Joseph Dinan heads the SCS Engineers new office at 101 Arch Street, Boston, MA 02110,
Tel: 857-444-6302
SCS Engineers opened a new office in Boston’s Downtown Crossing district. The new location is more convenient for clients and enhances support to the firm’s growing client base in New England.
Joseph Dinan, an accomplished project manager and senior scientist heads Boston’s SCS team. Dinan has an excellent record meeting regulatory compliance and accountability for his clients to efficiently permit projects, keep them on budget and maintain the redevelopment schedule while meeting all environmental guidance. His background includes applied sciences including chemistry, microbiology, and environmental and soil sciences. Dinan has successfully managed hundreds of environmental assessment and remediation projects, both domestically and internationally.
Dinan’s Boston team resolves complex environmental challenges through the application of comprehensive analytical skills and technologies. Approaching each project with decades of expertise, mitigating the financial risk through careful assessment, analysis, and planning protects clients and the environment during all phases of redevelopment.
The Boston location supports the growing demand for environmental scientists, engineers, and consultants. SCS professional staff specializes in meeting federal, state, and local clean air, water, and soil goals, and the restoration of property once thought impractical to revitalize. The firm also provides vapor intrusion systems for protecting existing properties and a range of comprehensive environmental services for public and private entities.
As with most established urban environments, many properties may have previously been industrial or mass transportation sites, which often means that extra care is taken during redevelopment. Commercial real estate transactions must take environmental issues into consideration. Complex laws can impose significant environmental liabilities on purchasers, sellers, and lenders, whether or not they caused the problem, and whether or not they still own the property.
Important rules published by the U.S. Environmental Protection Agency – USEPA and in Massachusetts and other states offer defenses against environmental liabilities provided that the defendant conducted “all appropriate inquiries” regarding the property at the time of the acquisition, and then took reasonable steps to mitigate the effects of hazardous substances found on the property.
For more information, case studies, events, and articles visit these pages:
The Department of Toxic Substances Control (DTSC), State Water Resources Control Board, and San Francisco Bay Regional Water Quality Control Board have developed supplemental vapor intrusion guidance for conducting vapor intrusion evaluations in California. The Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion is available for review and public comment until 12:00 noon, April 30, 2020. Click here for available public meetings and comments.
According to the published Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion Executive Summary
Background
Toxic vapors can move from contaminated groundwater and soil to indoor air. This process is called vapor intrusion. Vapors inside buildings can threaten human health. The science behind vapor intrusion has been evolving quickly. To protect the health of Californians, the DTSC and the California Water Boards drafted a supplement to the existing vapor intrusion guidance. This is important information to collect for environmental protection. This document is called the “Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion” (Draft Guidance). This Draft Guidance contains recommended improvements for vapor intrusion investigations and promotes consistency throughout the state. It also offers suggestions on the following topics:
The Draft Guidance is intended to be used with existing State guidance – DTSC 2011 Vapor Intrusion Guidance and San Francisco Bay Regional Water Board 2014 Interim Framework 1 – when there is a spill or disposal of vapor-forming chemicals. This guidance does not apply to any leaking petroleum underground storage tanks (USTs) since they are governed under the State Water Resources Control Board’s Low-Threat UST Case Closure Policy.
Four Steps to Evaluate Vapor Intrusion
The Draft Guidance describes four recommended steps to decide if there is vapor intrusion that could pose a risk to the health of people inside buildings. These actions are meant to protect public health and should be carried out under the oversight of the lead regulatory agency.
Step 1 – Decide which buildings should be tested first and how.
When there are several buildings, start with those that are occupied and closest to the contamination. If a building is directly above or very close to the spill, or if it is likely that the sewer could bring toxic vapors inside, skip Step 2 and go directly to Step 3.
Step 2 – Screen buildings from outside.
Measure vapor-forming chemicals underground at these locations:
Step 3 – Test indoor air.
Measure vapor-forming chemicals in indoor air, beneath the building’s foundation, and outdoor air at the same time:
Step 4 – Act to protect public health.
Toxic Vapors Can Travel Through Sewer Pipes
Vapor-forming chemicals can enter sewer pipes that run through contaminated soil or groundwater. Once inside a sewer, vapors can move through the pipes and escape through cracks or openings, under or inside a building. Some of the traditional ways to test for vapor intrusion could potentially miss vapor-forming chemicals moving through sewer pipes. This Draft Guidance recommends evaluating whether the sewer could bring toxic vapors inside.
Vapor Intrusion Attenuation Factors
Attenuation factors are used to estimate how much of the vapors underground or in groundwater end up in the indoor air. This Draft Guidance uses attenuation factors recommended by the U.S. Environmental Protection Agency. These were calculated from a large study of buildings at contaminated sites around the nation, including California.
California Vapor Intrusion Database
Data from sites evaluated using the process described in the Draft Guidance will be entered into a database that will be publicly available. The State Water Resources Control Board (State Water Board) added capabilities to the GeoTracker database including building-specific information for a cleanup case and the ability to differentiate Field Points for collecting samples. The State will analyze the information in the database and learn how to better protect the people of California from vapor intrusion.
Where to Find the Draft Guidance
The environmental reporting season is just around the corner. Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.
Table: environmental regulatory agencies in Illinois, Indiana, and Wisconsin
The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry. Contact us at or find a professional like Ann, nearest you.
Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Thanks, Ann!
The staff at SCS Engineers (SCS) has talked at length about how changing the parameters of a coal ash remediation project impacts the eventual outcome of that project. That involves not only the factors present at a particular site but also the regulatory environment in which that site operates, certainly as rules evolve regarding the disposal of coal combustion residuals (CCRs).
Two primary means of coal ash remediation are closure-in-place, or cap-in-place, of an existing coal ash storage site, and closure-by-removal. Closure-in-place involves dewatering the storage site, or impoundment, in effect converting from wet storage to dry storage of ash. A cover system is then used to prevent more water from entering the site.
Closure-by-removal involves dewatering of the coal ash, and then excavating it, and transporting it to a lined landfill or a recycling center.
“There are lots of technical reasons and site-specific factors that can influence a project’s outcome,” said Eric Nelson, vice president of SCS and an experienced engineer and hydrogeologist. “These might include the type and volume of CCR, the geologic setting [e.g., groundwater separation], presence and proximity of receptors [e.g., drinking water supply], and physical setting [e.g., constraints such as access, available space onsite for re-disposal, proximity/availability of offsite re-disposal airspace, etc.].”
Sherren Clark, an SCS team member with experience in civil engineering and environmental science, said “risk evaluation is a key component of remedy selection. A CCR unit undergoing an assessment of corrective measures [ACM] could be a 100-acre ash impoundment containing 30 feet of fly ash, but it also could be a 2-acre bottom ash pond. It could have numerous groundwater constituents exceeding drinking water standards by a significant margin, or it could have a single parameter slightly above the limit at a single well. And there could be water supply wells nearby in the same aquifer, or none for miles around. All of these factors play into the selection of a remedy that addresses the existing risks, without creating other negative impacts such as site disturbance, dust, or truck traffic.”
Tom Karwoski, a hydrogeologist and project manager for SCS who has designed and managed investigations and remediations at landfills as well as industrial, Superfund, and other waste storage sites, noted the challenges inherent to individual sites and stressed careful planning is needed to achieve the desired result. At some sites, “given the size and the nature of the impoundments, transport of CCR off-site may not be the best option.” When moving from the ACM to the remedy [selection], it’s extremely important to have multiple meetings with the client to set the schedule. Based on the way the [CCR] rule is written, things have to progress logically. There’s time available for careful planning. The last thing we want to do is start making assumptions without input from the client and other interested parties. Regulatory compliance and concern for the surrounding community and the environment are important to us and our clients.
“If the nature of the site in its current condition allows it, capping of the site will reduce surface water moving through the waste and significantly cut down on the risk of groundwater contamination,” Karwoski said. “At sites where you have CCRs that may be distributed across a site, to consolidate that onsite and then the cap will address CCRs impacting groundwater.”
Jennifer Robb, vice president and project director with SCS’s Solid Waste Services Division, and the company’s Groundwater Technical Advisor for the Mid-Atlantic region said her group has “done corrective measures for cobalt, arsenic, and thallium,” all contaminants found in coal ash. “There are some in situ bio-remediation that can be done, where basically you’re trying to alter the chemistry to immobilize the metal.” Jennifer noted that there are also more physical remedies where contaminated groundwater is extracted from the subsurface by pumping or the groundwater plume is contained or treated in-situ with the construction of “cut off trenches.”
Karwoski said, “we have no preconceived notions about what is best for all sites, but if you consolidate [waste] onsite and then cap, it will certainly take care of a lot of situations where you have CCRs impacting downgradient groundwater.” This approach may not be appropriate in every situation, but, if arrived at after thoughtfully navigating the remedy selection process defined in the current Federal CCR rules (40 CFR 257 Subpart D—Standards for the Disposal of Coal Combustion Residuals in Landfills and Surface Impoundments), should result in an approach that is effective based on the site-specific factors present.
Read last month’s blog “Many Factors Influence Remedies for CCR Control and Disposal.”
California leads the way in the United States with a GHG MRP and C&T program that continues to grow and link with other jurisdictions. The California Air Resources Board (CARB) Market Readiness Proposal initially started with basic facility reporting and has grown and adopted to include multiple non-facility specific sectors of the economy, as dictated by the growing initiatives and programs that CARB joins or creates. However, as the program applicability may change, the basics tenants of MRP stay the same with reporting and verification at the center of the program.
By having CARB’s C&T Program as a separate program, entities have to navigate if they have a compliance obligation and how they will meet that obligation in addition to complying with reporting requirements. Entities can reduce their emissions by switching to biomass-derived fuels or meeting their compliance obligation by using CARB-provided allowances or purchasing allowances and/or compliance offset credits.
As CARB’s programs grow, it will likely trigger similar growth in the western North American GHG programs and regional agreements. As discussed, Québec’s C&T system, which is linked with CARB’s program, has been growing and is being used to meet the Canadian federal GHG rules that are being put in place. Ontario’s program was annulled but shows that the discussion on how best to reduce GHG emission is a topic that continues to thrive, and we may see new programs developing even though some may hit some setbacks. The PCC shows that even if a Market Readiness Proposal and C&T Program is not the particular method chosen by a region to reduce emissions, many regions still see reducing GHG emissions as the future to create jobs, develop the economy, develop new infrastructure and maintain growth while protecting the environment.
About the Authors:
Cassandra Drotman Farrant is experienced in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. She has participated in GHG verification projects throughout the U.S.
Raymond H. Huff is SCS Engineers’ National Expert on Greenhouse Gas. He specializes in landfill regulatory compliance; air quality/compliance issues, including GHG emissions quantification; and site assessment, remediation, and post-closure care.
Haley DeLong is experienced in greenhouse gas (GHG) emissions, sustainable energy, and climate dynamics. She specializes in air quality consulting and has been involved in numerous projects related to air permitting and compliance with solid waste regulations, including preparing Title V and Non-Title V permit-to-construct/operate permit applications.
Do Tracer Environmental professionals ever slow down? The SCS Tracer professionals at SCS Engineers were busy publishing new articles last month in addition to Operator Training. We’ve compiled several of them along with the most popular in our SCS library for your convenience. Select a title and start reading. Enjoy!
How to Properly Complete an IIAR 6 System Safety Inspection Checklist Form? When filling out the ANSI/IIAR 6-2019 Ammonia Refrigeration Safety Inspection Checklists, located in appendix B, some of the information required may not always be readily accessible. This comprehensive article takes readers step-by-step through the process.
Epic Fails, Part Deux Failures that come together, form a picture. The author discusses how we can begin to learn from these Epic Fails and start to take steps to prevent them in our plants.
Ammonia Pipe and Equipment Labeling – Part I Recognized and Generally Accepted Good Engineering Practices (RAGEGEP), an overview of many of the standards and guidelines that are relevant to the ammonia refrigeration system labeling, and guidance on how to apply them.
Ammonia Pipe and Equipment Labeling – Part II Options facilities have when choosing their RAGAGEP for pipe and equipment labeling.
It’s All in Your Past, RETA Breeze Investing in the knowledge and development of your personnel is the first step towards making your management system world-class in the safe operation and maintenance of your ammonia refrigeration system.
Employee Training Under PSM/RMP FAQs about designing a training program that is part of your facility’s PSM and RMP programs and provides a defensible position during inspections while ensuring that your facility operators and maintainers perform their jobs safely.
Mechanical Integrity, Documentation Discrepancies Checks, and verification prevent big problems.
Managing Organizational Change: How it Impacts Your Ammonia Refrigeration System During periods of organizational change, we must keep in mind the potential impacts on our facility’s PSM/RMP or ARM programs, and on the operation of the ammonia refrigeration system itself.
PSM/RMP Compliance Audits: Who Should Perform Them? What to look for in an auditor for hire? For starters, more than a consultant familiar with PSM/RMP regulations.
Management of Change: Have We Captured All of the Impacts of a Change? It is vital to ask as many questions as possible regarding equipment changes under consideration. With more information, you may find that the proposed changes could impact safety.
The U.S. Environmental Protection Agency (EPA) has identified 1, 2, 3 – Trichloropropane (TCP), which does not occur naturally in the environment, as an emerging chemical of concern that can threaten drinking water supplies. It states that TCP is a persistent pollutant in groundwater and has classified it as “likely to be carcinogenic to humans.” California State Water Board member Steven Moore called TCP an “insidious chemical” because it persists in the environment, sinks in water and is harmful in even tiny doses. Currently, there is no federal maximum contamination level (MCL) for TCP; however, there is a federal non-enforceable health-based screening level of 0.00075 ug/L.
Since 2012, TCP has been on the emerging Contaminant Candidate List (CCL), which is a watch list of unregulated contaminants that are known to, or anticipated to, occur in public water systems and may require regulation under the Safe Drinking Water Act (SDWA). The EPA has required, under the Unregulated Contaminant Monitoring Rule (UCMR), that large water systems test for TCP every five years with a minimum reporting level of 0.03 μg/L. This rule allows for the EPA to monitor contaminants suspected to be in drinking water that are unregulated under the SDWA. As a result of the testing, TCP has been identified across the US in drinking water sources. Currently, there is no federal maximum contamination level (MCL) for TCP; there is a federal non-enforceable health-based screening level of 0.00075 ug/L.
The author continues the paper with an examination of what TCP is and how it impacts our environment and our health. She then discusses regulatory policies and how California’s mandatory TCP standard could be a blueprint for other state water agencies currently investigating how to enhance their own drinking water protections from emerging contaminants.
Lyn covers some of the legal aspects, risks to businesses, detection, and treatment options to conclude her white paper. She also provides plenty of resources to start the journey toward sustainable treatment solutions that communities can afford.
About the Author: Lynleigh Love is a Senior Project Geologist with SCS Engineers. She has been a professional geologist for more than 22 years with extensive technical expertise in environmental assessment, remediation, and regulatory compliance. Her experience includes groundwater/soil vapor monitoring, excavation work plans, and remedial action plans.
PFAS are also key components in aqueous film-forming foam (AFFF), which is used to fight petroleum-based fires at aviation and manufacturing facilities. For decades, AFFF containing PFAS has been used extensively at airports throughout the world to protect the safety of passengers, crew, and others. The FAA requires that commercial airports train with, calibrate equipment with, and use the best performing AFFF fire suppression systems. AFFF is required to be used at airports and must be certified to meet strict performance specifications, including those mandated by the U.S. Department of Defense Military Specifications.
Lynleigh Love and Chris Crosby of SCS Engineers discuss the risks and issues with PFAS-based firefighting foam used at airports. The authors cover the regulatory climate, contamination investigations, operational and environmental management and litigation, along with alternatives to using traditional AFFF. There are some possible alternatives that can mitigate health risks in your community.
Read this article to help inform your mitigation plan and strategies to minimize risk.
Article published in the January 2020 edition of Waste Advantage Magazine.
At the Federal level, GHG emission reporting has become part of the standard regulatory requirements; however, on the west coast, GHG programs continue to develop and evolve from reporting to reduction programs beyond federal requirements. Solid waste facilities can be impacted by all of these reporting mechanisms directly as a landfill located in the state in question, opting in for C&T as part of the LCFS in California, or in limbo, as the courts work out the legality of Washington’s Clean Air Act. More stringent federal GHG requirements are unlikely with the current administration, however, that could change with the 2020 election. In general, GHG rules and legislation keep developing and updating to account for and reduce GHG emissions.
Read, share, or download the full article here.
Cassandra Drotman Farrant is Project Manager with SCS Engineers. She has nine years of experience in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. Cassandra has participated in many GHG verification projects throughout the U.S. and has completed approximately 70 Phase I Environmental Assessments (ESAs) in California, Oregon, and Washington. Phase I projects included research and review of geologic and hydrogeologic conditions at project sites and in the surrounding areas and evaluating the potential for soil and groundwater contamination from on and offsite sources. Cassandra has completed emissions estimates and inventories and has prepared numerous permit-to-construct/operate permit applications. She prepares compliance reports, which includes reviewing and maintaining records and regulatory deadlines.
SCS Engineers provides engineering, consulting, operations and monitoring services to report and reduce greenhouse gas emissions. Select a service category to learn more.
Reprint of USEPA Press Release dated today.
WASHINGTON (Dec. 19, 2019) — Today, the U.S. Environmental Protection Agency (EPA) took another key step in implementing the agency’s PFAS Action Plan by announcing a new validated method for testing per- and polyfluoroalkyl substances (PFAS) in drinking water. This new validated test method complements other actions the agency is taking under the Action Plan to help communities address PFAS nationwide.
“EPA’s important scientific advancement makes it possible for both government and private laboratories to effectively measure more PFAS chemicals in drinking water than ever before,” said EPA Administrator Andrew Wheeler. “We can now measure 29 chemicals, marking a critical step in implementing the agency’s PFAS Action Plan—the most comprehensive cross-agency plan ever to address an emerging chemical of concern.”
EPA’s new validated Method 533 focuses on “short chain” PFAS, those PFAS with carbon chain lengths of four to 12. Method 533 complements EPA Method 537.1 and can be used to test for 11 additional PFAS.
Method 533 accomplishes a key milestone in the EPA PFAS Action Plan by meeting the agency’s commitment to develop new validated methods to accurately test for additional PFAS in drinking water. Method 533 also incorporates an analytical technique called isotope dilution, which can minimize sample matrix interference and improve data quality.
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