The de minimis level for PFOA (CAS number 335-67-1) is 0.1 percent; all other PFAS have a de minimis level of 1 percent.Several other exemptions exist in the regulation, including an articles exemption, janitorial/facility grounds maintenance exemption, structural component exemption, personal use exemption, and intake air and water exemption. It is important to understand whether any of these exemptions may apply to a specific facility.Aqueous Film Forming Foams (AFFFs) for FirefightingA major source of PFAS is related to the storage and use of PFAS-containing aqueous film forming foams (AFFFs), which are synthetic foams designed to combat flammable liquid or Class B fires. AFFFs have been widely used at military installations and airports, resulting in PFAS-impacted soils, surface water, and groundwater. The use of fire suppression systems containing AFFF for system testing, training, or to suppress a fire as part of an emergency response would fall under the “otherwise use” category of the TRI-listed chemicals, and the materials may be reportable if stored above the threshold quantities. The placement of AFFF into a fire suppression system is not an “otherwise use” activity for TRI reporting purposes until the AFFF is released from the system. The storage of AFFF is not considered a manufacturing, processing, or “otherwise use” activity; however, as noted above, if the same EPCRA Section 313 chemical is manufactured, processed, or otherwise used elsewhere at the facility, then the total stored quantities of the same chemical are cumulative, and must also be reported.What’s Next?EPA expects that additional PFAS compounds will be added to the TRI list for Reporting Year 2021, with TRI reports due by July 1, 2022, as mandated by NDAA Section 7321(c), specifically for any PFAS compound where:EPA finalizes a toxicity value; orSignificant New Use Rules (SNURs) are issued under TSCA, or the specific PFAS is added to certain existing SNURs; orIt is added as an active chemical on the TSCA Inventory.Learn More:EHS Support’s compliance experts can assist you with your facility determinations and can answer any questions you may have about this update. Please reach out to Bruce Martin for:Questions related to threshold determinations or possible exemptionsHow to quantify and report the storage and use AFFFAny other PFAS related questions!Let's block ads! (Why?)

When it comes to in-situ injection remedies there is no one-size fits all solution. A good conceptual site model enables injection remedy designers to get it right the first time; well, almost right the first time. That is correct, ‘almost right‑the‑first‑time’ because even the best investigation tools and conceptual site models are unable to fully predict behavior, performance, and implementation issues of injection remedies. Today’s changing paradigm for injection remedies recognizes need to embrace adaptive optimization along the way.For example, the Interstate Technology & Regulatory Counsel (ITRC) released a 2020 Guidance Document1 entitled Optimizing Injection Strategies and In Situ Remediation Performance details how ineffectiveness can be avoided through effective up-front characterization and design, attentive monitoring and performance interpretation, and follow-on in-progress enhancements (aka adaptations and optimization initiatives) as informed by performance monitoring results. Driven by firsthand knowledge and experiences, this guidance document provides valuable insight for environmental consultants, responsible parties, federal and state regulators, and community and tribal stakeholders.From EHS Support’s perspective, agencies have largely embraced the use of adaptive management and adaptive optimization for injection-based remedies. Yet regulators remain conflicted as some of their (aged) statutes, rules, and guidance are written in a linear fashion (assess, design, construct, implement, monitor, close when cleanup objectives are met) – offering little or no path for refining the remedy along the way.EHS Support is skilled at navigating the nuances of the ridged and linear-thinking legacy regulations. Through this experience, we have found that incorporating a more-modern path to cost-effectiveness garners optimum performance leading to a more-timely and more-cost effective remedy completion.If you would like to discuss in more detail, EHS Support’s team of subject matter experts are here to help:Will Harms, In-Situ Remediation Services PractitionerJohn Bartos, Senior Remediation Hydrogeological EngineerRich Landis, Senior Innovative Technologies PractitionerLaurel Seus, Remediation MicrobiologistSources 1 ITRC. 2020. Optimizing Injection Strategies and In situ Remediation Performance. OIS-ISRP-1. Washington, D.C. OIS-ISRP Team. 2020 Guidance Document: https://ois-isrp-1.itrcweb.org/Let's block ads! (Why?)

Regulations addressing PFAS and state-specific sampling requirements are outpacing the science. In order to move forward, we may find some guidance by revisiting the past lessons learned from PCBs.  Dana McCue, Senior Risk Assessor at EHS Support and Charles M. Denton, Partner at Barnes & Thornburg, take a closer look in this recent blog post.Let's block ads! (Why?)

The cannabis industry is one of the fastest growing and most regulated industries in the United States.  This rapid growth, both in sales and in States allowing Cannabis use, creates dynamic regulatory challenges, and unprecedented opportunity for environmental sustainability leadership.Recognizing this, the National Cannabis Industry Association (NCIA), has released a detailed report Environmental Sustainability in the Cannabis Industry: Impacts, Best Management Practices, and Policy Considerations, focusing on the unique environmental challenges facing businesses in the cannabis industry.“The cannabis industry has the opportunity to be a trailblazer in environmental sustainability, but unfortunately is being held back by lack of knowledge, unnecessary regulations, and onerous financial burdens, which encourage the continued existence of unregulated markets, and make it difficult for regulated businesses to implement the practices and technology they would like to use,” said Aaron Smith, co-founder and CEO of the NCIA.  “We hope cannabis businesses and regulators will work together using this report to make our industry the environmentally responsible example for other industries to follow.”The report is a collective effort produced by NCIA’s Policy Council with the assistance of national experts across a variety of disciplines – addressing issues including land use, water, energy, air quality, and waste.Click here to read the complete report.EHS Support Compliance Specialist Maureen Bayer was a contributor to this NCIA report.Let's block ads! (Why?)

By: Will Harms, Bioremediation Services Practitioner and Laurel Seus, Remediation MicrobiologistAbiotic mechanisms responsible for natural and enhanced detoxification of chlorinated compounds like tetrachloroethene (PCE, tetrachloroethylene) and trichloroethene (TCE, trichloroethylene) are increasingly recognized for their credible role in holistic in-situ remediation of chlorinated solvents. The reason? The means to understand and measure abiotic degradation of chlorinateds is finally emerging – making way for more effective and less expensive treatment options.The Department of Defense (DoD) has two dedicated environmental research programs, the Strategic Environmental Research and Development Program (SERDP), and the Environmental Security Technology Certification Program (ESTCP). Among all things remediation, SERDP/ESTCP is keenly focused on abiotic natural attenuation (ANA) and on iron-based in-situ chemical reduction (ISCR) techniques. Together, these abiotic treatment research initiatives focus on:practical metrics of performance,enhancing utility of solvent-reactive biogenic iron minerals,factors that control abiotic degradation rates, anduse of dissolved iron additives (Fe(II), Fe2+).SERDP/ESTCP’s investment in researching abiotic mechanisms of chlorinated detoxification not only benefits the DoD but extend to private site owners and the entire remediation industry. These learnings are made readily available to the public and SERDP/ESTCP research reports are respected by regulatory agencies.For example, take the recent work of Sherer et al., 20191 entitled Biologically Mediated Abiotic Degradation (BMAD) of Chlorinated Ethenes: A New Conceptual Framework found conditions that favor active precipitation of metastable reactive mineral intermediates (RMIs) onto surfaces of aquifer materials that lead to effective detoxification of chlorinated compounds in groundwater include relatively high dissolved iron concentrations and relatively high groundwater flow rates.This means that adding dissolved iron to in-situ treatment zones may be a more effective and less expensive option than emplacement of broadly accepted metallic iron products like zero valent iron (ZVI). At EHS Support, the concept to adding dissolved iron (Fe2+) (like ferrous gluconate) instead of particulate iron products like ZVI is not new. In fact, we are close to implementing an in-situ source remedy at one of our client trichloroethylene TCE sites that will use soluble ferrous gluconate along with emulsified biostimulants to gain maximum TCE detoxification through in-situ chemical reduction-enhanced anaerobic bioremediation.If you would like to discuss biologically mediated abiotic degradation in more detail, EHS Support’s team of subject matter experts are here to help:Will Harms, Bioremediation Services PractitionerLaurel Seus, Remediation MicrobiologistJohn Bartos, Senior Remediation Hydrogeological EngineerRichard Landis, Senior EngineerSource:1Michelle Scherer, Drew Latta, Anke Neumann, David Cwiertny, and Rula Deeb. 2019. Biologically Mediated Abiotic Degradation (BMAD) of Chlorinated Ethenes: A New Conceptual Framework. SERDP Final Report ER-2532. Feb 12, 2019.Let's block ads! (Why?)

By: Will Harms, Bioremediation Services PractitionerIn recent years, polyfluorinated pollutants have emerged as recalcitrant pollutants with limited remediation options – but new options may be on the horizon.Fluorinated compounds are naturally harder to biodegrade than their chlorinated cousins due to the carbon‑fluorine bond (C‑F) being stronger than carbon‑chlorine bonds (C-Cl). The conventional paradigm that polyfluorinated compounds – like per- and polyfluoroalkyl substances (PFAS) – are not subject to effective bioremediation is finally being challenged.A recent article by Yu et al. 20201 illuminates the possibility that conventional anaerobic biostimulation techniques, such as those commonly used to bioremediate polychlorinated compounds, can also biodegrade fluorinated compounds when augmented with defluorinating bacteria cultures.This means that bioremediation bacteria cultures that work on polyfluorinated pollutants could be on their way to market – aiding your approach to remediation strategies and decision-making.To learn more, contact our subject matter experts: Laurel Seus, Remediation Microbiologist or Will Harms.1 Microbial Cleavage of C–F Bonds in Two C6 Per- and Polyfluorinated Compounds via Reductive DefluorinationYaochun Yu, Kunyang Zhang, Zhong Li, Changxu Ren, Jin Chen, Ying-Hsuan Lin, Jinyong Liu, and Yujie MenEnvironmental Science & Technology Article ASAPDOI: 10.1021/acs.est.0c04483Graphic (source: Yu et al. 20201)Let's block ads! (Why?)