May 2019

EPA Draft Interim Recommendations for PFAS Contaminated Groundwater

US EPA (EPA) is seeking public comment on draft recommendations for cleanup of groundwater contaminated with perfluorooctanoic acid (PFOA) and/or perfluoroctane sulfonate (PFOS) under federal cleanup programs.  The draft guidance provides screening levels, preliminary remedial goals, and, in areas where groundwater is being used for drinking water, clean up levels. The guidance is poorly written and confusing, due in part to last minute wholesale changes. For states which have moved ahead with state-specific cleanup and drinking water standards, the recommendations will be viewed as too little too late, and for those states taking a wait and see approach…

The Dry Cleaner Dilemma

There are, or have been, thousands of small commercial dry cleaning operations throughout the U.S. – nearly every neighborhood had one. Most of them are or were small, family owned businesses that started in the 30s, 40s, or 50s. Many of these facilities became ‘anchor’ stores of small shopping centers that are now being redeveloped. The first step in the redevelopment process should be the Phase I Environmental Site Assessment. However, many times this essential first step is requested after the deals are well along their way. As an environmental professional, we find ourselves fielding calls that begin with “We’re closing next week and need a Phase I done.” What could go wrong…

PFAS – Can it be Treated?

PFAS is quickly becoming the hottest topic in the environmental field. With these emerging contaminants headed toward increased regulation, questions regarding treatability are at the forefront. PFAS have oil and water repellency, temperature resistance, friction reduction properties, and one of the strongest bonds in nature. These properties all contribute to significant challenges in the treatment of PFAS in environmental media. For a brief overview of PFAS treatability with respect to commonly employed technologies for soil and groundwater….

Ohio EPA VAP Rules to be Updated

Ohio EPA is in the process of performing their scheduled 5-year review of the Voluntary Action Program (VAP) rules. The draft rules are available for Interested Party Review, with comments due by close of business, May 29, 2019. The majority of changes are to clean up language and make them more readable, although there are other notable changes that emphasize the importance of understanding institutional controls at VAP properties.

Applicability of the 2015 Waters of the US in Ohio

On May 2, 2019, Chief Judge Edmund A. Sargus of the U.S. District Court for the Southern District of Ohio rejected a request from the states of Ohio and Tennessee to block enforcement of the 2015 Clean Water Act (CWA) in those states. In his order, Judge Sargus declined to reconsider his denial of their motion to block the implementation of the 2015 Waters of the United States. As a result, the 2015 rule remains in effect in Ohio and Tennessee, along with twenty-two other states. This will remain in effect until the U.S. EPA rescinds or replaces the 2015 rule, or until additional court rulings deem otherwise.

Updated Map Tracks PFAS Contamination in the U.S.

On May 6, 2019, the Environmental Working Group and the Social Science Environmental Health Research Institute at Northeastern University released the latest update of their interactive map documenting the publicly known contamination from PFAS chemicals in the United States. One take away regarding the apparent distribution of PFAS contaminated sites is that the more you sample, the more you find.

US EPA Updates Regional Screening Levels (RSLs)

US EPA updates their Regional Screening Levels (RSLs) every six months, typically in May and November. On May 16, 2019, US EPA released their most recent revision (available here). The RSLs form the basis for screening and cleanup standards on many RCRA and CERCLA sites, and are frequently used by other programs. The May 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.

Cox-Colvin & Associates, Inc.

Project Spotlight

Coming Soon in the June Newsletter

  • More on PFAS
  • EPA’s recent review of the management of wastes generated during oil and natural gas exploration, development, and production
  • Just how permanent are your environmental documents

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.

June 10-12, 2019: AIPG Michigan Environmental Risk Management Workshop

July 2-4, 2019: AESAS Conference in Sao Paulo, Brazil. 

July 2, 2019: Poster Presentation by Craig Cox – Why the Historical VOC Production Trends Necessitate the Use of High-Resolution Site Characterization Techniques – Proven Methods to Access Vapor Intrusion Potential and Better Define the Conceptual Site Model

July 4, 2019, 10:30AM: Vapor Intrusion Section C36: Craig Cox will be presenting The Importance of Sanitary Sewers as the Expected Preferential Pathway in Vapor Intrusion Evaluations  

July 4, 2019, 14:00 pm: Vapor Intrusion Section C40: Laurie Chilcote will be presenting Proven Methods to Access Vapor Intrusion Potential and Better Define the Conceptual Site Model

July 4, 2019: Poster Presentation by Laurie Chilcote Proven Methods to Access Vapor Intrusion Potential and Better Define the Conceptual Site Model

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