March 2020

A Word About COVID-19

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Cox-Colvin & Associates, Inc.

Like each of you, we have been closely monitoring the rapidly changing COVID-19 pandemic. On March 19, 2020, the Cybersecurity and Infrastructure Security Agency (CISA) issued its “Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response.” By virtue of this memo and our support of CISA-identified critical infrastructure sectors such as the Chemical, Critical Manufacturing, Energy, and Water and Wastewater Systems Sectors, Cox-Colvin & Associates, Inc. staff are considered Critical Infrastructure Workers. We take this designation seriously and are committed to assisting our clients and the nation in this difficult time. We are equally committed to doing our part to slow or stop the spread of COVID-19 and protect the health of our employees, their families, our clients and colleagues, and the communities we live in. We have instituted the recommended precautions and protocols issued by the CDC, WHO, and state and local government officials but otherwise our operations are continuing, including field work. We are still here to support you, so don’t hesitate to contact us by email or phone at 614-526-2040 anytime.

Pump-and-Treat – Can’t Live With it, Can’t Live Without it

Few, if any, remediation technologies are as scorned and maligned as pump and treat (P&T). Detractors are quick to dismiss it as antiquated and inefficient, pointing to the many failed applications, missed cleanup objectives and high operation and maintenance costs. Although there is no shortage of examples to support these criticisms, they are more attributable to either the improper application of the technology or the poor design and operation of the system. Yet despite all of the short comings, P&T remains the most commonly utilized groundwater remediation technology. This fact, combined with the emergence of 1,4-dioxane and per- and polyfluoroalkyl substances (PFAS) in groundwater which are challenging, if not impossible, to treat in-situ, ensure that P&T technology is here to stay. With that in mind, its time to take a fresh look at this technology and the benefits of actively managing P&T operations to improve efficiency and reduce costs.  

U.S. EPA Releases NPDES 2020 Draft Industrial Stormwater Permit for Public Comment

On March 2, 2020, U.S. EPA released for public comment the draft 2020 National Pollutant Discharge Elimination System (NPDES) general permit for stormwater discharges associated with industrial activity, also referred to as the Multi-Sector General Permit (MSGP). Some of the proposed revisions streamline the ability to interpret and comply with the permit, while others will likely increase both the level of effort and costs to maintain permit compliance. Although the proposed permit has near-term implications for industrial facilities where U.S. EPA is the NPDES permitting authority, many NPDES-delegated states (including Ohio) mirror the federal permit language when updating their state permit. Therefore, you can expect significant changes to many state-authored MSGPs in the coming years. 

End of Post-Closure Care at Solid Waste Landfills

For years, owners/operators of solid waste landfills in Ohio were under the false impression that after thirty years of post-closure care and maintaining financial assurance, they could just stop. Several years ago, when the 30-year periods for early landfill closures were approaching, Ohio EPA began informing the owners/operators that this was a misconception, and that they could not just stop post-closure activities; owners/operators had to demonstrate that their landfills no longer posed a threat to human health and the environment prior to ending post-closure care. Until recently, the process of doing that was not well defined. On February 28, 2020, the Ohio EPA released guidance regarding the process for ending post-closure care at solid waste landfills.

FY 2019 EPA Enforcement Results Spotlight an Increase in Voluntary Self-Disclosed Violations

On February 13, 2019, U.S. EPA (EPA) released its annual enforcement and compliance results for fiscal year (FY) 2019. The report shows continued decreases in inspections and cleanup commitments, while the number of self-audits increased in 2019. Given likely budget cuts to EPA, and a continued focus on “informal” compliance, this trend seems likely to continue.

Ohio EPA Issues Final Vapor Intrusion Guidance

Cox-Colvin & Associates personnel routinely provide vapor intrusion (VI) training to regulators, attorneys, environmental professionals, and the regulated community; and have helped in the development of VI guidance within the US and throughout Latin America and Europe. As a result, we have had the opportunity to review a large number of VI guidance documents over the years. 

On March 10, 2020, Ohio EPA released a final version of its updated “Sample Collection and Evaluation of Vapor Intrusion to Indoor Air for Remedial Response and Voluntary Action Programs” (Ohio EPA VI Guidance or Guidance). In our opinion, Ohio EPA, with input from a variety of experienced stakeholders, have crafted a very comprehensive yet flexible approach to the assessment and mitigation of VI sites within Ohio. Even though the Guidance is by nature Ohio-centric, the approaches, processes, and documentation presented in the document could be helpful to anyone conducting VI assessments.    

Cox-Colvin & Associates, Inc.

Project Spotlight

Coming Soon in the April 2020 Newsletter

  • Benefits of video inspections of monitor wells
  • The latest on PFAS

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.

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.