December 2019

Ohio PFAS Action Plan for Drinking Water

On December 2, 2019, the Ohio EPA and Ohio Department of Health (ODH) released the Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water. The stated focus of the action plan is to evaluate the potential risk of PFAS in both public and private drinking water systems in Ohio and assist communities in addressing these risks. To this end, the action plan lists six objectives and the proposed strategies for achieving those objectives.

US EPA Updates RSLs and Introduces App

US EPA (EPA) updates their Regional Screening Levels (RSLs) every six months, typically in May and November. On November 18, 2019, US EPA released their most recent revisionThe RSLs form the basis for screening and cleanup standards on many RCRA and CERCLA sites and are frequently used by other programs. The November 2019 changes are generally minor, and not anticipated to dramatically affect the majority of Cox-Colvin’s clients. To see exactly what this update included, see the “What’s New” link on the RSLs homepage.

Along with their November 2019 update to RSLs, EPA announced their new RSL/RML app available for free download in the Google Play Store and Apple Store (simply search for EPA RSL). Cox-Colvin has tested the Android version of their app. It is a simple app that allows searching for RSLs without needing to fumble through the extra toxicity and other data found on the RSL spreadsheets or the web-based RSL calculator. Despite the simplicity, it is difficult to envision how often an environmental professional would need to access this information from a mobile phone outside of the office. Perhaps now you’ll be able to settle those holiday dinner disputes over soil standards for decabromodiphenyl ether, 2,2′,3,3′,4,4′,5,5′,6,6′- (BDE-209) without leaving the table. Or you can simply call Cox-Colvin the next morning and we’d be happy to help.

Ohio EPA Proposed Industrial/Residual Solid Waste Rule Changes

On December 6, 2019, the Ohio EPA released an Interested Party draft of the changes to the industrial solid waste (ISW) and residual solid waste (RSW) rules. The rules package proposes to rescind Rule 3745-29, the ISW rules, altogether and incorporate those requirements into Rule 3745-30, the RSW rules. These two sets of rules were very similar, so combining them makes sense. The proposed changes to the RSW rules include language to merge the rules, changes to financial assurance requirements, construction specifications, and to some of the groundwater monitoring parameter lists, amongst others.

Ten Most Frequently Cited OSHA Workplace Violations for FY 2019

In September 2019, OSHA announced its preliminary list of 10 most frequently cited workplace safety violations for fiscal year 2019. Speaking at the National Safety Council 2019 Congress & Expo in San Diego, OSHA identified the following “Top Ten”

1.  Fall Protection – General Requirements

2.  Hazard Communication

3.  Scaffolding

4.  Lockout/Tagout

5.  Respirator Protection

6.  Ladders

7.  Powered Industrial Trucks

8.  Fall Protection – Training Requirements

9.  Machine Guarding

10.  Personal Protective and Lifesaving – Eyes and Face Protection

Fall protection tops the list for the ninth straight year in a row. Although there is not much change in the list from year to year, it is useful to revisit the list occasionally as a reminder. The OSHA presentation can be viewed at Safety+Health Magazine website.

EPA Updates its Small Business Guide to Managing Hazardous Waste to Include the Generator Improvement Rule

US EPA (EPA) recently updated its small business guide to managing hazardous waste. The handbook provides an overview of the federal hazardous waste regulations and is designed to give small business owners and operators a basic understanding of their hazardous waste management responsibilities at the federal level. The guide has been updated to reflect recent federal rulemakings including, most notably, the 2016 Generator Improvement Rule. 

This EPA handbook covers only the federal requirements for hazardous waste management. Most implementing agencies (e.g., states) have their own hazardous waste regulations based on the federal hazardous waste regulations. Some use the federal requirements and definitions; others have developed more stringent requirements. If the latter is true for your implementing agency, you must comply with those more stringent regulations. In some cases, some of the regulations covered in the handbook have not been adopted by all states at this time. Ohio, for instance, is just now in the process of adopting the Generator Improvement Rules and on December 4, 2019 released draft rules for interested party review. In addition to the Generator Improvement Rule, the proposed Ohio EPA hazardous waste rule set includes disposal of coal combustion residuals from electric utilities, imports and exports of hazardous waste, E-manifests, and management standards for hazardous waste pharmaceuticals, among others. The Ohio EPA fact sheet, business impact analysis (BIA) form, and the draft rules are on the Division of Environmental Response and Revitalization website. Comments on the Ohio EPA hazardous waste rule-making must be received by January 20, 2020. Final rules could be adopted in Spring of 2020.

Cox-Colvin & Associates, Inc.

Project Spotlight

Coming Soon in the January 2020 Newsletter

  • Pump-and-Treat – Using Old Technology to Tackle Emerging Contaminants
  • Inspecting Monitor Wells

Upcoming Events

Colvin & Associates, Inc. personnel are actively involved in the technical and regulatory aspects of the environmental field as it evolves. Cox-Colvin will be participating as presenters, sponsors, or exhibitors at the following environmental conferences in the coming months.

February 4-5, 2020: Craig A. Cox will be presenting “The Importance of Sanitary Sewers as the Expected Preferential Vapor Intrusion Evaluations”The New Jersey Site Remediation Conference (NJSRC), Brunswick, NJ.

February 4-5, 2020: Laurie A. Chilcote will be presenting “Proven Active Soil Gas Sampling Techniques for Efficient Site Characterization, Vapor Intrusion Investigation and Mitigation“, The New Jersey Site Remediation Conference (NJSRC), Brunswick, NJ

March 19, 2020: Vapor Intrusion III Session Craig Cox will be presenting The Importance of Sanitary Sewers as the Expected Preferential Vapor Intrusion Evaluations”, 30th Annual International Conference on Soil, Water, Energy, and Air, San Diego, CA.

March 26-27, 2020:Cox-Colvin & Associates, Inc., will be exhibiting at the 35th Annual Environment, Energy and Resources Law Institute at the Nationwide Conference Center in Lewis Center, Ohio

March 31-April 2, 2020:  Craig A. Cox and Laurie A. Chilcote will be presenting at EnviroWorkshops – Vapor Intrusion Workshops.

Workshops are scheduled in:

  • Pittsburgh, PA – Tuesday, March 31st
  • Cincinnati, OH – Wednesday, April 1st
  • Indianapolis, IN – Thursday, April 2nd

May 31-June 4, 2020: Session G10 Nate Wanner will be presenting “Evaluating the Potential for Mercury Vapor Intrusion“, The Twelfth International Conference on Remediation of Chlorinated and Recalcitrant Compounds, at the Oregon Convention Center in Portland, Oregon.

May 31-June 4, 2020: Session G11, Poster Group 2, Craig A. Cox will be presenting “The Importance of Sanitary Sewers as the Expected Preferential Vapor Intrusion Evaluations”The Twelfth International Conference on Remediation of Chlorinated and Recalcitrant Compounds, at the Oregon Convention Center in Portland, Oregon.

May 31-June 4, 2020: Session G11 Nate Wanner will be presenting “Where’d That Come From? Differentiating Soil Gas, Sewer Gas, and Outdoor Air in Vapor Intrusion”The Twelfth International Conference on Remediation of Chlorinated and Recalcitrant Compounds, at the Oregon Convention Center in Portland, Oregon.

June 1, 2020: Learning Lab 3:05-3:30 pm Laurie Chilcote and Craig Cox will be presenting “Proven Active Soil Gas Sampling Techniques for Efficient Site Characterization, Vapor Intrusion Investigation and Mitigation“, The Twelfth International Conference on Remediation of Chlorinated and Recalcitrant Compounds, at the Oregon Convention Center in Portland, Oregon.