July 2019

Ohio EPA Significantly Revises Vapor Intrusion Guidance

Ohio EPA is in the process of updating its vapor intrusion guidance. Except for the 2016 withdrawal of several chapters of the guidance (mostly dealing with the use of the J&E model), this is the first major revision since the document was released in 2010. Ohio EPA requested comments on the significantly revised draft final version (June 2019) of the guidance, with the comment period ending June 15. For a summary of the most significant changes to the guidance, read more….

They Call them Emerging Contaminants for a Reason

PFAS contamination is driving a nationwide environmental crisis that has left us playing catch up as we struggle to characterize the potential threat this seemingly ever-expanding class of chemicals pose to human health and the environment. With the federal government lagging-behind in the establishment of drinking water and cleanup standards, states are developing their own policies to regulate these chemicals. Commercial laboratories faced with similar challenges in developing their own accredited methods for PFAS analysis of non-drinking water matrices, while environmental consultants test and develop appropriate sampling protocol. As we strive to understand and interpret concentrations in the part-per-trillion range, some basic, common sense QA/QC can go a long way.  

EPA Evaluation Concludes Revisions to Federal Solid Waste Management Regulations of Oil and Gas Waste Not Necessary

In response to a 2019 law suite, EPA recently completed an evaluation of the need to revise its federal nonhazardous solid waste regulations for wastes associated with the exploration, development and production of crude oil, natural gas, and geothermal energy. The lawsuit was driven in part by the significant advancements in the production of crude oil and natural gas from hydraulic fracturing and directional drilling used to access black shale, tight oil and other “unconventional” formations. These advancements and the volume of wastes currently generated were not fully envisioned in 1988 when EPA issued a regulatory determination exempting this type of waste from the hazardous waste regulations. On April 26, 2019, EPA released the results of its required review, and concluded…read more.

Cox-Colvin Now Offering Asbestos Sampling and Air Monitoring Services

Cox-Colvin’s Evan Cox was recently certified by Ohio EPA as an Asbestos Hazard Evaluation Specialist. The National Emissions Standards for Hazardous Air Pollutants (NESHAP), requires an asbestos survey to be conducted prior to renovation and/or demolition of a structure. Asbestos surveys are also conducted as part of environmental site assessments. As an aside, the common misconception around asbestos is that a building constructed after promulgation of the Clean Air Act in 1973 will not contain asbestos and all building material is asbestos-free. This is simply not true. While asbestos manufacturing in the US has largely ended, products are still imported from abroad for use in the United States. For example, drywall generally doesn’t contain asbestos, however, drywall joint compound from abroad sometimes contains asbestos. Furthermore, when the asbestos “bans” were enacted, companies using asbestos were permitted to continue using surplus asbestos containing material until depleted. Therefore, facility construction or renovation date is not always a fair indication of the presence or absence of asbestos.

With this certification, Cox-Colvin & Associates can assist our clients and others with asbestos building inspections, asbestos bulk sampling, air monitoring, and preparation of asbestos management plans. Cox-Colvin & Associates is an ISN and Avetta certified contractor and we are excited to provide these new services alongside the core Cox-Colvin & Associates’ groundwater, soil, air, and vapor intrusion related services.

Please feel free to contact Evan directly at (Evan_cox@coxcolvin.com), for help with a project or general questions.

What Does Method TO-15 Really Mean?

EPA Method TO-15 is often used when conducting air sampling or vapor intrusion investigations and is familiar to many in the environmental field. However, many do not realize that the compounds reported for the “standard TO-15 analysis” varies between laboratories. Interested parties need to ask themselves: What does Method TO-15 really mean?

Ohio EPA Solid Waste Rule-Making Updates

Recently, the Ohio EPA released Interested Party versions of some solid waste rules as part of the required five-year rule review process. Most notably, this includes changes to Rule 3745-27-13, or what is commonly known as “Rule 13’. Rule 13 concerns the filling, grading, excavating, building, drilling or mining on property where a solid or hazardous waste landfill has been operated.

The Ohio EPA has also proposed changes to several of the other municipal solid waste rules. Most of those changes are minor, but there are changes to Rule 3745-27-08, “Sanitary Landfill Facility Construction”, as well as a few key changes to a few other rules. For more information on the proposed changes, please read on. 

Helping with Dayton Tornado Relief

On the night of May 27, 2019, Dayton-area counties in Ohio were devastated by a local record-breaking tornado outbreak that continued through the early morning hours on May 28. The National Weather Service confirmed eighteen touchdowns, including an EF4 tornado in Montgomery County with winds reaching an estimated maximum of 170 mph. Several other strong EF3 and EF2 tornadoes were confirmed throughout the surrounding counties. The storms destroyed numerous buildings and brought down countless trees, many in highly populated areas. 

To assist in the cleanup, Cox-Colvin’s staff supported the relief efforts in cutting and moving trees, setting up emergency supply stations, removing debris from roadways, and participating in other tasks to help where needed. Cox-Colvin & Associates has worked at numerous sites in and around the Dayton-area, and some of our staff have roots there as well. As a company with ties to the area, we were happy to lend a helping hand.  

Cox-Colvin & Associates, Inc.

Project Spotlight

Coming Soon in the August Newsletter

  • More on PFAS
  • EPA 2020-2023 enforcement priorities
  • 2019 Spring Federal Regulatory Agenda
  • The dry cleaner dilemma, Part 2
  • Enhancing effective State/Federal Enforcement

Upcoming Events

Cox-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.

July 24, 2019, 2:45pm-4:15pm: Nick Petruzzi presents Best Practices for Navigating RCRA Permit and Variance Requirements Under the New Definition of Solid Waste at the 29th Annual Conference on Air, RCRA & Water Permits , Environmental Permitting in Ohio

August 1-2, 2019: Craig Cox and Laurie Chilcote will be presenting at the International Workshops on Soil Remediation in Buenos Aires, Argentina.

September 9-11, 2019: AARST International Radon Symposium and Trade Show in Denver, Colorado

September 18-20, 2019, 16:55: Craig A. Cox, CPG will be presenting The Importance of Sanitary Sewers as the Expected Preferential Pathway in Vapor Intrusion Evaluations. Also, stop by our booth and see Craig Cox and Laurie Chilcote at the RemTech Europe Conference in Ferrara, Italy.