REGENESIS President and CEO Scott Wilson
Scott Wilson, President and CEO of REGENESIS Remediation Technologies, San Clemente, CA, will be speaking at the National Groundwater Association’s (NGWA) Theis Conference on November 10, in Phoenix, AZ. Mr. Wilson, drawing on his 30 year career in commercializing technologies in the environmental industry, will be speaking on the topic of, “So You’ve Developed A Revolutionary Environmental Technology….Now What?” His presentation will focus on taking an environmental technology from the early concept stages through product development and then into the all-important commercialization step.
The theme of this year’s Theis Conference, to be held Nov. 8-10 at the Embassy Suites Phoenix-Scottsdale, is “Accelerating the Use of New and Developing Tools and Technologies for Groundwater Monitoring, Modeling, and Management: Theory to Practice”. Attendees will gather to hear industry professionals discuss how they have successfully moved scientific and technological ideas into standard practice, including what obstacles they faced and how they were overcome.
The Theis conference is held in honor of Charles Vernon (C.V.) Theis and his work in hydrogeology. Theis was the first to develop mathematical equations that allow hydrogeologists determine the characteristics of an aquifer and predict how water levels in the aquifer will change during pumping. The “Theis Equation” is still used in the remediation industry today and remains a standard for determining groundwater characteristics.
In conjunction with the Theis Conference, NGWA will host its Pillars of Groundwater Innovation conference which will provide groundwater experts firsthand and thought-provoking perspectives from scientists and practitioners who have made significant contributions to hydrogeology.
Contributed by Scott Wilson, President and CEO, REGENESIS
Last week the USEPA released proposed changes to the Underground Storage Tank (UST) Regulations. While the revision is, by most accounts, long overdue a few of the proposed changes could be quite impactful for those involved in the sampling and analysis of groundwater.
The main thrust of the changes proposed by the EPA is to push UST owners to properly maintain and operate UST equipment. As this is accomplished the emphasis for leak prevention and detection will be placed solely on equipment and not on the sampling of external media such as groundwater or vapors.
As currently proposed, the use of groundwater and vapor sampling to detect leaks will be phased out completely within the five year period following publication of the final regulation. This move is in favor of using interstitial space sensors (all properly maintained of course!) along with inventory reconciliation techniques. The EPA estimates that currently only 5% of operating USTs use groundwater and vapor sampling as part of their leak detection/prevention program—I’m not so sure this is the case.
Specifically the EPA’s proposal revises the UST technical regulation in 40 CFR part 280 by:
- Requiring secondary containment requirements for new and replaced tanks and piping
- Requiring operator training requirements for UST system owners and operators
- Requiring periodic operation and maintenance requirements for UST systems
- No longer allowing certain deferrals
- Phasing out of groundwater and vapor monitoring in favor of new release prevention and detection technologies
To view a pre-publication version of the proposed UST regulations signed by EPA Administrator Jackson on October 25, 2011 go to this link: https://regenesis.com/regenesis-resource-center/developments/default.aspx The section related to phasing out groundwater and vapor as a detection method is described in section IV.D.6
I’ll keep you posted.
This post was contributed by REGENESIS CEO Scott Wilson.
In a rare showing of bipartisanship, both democratic and republican legislators show strong support for the USEPA Brownfields Program.
I have received word yesterday from a hearing of the US Senate Environment and Public Works Committee that praise was heaped on the USEPA for the success of its Brownfields Program. Standout remarks came from Sen. Frank Lautenberg (D-N.J.) who supported the USEPA’s use of funding to clean up brownfields stating, “Once brownfields are rehabilitated, they often spark neighborhood revitalization, boost property values and make communities more attractive places to live, work and do business.” He went on to say, “These cleanups have created more than 72,000 jobs and attracted more than $17 billion in private investment.” Positive sentiments were also echoed by the republican side of the aisle as ranking member of the Environment and Public Works Committee James Inhofe (R-Okla) stated, “[the Brownfields Program] is one program that has worked very well.”
If you are not familiar with the Brownfields Program, it was started by the USEPA more than a decade ago to aid in funding the restoration of contaminated properties, which are generally former industrial sites. Usually in urban areas these properties, once restored, are put back into good use attracting new businesses and civic facilities. This, in turn, results in the generation of jobs and tax revenue.
In a describing the success of the Program, David Lloyd, Director of EPA’s Office of Brownfields and Land Revitalization indicated that the Program has treated over 24,500 brownfield acres stimulating some $17.5 billion in economic development.
While most testimony was very positive in support of continued funding for the program, suggestions were made for improvements including a call for funding sites outside of urban areas (Aaron Scheff, Brownfields Project Manager at the Idaho Department of Environmental Quality) and for raising the $200K initial funding limit and speeding up the application period (Oklahoma City Mayor Mick Cornett).
In one of the most bitter partisan environments on Capitol Hill in decades, legislators from both sides of the aisle spoke very favorably of what the USEPA’s Brownfield Program has accomplished and indicated strong support of the funding the Program in future. – Good news for those of us involved in environmental assessment and remediation!
This blog post was contributed by REGENESIS CEO Scott Wilson
USEPA Announces final toxicity values for TCE
As most of you are probably aware, the USEPA announced last week that the agency has completed its Final Health Assessment for Trichloroethylene (TCE). In short, this means that the agency has performed an in-depth study of the health hazards posed by the chemical which is often found as a groundwater and soil contaminant at dry cleaner sites, manufacturing facilities and the like. The results of the study have formally characterized the chemical as a human carcinogen and a non-carcinogenic health hazard… no big surprise to those of us involved in groundwater and soil remediation. Here is a link to the official press release in case you didn’t catch it. If you are interested in the toxicological details here are the established reference doses (RfD)/concentrations (RfC) for TCE:
|Chronic Oral RfD Assessment:||0.0005 mg/kg/day|
|Chronic Inhalation RfC Assessment:||0.002 mg/m3|
|Carcinogenicity Assessment:||Carcinogenic by weight of evidence (mutagenic mode of action kidney tumor)|
For further details on the assessment and references go to the USEPA’s Integrated Risk Information System (IRIS) database.
So How Does this Impact Groundwater and Vapor Assessment?
When I saw the USEPA press release announcing the Final Health Assessment for TCE the first thing I asked myself was, “So how does this impact the sites around the U.S. known to contain TCE in soil, groundwater and soil vapor?” After a bit of research it appears to me that there will in fact be some impact… but not right away.
First we have to realize that current federal cleanup standards for TCE in groundwater are based upon Maximum Concentration Limits (MCLs) which were established decades ago by the Office of Water. These MCLs (i.e. 5.0 ug/l) were based primarily upon limits of analytical methods in use at the time rather than toxicological risk.
Currently when establishing cleanup goals for regions within U.S., the USEPA takes the MCL and adjusts the value taking into consideration toxicological risks and physical characteristics inherent within the region and comes up with a Regional Screening Level (RSL).
Now that we have the USEPA established Final Health Assessment Values for TCE, there is a shift underway to re-evaluate the current RSLs. Already, an RSL Working Group has been underway at USEPA headquarters reviewing the impact the newly published Assessment Values will have on RSLs for TCE.
Of particular interest is the impact the newly published Final Health Assessment Values will have on vapor limits (not currently based upon MCLs). Word on the street is that the RSL Working Group has been focusing on this with preliminary thoughts for USEPA Region 9 of 0.5ug/m3 for carcinogenic RfC and 2.0 ug/m3 for non-carcinogenic RfC.
As far as timing of new RSL adoption, I have been told that historically this has been a rather slow process- say 2 to 3 years or so. However, movement in convening the RSL Working Group and talk of having already generated preliminary values for vapor indicate the timeframe for Trichloroethylene RSL adoption could be much sooner. I’ll keep you posted on what develops.
This blog post was contributed by REGENESIS CEO Scott Wilson.
I was recently preparing for a talk on the current trends in environmental management and the associated cost impact on commercial and industrial operations in the United States. One of the clear trends noted was the proactive attitude being taken by some corporations with environmentally impacted properties such as those with groundwater contamination. It seems that a number of progressive corporations see an economic advantage to implementing in situ treatment approaches that allow them to shut down inefficient and costly existing groundwater remediation systems.
In many states across the United States, regulations are now in place that allow for risk-based regulatory closure of sites with groundwater contamination. Often risk-based cleanup objectives can be achieved by simply removing a significant mass of contamination from the source zone and conditioning the subsurface such that Monitored Natural Attenuation (MNA) will degrade the balance of contamination before any significant down-gradient receptor is impacted (e.g. surface water body or drinking water source).
In discussions about this topic here at REGENESIS it was brought to my attention that the environmental engineering firm Symbiont had taken this very approach. When their client was confronted with mounting costs, year after year, of operating a pumping system to control and treat a chlorinated solvent groundwater plume at their manufacturing plant in West Allis, Wisconsin, the team penciled the total lifecycle costs of continued operation—a total of $12 million out the door over the next 30 years! Searching for alternatives to this they then looked at a creative approach using chemical oxidation to reduce the mass of contamination in the source area, followed by injecting a controlled-release substrate to enhance the natural contaminant attenuation on the property (through a process referred to as reductive dechlorination). They figured this “combined remedy” approach would enable them to shut down the costly pumping system and position them to make the case that the site required “No Further Action” based upon the source mass being reduced, no receptors being impacted and the plume undergoing natural attenuation. The project was then undertaken with the application of REGENESIS technologies.
The Symbiont team recently published the results of their creative approach at the International Symposium on Bioremediation and Sustainable Environmental Technologies sponsored by Battelle held in May this year in Reno, Nevada. By anyone’s measure this project has been a tremendous success. Due to the mass removal in the source area regulators allowed for deactivation of the costly pumping system in May 2011. The project is currently on a quarterly monitoring schedule with the intent of gaining “No Further Action” status within the next 24 months. For more about the project, read the poster presented at the Battelle Bioremediation Conference.
So, getting back to the reason I stumbled upon this case in the first place… the point is that there most certainly are mounting costs impacting U.S. businesses from increased environmental regulations, particularly in the areas of air emission controls and reporting. However advanced in situ technologies and creative combining of remediation approaches are allowing corporations to relieve themselves of the costly burden associated with ongoing groundwater treatment systems at impacted properties. In the specific case of this Wisconsin manufacturing facility, the Symbiont team undoubtedly saved their client millions of dollars in operating and maintenance costs. Additionally, they will have effectively relieved their client’s corporate balance sheet of a large environmental liability. That’s just good environmental management!