We often say that “PFAS are everywhere…”; we can now finish the sentence with “…even in the proposed American Jobs Plan.”The proposed Plan, shared by the White House on March 31, 2021, includes an eight-year, $2 trillion investment to modernize and improve U.S. infrastructure, generate jobs and economic growth, and promote American national security interests.But where are the PFAS?The Plan incorporates significant goals and objectives for the water industry.  It targets the need for upgrading and modernizing America’s drinking water sources, management, and delivery; wastewater and stormwater systems; and supporting clean water infrastructure across rural America.The Plan calls for $111 billion to update and improve clean water infrastructure, including $45 billion to replace lead pipes and service lines and $56 billion in drinking water grants and low-cost loans to states, Tribes, territories, and disadvantaged communities.Important to the regulated community, the Plan also incorporates new and emerging contaminants, earmarking $10 billion to monitor and remediate PFAS in drinking water.That’s where the PFAS are! This focus and proposed funding to address PFAS contamination are important to the regulated community, because:It is an initial and major sign acknowledging that PFAS will be dealt with on a Federal level sooner, rather than later.Science will be funded to improve our understanding of the behavior and environmental toxicity of PFAS, and better inform legislation and regulation.Federal regulation is likely to designate PFAS as a ‘Hazardous Substance’ clearing the path for regulatory-driven prioritization, site investigation, and clean up.Remediation dollars will be spent based on more realistic risk decisions that target true environmental risk and not potential threats based on overly conservative assumptions and faulty toxicity thresholds in the absence of appropriate data.Technical challenges associated with PFAS risk and remedial decision-making are complex and require multi-disciplined input. Now more than ever you will need an experienced partner to replace the ‘one size fits all’ approach, with a constituent and site-specific strategy focused on true risks if and where they exist.The inclusion of PFAS in the American Jobs Plan will drive additional scrutiny and study of these compounds. This includes increased focus by state and regulatory agencies, banks, lending institutions, and insurers. In addition, successful mergers, acquisitions, and divestitures will have to consider the timing of the developing regulatory requirements. EHS Support has a multi-disciplined team of PFAS experts who can guide you through the complex decision process and navigate the evolving regulations that may impact your business.To learn more, contact Ceil Mancini, Senior Scientist at EHS Support.Additional PFAS Articles by EHS SupportNew TRI Reporting Requirements for Certain PFAS CompoundsPFAS Emerging Contaminant Response Could Learn Some Lessons From PCBsAcquiring a Food or Beverage Company? Here is what you need to know about PFASWho We AreEHS Support is a global family of scientists, engineers, geologists, and technical experts who specialize in complex environmental, health, and safety (EH&S) challenges across industries and markets. We’ve successfully completed projects in over 100 countries, including water resources and remediation management, compliance and permitting, health and safety, and acquisitions and divestitures. We’re problem solvers and we’re passionate about what we do!Adblock test (Why?)

Finally, A Simple Way to Measure TCE Aerobic Degradation Rates in Groundwater (and you may already have the data).By: Will Harms, Senior Bioremediation EngineerCommonly used as an industrial solvent, trichloroethene (also known as trichloroethylene or TCE) has been shown to break down rapidly in air and surface water but much more slowly in soil and groundwater. Cometabolism has been widely accepted as an effective approach for the biological degradation of this hazardous solvent. When it comes to documenting natural attenuation of TCE in groundwater, however, the problem is estimating just how much aerobic biological cometabolism of TCE is occurring at a site.That is, until now. According to a recent study (Wilson et al. 2019), simple, readily available tests for bacteria DNA in groundwater can effectively predict rates of cometabolism of TCE in aerobic groundwater. This is particularly good news for aerobic TCE sites that would be candidates for a monitored natural attenuation (MNA) remedy.The key is the correlation between the rate of aerobic TCE cometabolism and the abundance of planktonic bacteria DNA that code for five fundamental biogenic enzymes: SMMO, RDEG, RMO, TOD, and PHE. By implementing the microbial test method known as QuantArray-Chlor (or even QuantArray-Petro). Many TCE sites have already tested for an abundance of planktonic bacteria DNA expressions for these specific enzymes and, therefore, already have the data needed to estimate rates of TCE degradation by aerobic cometabolosm. The test doesn’t work for sessile bacteria, however, like those harvested from aquifer sediments or from downhole Bio-Trap passive samplers.The costs are nominal. DNA tests for these five enzymes in groundwater samples cost about $575 per sample by a la carte qPCR method and $750 per sample for a QuantArray-Chlor test. The QuantArray-Chlor test includes these five enzyme DNA targets plus a bundle of about 20 other aerobic and anaerobic DNA targets that are known to be involved in chlorinated solvent degradation.Through the method described in the cited report, EHS Support was able to construct a simple spreadsheet-based calculator for quantifying aerobic TCE cometabolic degradation-rate constants. Screening three sites that already have planktonic microbial assays for biogenic enzymes SMMO, RDEG, RMO,TOD, and PHE, we found remediation-relevant TCE aerobic cometabolic degradation-rate constants between 0.1 per year and 0.3 per year. (The EPA recognizes that TCE degradation-rate constants greater than 0.1 year-1 are generally useful for MNA, based on a presumptive 30-year restoration timeframe).Simply put, EHS Support can readily screen your site for its TCE aerobic cometabolic degradation rate constant given only the results of DNA test results in your groundwater.If you’re interested in learning more, please contact one of EHS Support’s Subject Matter Experts:Laurel Seus, Remediation MicrobiologistWill Harms, Senior Bioremediation EngineerJohn Bartos, Senior Remediation Hydrogeological EngineerSource/Citation: https://ngwa.onlinelibrary.wiley.com/doi/full/10.1111/gwmr.12321Let's block ads! (Why?)

On March 5, 2021, EPA announced the proposed cancellation of Pentachlorophenol registration under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). The agency concurrently issued its Proposed Interim Registration Review Decision (ID) for Pentachlorophenol (Docket ID No. EPA-HQ-OPP-2014-0653). A registration review decision is the agency’s determination of whether a pesticide meets or continues to meet the standard for registration under FIFRA. Registration standards require continuous review of existing pesticides to ensure they will not cause harm to human health or the environment.Pentachlorophenol, or Penta, is a wood preservative that is classified as a restricted use pesticide (RUP). RUPs may only be sold to and used by certified applicators. Penta has been found to present health risks to occupational handlers, which prompted EPA’s proposal to cancel registration and phase-out use of the product across the wood treating industry.The proposed ID indicates that EPA anticipates a phase-out period of five years. The agency plans to submit a request for voluntary cancellation in March 2023. Penta users will then have three years to use existing stocks and transition to alternative preservation methods. This phase-out period is intended to provide stability to the utility pole market. EPA is currently accepting comments on the proposed phase-out process, and key industry groups have begun to submit their questions and concerns. While stakeholders may understand the potential human health risks associated with Penta use and be willing to work with EPA through the transition, many are uncertain that EPA has considered all the industry implications. Some of their concerns include:Short Timeline for Use of Existing StocksWood treating facilities typically stock large volumes of Penta product on-site in block or liquid concentrate form as well as diluted liquid form. Additionally, the utility market can be expected to quickly transition away from using Penta-treated poles in an effort to get ahead of the impending market changes. The combination of these factors may lead to a situation where demand is low and existing stocks of Penta remain high. Therefore, it is unclear whether 5 years is enough time to exhaust existing stocks.Unrealistic Decontamination StandardsF032 is the Resource Conservation and Recovery Act (RCRA) hazardous waste code for wastes generated from wood preserving processes that currently use or have previously used chlorophenolic formulations, including Penta. After transitioning to new preservation methods, wood treating facilities will want to remove this waste code from their hazardous waste profiles. According to 40 CFR 261.35, facilities that want to delete the F032 waste code must either replace all process equipment or decontaminate any process equipment that may have contacted Penta to below 0.01 parts per trillion of dioxins and dibenzofurans. The replacement of all equipment is not a financially viable option for most treating plants. Furthermore, industry professionals have raised concerns that the decontamination standard is unobtainable because dioxins and dibenzofurans are pervasive. Sites that have never used Penta have detected these chemicals in higher concentrations than what the standard allows. Facilities will need a practical way to manage their hazardous wastes under other waste codes. Thus, EPA may need to develop alternative decontamination requirements.Legality of Sale and Shipment of Partial StocksWood treating equipment typically requires a minimum volume (upwards of 20,000 gallons) of treating solution. This volume of solution is therefore leftover in the equipment following the treating process. For any facility that switches to an alternative treating solution, the leftover Penta solution would need to be pumped out of the machinery and either disposed of or used at another facility that is still treating with Penta. This may create a need for Penta solutions to be sold and transported between wood treating plants. Because these solutions are diluted (the dilution process occurs when they are added to the equipment at the original facility), they do not conform to any FIFRA chemical description. The industry would therefore need clarification on how to sell and ship these solutions while remaining in compliance with associated EPA and Department of Transportation (DOT) regulations. In addition, it may prove difficult for treating plants to find buyers of their excess stock when the industry is working to transition away from Penta use altogether.Clarification on Closure Requirements and the Treated Article ExemptionEPA has been unclear on certain requirements that are likely to affect the Penta phase-out process. First, facilities that switch to alternative wood preservatives that do not generate hazardous waste will be subject to modified hazardous waste requirements under RCRA. Under, 40 CFR 262.17(a)(8)(iii), generators of hazardous waste are allowed to defer closure of drip pads until facility closure. However, it is unclear whether this rule applies specifically to facilities that formerly used Penta. Industry stakeholders have expressed a need for clarification on this regulation. Second, it is unclear whether the proposed Penta registration cancellation will apply to the sale and installation of poles treated with Penta. Currently, a pole treated with Penta meets the definition of a treated article and is not subject to FIFRA regulations. Poles treated with Penta are often stored for long periods of time before sale or installation and are expected to last up to 70 years once in service. Therefore, the industry will need confirmation that Penta-treated poles are exempt from the registration cancellation in order to ensure that the change does not affect the sale and installation of Penta-treated poles after the phase-out period.Despite concerns, industry stakeholders have been in the know about the proposed Penta phase-out for several years and are, in many ways, well positioned for the transition. Some businesses have begun to manufacture alternative preservation chemicals such as copper naphthenate. Yet, the ease of the proposed transition will depend heavily upon continued cooperation and understanding between EPA and industry experts with in-depth knowledge of the manufacturing and market intricacies.To review the full ID and submit comments, visit https://www.regulations.gov/document/EPA-HQ-OPP-2015-0349-0015. Comments must be received on or before May 4, 2021.For more information on how EHS Support can help translate environmental challenges into business solutions for your organization, contact Monica Meyer.References / NotesComments on Proposed Interim Registration Review Decision for Pentachlorophenol (Docket ID No. EPA-HQ-OPP-2014-0653), Treated Wood Council, April 22, 2021Pentachlorophenol Proposed Interim Registration Review Decision, Case Number 2505, December 2020Pentachlorophenol is on its way out as a utility pole preservative. Here’s what might take its place. Chemical & Engineering News, April 12, 2021Penta’s Foggy Future for Industrial Wood Treaters, Building Products Digest/526 Media Group, May 6, 2020Let's block ads! (Why?)

We believe one small act can make a big impact.At EHS Support, we realize we can impact the world around us – as individuals and as a company, and quite simply, we want the world to be a better place because we acted. This year to celebrate Earth Day, we’ve planted seedlings in honor of our client partners and employees around the globe. We believe that it all starts with one small act.Let's block ads! (Why?)

The rest of 2021 is showcasing some significant changes for business leaders and their companies. The most recent action by President Biden was the nomination of Doug Parker of San Francisco to head the Occupational Safety and Health Administration (OSHA) as the Assistant Secretary.  Parker is currently the chief of California’s Division of Occupational Safety and Health (Cal/OHSA), a position he has held since 2019.  He served in the Obama Administration as Deputy Assistant Secretary for Policy in the Mine Safety and Health Administration (MSHA), was a member of the Biden-Harris transition team focused on worker health and safety issues, and was executive director of Worksafe, a legal services provider.  Parker’s nomination for assistant secretary requires Senate confirmation; however, no confirmation hearing is scheduled yet. Should Parker’s nomination become official, his policies will undoubtedly impact OSHA regulation as we will discuss in this article.COVID-19 Emergency Temporary StandardIn his tenure at Cal/OSHA, a hastily-issued COVID-19 emergency temporary standard (ETS) was aggressively enforced, using COVID-19 to engage employers in surveillance testing, which resulted in confusion on outbreaks, exposed workplaces, and notification obligations. While Parker may not have had an official role in issuing the ETS, the prediction is that one of Parker’s first focus areas will likely mesh with the Biden administration’s push for a federal ETS since the COVID-19 pandemic is still ongoing; therefore, employers should familiarize themselves with Cal/OSHA’s ETS requirements.Shift to Organized Labor UnionsBiden kicked off his campaign by vowing to be “the most pro-union president” and stated, “I’m going to be the strongest labor president you have ever had.” That campaign pledge has taken root.  The Labor Department transition team has more than two dozen union officials and labor activists, and with the recently confirmed Secretary of Labor Marty Walsh in office, you may see the pendulum swinging back towards the worker-centered policy we saw during the Obama administration. According to the latest Gallup Pole¹, workers are responding positively to increasing unionization with a 65% approval rate.Beef Up OSHA Enforcement Parker will also be tasked with overseeing and revitalizing enforcement efforts and will resurrect many Obama-era rules that were set aside and not heavily enforced during the Trump administration.  The Biden administration intends to double the number of OSHA compliance officers as a means of ensuring enforcement.  As you investigate how that may play out in your state, the area offices will be able to knock on more doors.  The timespan for compliance officers to be trained and begin conducting inspections is around 18 months.  Now is the time dust off and reinvigorate your internal or third-party audit process.  While the identification and elimination of workplace safety hazards is paramount, another focus is on compliance gaps as companies may have come up short in policy and procedure execution in 2020.National Emphasis ProgramOSHA’s National Emphasis Programs (NEPs) are temporary programs that focus OSHA’s resources on particular hazards and high-hazard industries.  The NEP includes a planned/programmed and follow-up inspection initiative that aims to increase workplace safety in primary and secondary target industries where employees have a high frequency of close contact exposures, such as manufacturing (wood product, paper, chemical, food and beverage, metal, plastics, and rubber product), warehousing and storage, healthcare, meat and poultry processing, construction, grocery, and restaurants; refer to NEPs lists of targeted industries. Please be aware that industries not included on the lists may be targeted for inspection as unplanned inspections if OSHA believes it is warranted based on COVID-19 fatality events or by allegations of potential or confirmed employee exposure to COVID-19.State PlansExpect federal OSHA to work side-by-side with State Plans to seek more vigorous enforcement. This could result in a demand to increase the State Plan’s penalties, a resurrection of the original electronic reporting rule adopted in 2017 (which will require certain employers to electronically post their OSHA 300 log data), and an enforcement of the 2016 OSHA Anti-Retaliation Rule pertaining to injury and illness reporting rules, safety incentive programs, and drug testing policies.How You Can Plan and PrepareAs the new OSHA front office takes shape and as personnel start reporting back from remote work, plan accordingly by analyzing risk, identifying and controlling hazards, and auditing the status of your company’s health and safety compliance and the implementation of policies and procedures.For more information on how you can properly prepare for these expected changes, contact Monica Meyer.¹https://news.gallup.com/poll/12751/labor-unions.aspxLet's block ads! (Why?)

Wastewater Surveillance Sampling for SARS-CoV-2 RNA –‘Testing’ the WatersBy: Laurel Seus, Remediation MicrobiologistAs the world continues to monitor COVID-19, the new application of wastewater stream analysis has provided an avenue for monitoring the patterns and trends of communities as we coordinate and evolve our response to the virus. Wastewater surveillance data are intended to complement other COVID-19 surveillance indicators that inform public health actions.Initiated by the Centers for Disease Control and Prevention (CDC), the Wastewater Surveillance Sampling Strategy allows wastewater streams from individual buildings, combined sewer lines, or wastewater treatment plants to be tested for the presence RNA (ribonucleic acid) from SARS-CoV-2 (the virus that causes COVID-19) to determine if anyone living or working in the area has an active COVID-19 infection. During this process, wastewater samples are concentrated, RNA is extracted, and RT-qPCR (reverse transcription-quantitative polymerase chain reaction) or RT-ddPCR (RT-droplet digital PCR) is used to detect and quantify SARS-CoV-2 RNA from a location.By using this technology, the CDC is able to provide COVID-19 infection surveillance without having to test every healthy individual on a regular basis regardless of illness symptoms. It may be especially valuable for communities with limited healthcare resources or transportation access where vaccines and testing are limited or not easily accessible.  For example, if the wastewater outflow from a nursing home tests positive for SARS-CoV-2 RNA but no residents or staff are symptomatic, quarantine measures can be emplaced until individuals can be tested. Most notably, wastewater surveillance can detect the virus before clinical symptoms and in asymptomatic infections.  This testing can also be valuable in the near future for reopening and safety of schools where, as of now, children under age 16 cannot receive the COVID-19 vaccine. Individual testing could then identify an asymptomatic or mild case that may have otherwise become an unknown source of infection within the facility.This approach to testing wastewater is a “lemons to lemonade” technology from microbiology in the time of COVID-19. It provides proof that environmental microbiology can extend far beyond the environmental sector – intersecting with clinical microbiology and public health. As we vaccinate the general population and the COVID-19 pandemic wanes, the disease will continue to circulate, testing will be less widespread, and the virus is unlikely to be totally eradicated. Wastewater monitoring can help public health officials evaluate the extent of community infections and trends over time as a metric in addition to testing individuals. This technology can be applied to broader wastewater samples, such as wastewater treatment plants or individual sewer lines, that can alert public health officials to an emerging outbreak or be used to monitor the baseline number of cases of the disease.If you’re interested in learning more, please contact one of EHS Support’s Subject Matter Experts: Laurel Seus, Remediation MicrobiologistWill Harms, In Situ Remediation Services PractitionerSource/Citation: https://www.cdc.gov/coronavirus/2019-ncov/cases-updates/wastewater-surveillance/developing-a-wastewater-surveillance-sampling-strategy.htmlLet's block ads! (Why?)

As expected, the change in Administration has initiated change within certain Federal agencies, including EPA and OSHA. Based on what we are seeing, 2021 will bring some dramatic shifts in EH&S regulatory impact, including:Increased regulatory inspections and reporting requirements. This will also accelerate as the US comes out of COVID.A rise in enforcement action is likely (almost assured)Particular focus of enforcement will be on Environmental Justice impacts of an operationEHS Support is working with clients in the Food and Beverage and Cannabis Industry to prepare for, and adapt to, these changes. There are proactive steps you can take to protect your interests. To contact our team of experts or to learn more, visit the full article.Let's block ads! (Why?)

By: Andrew Fowler, Ph.D., Senior GeologistQuantification of natural source zone depletion (NSZD) rates at remediation sites can play a key role in selecting an effective remediation strategy for a site. NSZD assessments typically focus on the vadose zone where over 90% of NSZD mass removal occurs1. Methods used to assess NSZD in the vadose zone include use of passive gas traps, dynamic closed chamber systems, gas gradient assessments of nested soil gas probes, or the biogenic heat method.Until recently, biogenic heat was considered a cost-effective method as it may be implemented in existing monitoring well networks using relatively inexpensive equipment2.The thermal conductivity (KT) of soil is a key factor used to calculate NSZD rates in the unsaturated zone using the biogenic heat method. Moisture has a profound effect on soil KT values by affecting the heat balance through heat loss by evaporation and radiation, and heat advection with moisture migration3. These effects are frequently overlooked or oftentimes assumed to be negligible in biogenic heat NSZD assessments. A study by Janssen, H., Carmeliet, J. and Hens, H., 2004, provides evidence that oversimplifying subsurface heat loss mechanisms may lead to underestimation of NSZD rates using the biogenic heat method3.The approach is unique because most assessments of heat loss to soil do not account for the coupling effects of between soil heat and soil moisture transfer are taken into account – and these effects are shown to be notable. Consequently, the approach of identifying factors that underestimate NSZD methods promoted in current guidance documents provides a strong case for the need of more flexibility related to the treatment of data in biogenic heat NSZD studies. Accounting for the factors that underestimate NSZD in biogenic heat programs may lead to long term cost savings by realizing earlier active remediation endpoints.What these findings may mean for your site:NSZD rates calculated by the biogenic heat method may be underestimated if variations in soil moisture are not considered.When assessing biogenic heat data, methods for determining thermal conductivity should account for soil moisture.Comparing in-situ soil thermal conductivity measurements using a hand-held device with default values is a nominal cost that in some instances, may prove to be a worthwhile investment.In summary, the use of biogenetic heat at specific sites could result in reduced time to reach remediation goals, cost decreases, and improvements to site schedules.To discuss NSZD and Biogenic Heat Methods in more detail, EHS Support’s team of subject matter experts are here to help:Andrew Fowler, Ph.D., Senior GeologistNigel Goulding, Chief Technical Officer, Co-Managing DirectorTom Silverman, Remediation Services Group LeaderSources:1 ITRC, 2018, Light non-aqueous phase liquids (LNAPL) document update, LNAPL-3, Interstate Technology & Regulatory Council, LNAPL Update Team, Washington, USA.2Sweeney, R.E. and Ririe, G.T. (2014). Temperature as a Tool to Evaluate Aerobic Biodegradation in Hydrocarbon Contaminated Soil. Groundwater Monitoring & Remediation 34(3).3Janssen, H., Carmeliet, J. and Hens, H., 2004. The influence of soil moisture transfer on building heat loss via the ground. Building and Environment, 39(7), pp.825-836.Illustration: https://lnapl-3.itrcweb.org/appendix-b-natural-source-zone-depletion-nszd-appendix/Let's block ads! (Why?)

By: Will Harms, Bioremediation Services PractitionerIn Situ Chemical Oxidation (ISCO) remedies for groundwater contamination has evolved into a mature industry. Yet, effective and lasting use of ISCO suffers from two basic problems: 1) short oxidant lifespans, and 2) poor mixing in the subsurface.Several years ago, novel downhole slow-release oxidant-infused paraffin wax ‘candles’ (similar to ordinary candles) emerged with the intention to overcome the common limitation of short-lived oxidants. However, slow-release oxidant candles did not always perform up to expectations because (drum roll please), you guessed it, insufficient mixing of dissolved oxidants into groundwater. One new method to improve performance of downhole slow-release oxidant-infused paraffin wax candles pairs well-known airlift recirculation wells with slow-release oxidant candles. The approach was commercialized by AirLift Environmental LLC . Results of their research and case studies is compelling enough for the National Institute of Environmental Health Sciences  to spotlight the coupled remedy in the recent Superfund Research Program Research Brief 315 dated March 4, 2021.This new method is important because it holds promise to improve performance of ISCO initiatives at much lower cost compared to most of the conventional approaches used to deliver oxidants.Sites that could most benefit from coupling downhole oxidant candles in airlift recirc wells are those that:Present low to moderate pollutant concentrations.Present low to very low groundwater velocities.Back-diffusion sources the contaminant plume.Are almost, but not quite, ready for a monitored natural attenuation component of a final remedy.Site stakeholders benefit from awareness of new remedy approaches like this one because it enables better remediation decision-making.Contact Will Harms and our team of experts to learn how EHS Support can help you navigate the latest remedy approaches that may be a candidate for effective and cost-effective use at your site.View a video by AirLift Environmental LLC can be found here.Let's block ads! (Why?)

Today the United States Environmental Protection Agency (EPA) announced that it has proposed cancelling the registration of the wood preservative pentachlorophenol, commonly known as Penta. Penta has been used at least as early as the 1930s and was first registered as a pesticide with EPA on December 1, 1950. Historically, Penta was a widely used biocide in the United States, but in 1987 uses of Penta as an herbicide, defoliant, mossicide, and disinfectant were removed from product labels. Penta is a restricted use pesticide that is mainly used for treating utility poles. Only pressure and thermal treatments of Penta are allowed under the current product registration. There are no manufacturers of Penta in the United States, and only one in North America. Alternatives to Penta used by utility pole manufacturers include creosote, creosote solutions, copper naphthenate and DCOI. EPA conducted a risk assessment and determined that Penta poses significant human health risks to workers, prompting its proposed cancellation.Through the Pesticide Registration Review program, EPA reviews all registered pesticides to ensure that each pesticide continues to satisfy the statutory standard for registration, that is, the pesticide can perform its intended function without unreasonable adverse effects on human health or the environment.  In addition to Penta, creosote and chromated arsenicals are other wood preservatives subject to re-registration this year, for which EPA has prepared preliminary interim decisions.EPA is accepting public comment on the proposed decision to cancel the registration for Penta for the next 60 days.To learn more visit: https://www.regulations.gov/document/EPA-HQ-OPP-2015-0349-0015Let's block ads! (Why?)