The Best Fit – Selecting Remediation Technology for Site-Specific Conditions and Client Goals

Do any of these situations sound familiar to you? Gasoline floating on groundwater, vinyl chloride in saturated sands, hexavalent chromium leaching into a creek, perfluorooctanesulfonic acid (PFOS) heading towards a drinking water well, trichlorethylene (TCE) dense non-aqueous phase liquid (DNAPL) in weathered bedrock. If so, you probably have been around a site with soil and/or groundwater contamination or you’ve picked a really unusual hobby.  If you are a responsible party, a stakeholder, or an environmental manager responsible for handling the regulatory aspects of a contaminated site, the goal is generally to reach the cleanup finish line (closure) with the best possible results for the least possible cost. Consider this analogy. We know three things about fingerprints. 1) They are found on fingers, 2) they are generally arranged on the surface of the fingertips, and 3) each fingerprint is different from all others in the fine detail.  Remediation can be viewed
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TRI and P2 APR – Successfully Closing Out This Reporting Season

March reporting deadlines are still on the horizon. While you still have time, watch our uploaded January webinar and review our slides to assist in your first round of reporting. While you’re still finalizing your March reports, be mindful of the July 1st TRI and P2 Annual Progress Report just around the corner. We will host a live lunchtime webinar on March 28th to help you prepare for report requirements, report submittal and best methods for reducing waste and TRI releases. Texas’ Waste Reduction Policy Act of 1991 was adopted to prevent pollution in Texas. The Texas Commission on Environmental Quality (TCEQ) adopted the corresponding rule under 30 TAC 335 Subchapter Q, which requires small and large quantity generators of hazardous waste and TRI reporters to prepare a five-year P2 Plan and submit an Executive Summary of the plan to TCEQ. Large quantity generators and TRI reporters are also required
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Proposed Changes to the Endangered Species Act

ASSESSMENTS AND ECONOMIC CONSIDERATIONS In July of this year, the federal government proposed an amendment to the Endangered Species Act (ESA) that redefines/streamlines the procedures and criteria for listing and delisting endangered species and designating critical habitat.  There are a handful of amendments that are proposed but the overall direction points to allowing the U.S. Fish and Wildlife Service (FWS) to make unique or tailored assessments based on the species, habitat, region, etc. when deciding to list or delist a species. Additionally, the ESA currently states that it will not take economic or other impacts into consideration when listing, delisting, or reclassifying a species.  That is not being changed at this time.  However, under the proposed amendments, the FWS acknowledges that there is value in referencing economic or other considerations such as ambient air studies, cost/benefits analysis, etc. By clarifying the criteria for critical habitat designations, the proposed changes aim
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Brace yourself for March, it’s just around the corner.

For Environmental Health and Safety (EHS) Managers or professionals, the new year brings a new outlook on your job, promises to yourself and your company, and the desire for improvement over the past year. Unfortunately, the new year also brings the crushing realization that March is just around the corner, almost taunting you for becoming cocky in November and December when few environmental reports are due to the State or EPA. March marks the beginning of the annual reporting deadlines. The reporting calendar begins with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II report and the Annual Waste Summary (AWS) due March 1st, and then you dive right into the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) Benchmark Monitoring (BM) reporting and Discharge Monitoring Report, and the Air Emissions Inventory Report (AEIR), all due on March 31.  Individually the reports are not overly difficult or time
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Municipal Setting Designations

What is the most cost-effective way to address groundwater contamination? One cost-effective option is the use of a Municipal Setting Designation (MSD). An MSD is a state-approved deed restriction applied to a Site located within a municipality or its extraterritorial jurisdiction (ETJ) which restricts the use of groundwater for potable purposes. Any water used for drinking, bathing, cooking, or for the irrigation of crops is considered potable water. MSDs are commonly used in areas where shallow groundwater is not used and potable water is supplied by municipalities, and saves money by avoiding costly remediation. Additionally, MSDs may save time by closing sites sooner since remediation activities and subsequent groundwater monitoring could take years. Before pursuing an MSD there are a number of factors to consider that include: Does the local municipality have an MSD ordinance What are the chemicals of concern present in groundwater and what are the concentrations Is potable water
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Spill Response – Failing to Plan is Planning to Fail

Releases, spills, and overflows……nobody ever wants to hear those words. However, despite the best precautions, accidents happen or systems fail, and you need to be prepared.  From the initial spill response, to the critical first 24 hours of Site activities, there is a lot to do and a lot to process. Are you prepared? Emergency response, spill response, and rapid response teams are critical pieces to be included in preparation for a potential future spill or disaster that a number of industries may encounter. For oil and gas facilities, metal manufacturing facilities, and even food manufacturers, the potential for a spill or disaster could occur at any moment. There are a number of regulatory agencies that govern spills or discharges in Texas. However, what they all have in common is that spills need to be reported, assessed, and remediated as soon as possible to reduce potential long-term issues or liabilities. When
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Don’t Let Your Wastewater Knowledge Go Down The Drain

We all create wastewater every day, and for the most part, don’t give it a second thought. You wash your dishes and the water goes down the drain. You flush the toilet. You wash your car and the water runs off into the street or storm drain. But when a factory or industrial operation creates wastewater, it’s a different matter. Depending on how much wastewater is created and what types of pollutants or solids are involved, the business may need to obtain permits, build some type of wastewater treatment facility, or both. Failure to do so properly could create hazards to your employees, people in the community, wildlife, as well as the surrounding environment. Common types of wastewater and methods of dealing with wastewater issues including: Domestic wastewater from households & rural businesses Municipal wastewater from communities (sewage) Industrial wastewater from industrial activities Businesses call on W&M for assistance in handling the
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Stormwater Compliance In Practice

The history of stormwater regulation dates all the way back to 1972 with the passage of the Clean Water Act (CWA) by the US Environmental Protection Agency (EPA). The CWA, and subsequent legislation over the years, is both the precursor and the framework for current stormwater permits today.  The laws were initially passed to create some control over the amount of pollution entering waterways through industrial stormwater runoff.  The EPA has given the Texas Commission on Environmental Quality (TCEQ) the authority to regulate stormwater permits in Texas.  The permit most commonly used by industry is the TXR050000 Multi-Sector General Permit. So what is a “sector?” The TCEQ has broken the TXR050000 permit down into industry specific sectors, from A through Z and on to AD.  Each sector covers a specific industry or group of industries.  You can find which sector you might fall into based on your SIC code.  With
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Are We In Compliance With Environmental Regulations?

If someone has ever asked you “Are we in compliance with environmental regulations?”, there’s a good chance your role involves managing environmental compliance programs at your operating facility.  Or maybe your role is at the corporate level where you focus on strategic development of environmental, health, and safety programs and how that aligns with the operational and growth goals of the company.  Either way, you know the challenges associated with maintaining environmental compliance and how the question can sometimes be hard to answer. So what kind of environmental management system (EMS) do you need to answer the question? Odds are you don’t need an ISO certified management system, but you probably need to know the key metrics that ensure that the environmental and sustainability commitments that your company have established are on track.  The basis of this usually stems from an evaluation and identification of risks, review of culture and
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It’s Crucial! Safety First…No Matter What!

As an Environmental Health and Safety (EHS) consultant,  I am often asked to provide site level safety support overseeing multiple subcontractors.  I’ve found that the safety culture of our subcontractors varies greatly.  For example, the smaller subcontractors may not have the resources to implement a strong or well developed safety program. My job is to bridge the gap between the client and the subcontractors.  I’ve learned that regardless of the project type, a successful project is one in which safety is considered during the planning phase.  If you have a good understanding of your client’s safety culture and expectations from the start, you can pre-qualify your subcontractors for safety.  A contractor health and safety plan can be developed to include training requirements, injury reporting requirements and program requirements, and be provided to the contractors before they bid on the project.  Project communication and training can be tailored to fill the “gaps” that may
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