Month: December 2016

Did the EPA just end the era of PCE drycleaners?

Posted on by Jeff Carnahan

The United States Environmental Protection Agency (EPA) has announced a proposal that would bring about sweeping changes to the drycleaning industry. The measure is a ban on the chlorinated solvent trichloroethylene (TCE) being used as an aerosol degrEPA Logoeaser and as a spotting agent in the drycleaning process. This major announcement was the first of its kind following this year’s revisions to the Toxic Substances Control Act (TSCA). Only two weeks ago, the EPA released their list of the first ten chemicals to be assessed under TSCA reform. Not only did the list include TCE, but also tetrachloroethylene (PCE), which is another one of the most commonly used drycleaning chemical.

While TCE is used mainly as a pretreatment spot removing chemical in small volumes, PCE is used as a primary solvent in which textiles are completely immersed during drycleaning. Those in the fabric care industry commonly refer to PCE as Perc. Not all drycleaners use Perc as their primary solvent, but many at least still use TCE for spot removal. If the EPA follows suit and proposes a nationwide ban on the use of PCE, many Perc drycleaners could be in serious jeopardy of losing their business, not just scrambling for a replacement spot remover. The cost to convert a Perc drycleaning operation to one of the other available solvents can be cost-prohibitive for small business owners.

The use of Perc has been losing favor slowly over time, especially on the West Coast, as new toxicological data continue to show that exposure to PCE is probably linked to an increase in risk of cancer. California enacted law in 2007 that requires all Perc drycleaning to be phased out by 2023. Historical (usually pre-EPA) drycleaning practices have also resulted in an overabundance of environmental releases to soil and groundwater, which are very costly to clean up, result in a great deal of legal risk to the responsible parties, and cause exposure concerns. The fallout for drycleaners has included diminishing clientele, difficulties getting funding for upgrades to operations, loss of rental leases, and depressed property values.

The amended TSCA requires EPA to publish the entire list of ten chemicals in the Federal Register by December 19, 2016. At that time, it will trigger a statutory deadline will be established to complete risk evaluations for these chemicals within three years. If it is determined that one of the chemicals presents an unreasonable risk to human health or the environment, EPA has only two years to address the risk. Scoping documents for each chemical will be released by the EPA within six months, which should provide more details.

In essence, the EPA may have just brought the balance of the nation up to speed with California’s Perc phase-out date of 2023. That gives Perc drycleaners precious little time to devise an action plan on how to continue operating their businesses beyond the first quarter of the 21st Century, or alternatively, to get their business exit strategy finalized.

Published: December 15, 2016

U.S. EPA Finalizes Vapor Intrusion Rule for Superfund Sites

Posted on by Alex Miller

A major development in the Environmental Consulting industry. The United State Environmental Protection Agency has published a final rule which effectively adds a vapor intrusion component to CERCLA’sHazard Ranking System (HRS) for Superfund sites. This move finalizes the draft rule from earlier this year, after the incorporation of some public comments. This final rule paves that way for EPA involvement at sites with no known responsible party to address immediate vapor intrusion exposure concerns. Given the fact that vapor intrusion has not previously been considered during the Superfund ranking system, it is likely that a higher percentage of new sites being added to the program will have a vapor intrusion component.

Our Executive Vice President, Jeff Carnahan, LPG spoke with Bloomberg BNA earlier this year, and thinks this will create a need for new advancements in vapor intrusion research and remediation.

“This [regulatory development] is not likely to be the last one. With each additional incremental step in the regulation and highlighting of the exposure pathway, you’re going to see more and more developments in the science and technology,VIStamp

EnviroForensics Vapor Intrusion experts will continue to monitor this development as the new presidential administration and EPA commissioner take office early next year.

EnviroForensics presenting at international waste management conference this week

Posted on by Alex Miller

We are humbled to have some of the foremost minds in the Environmental Consulting industry right under our roof! Our staff boasts decades of experience, and the knowledge and wisdom to help move environmental science forward in a profound way. Our Director of Vapor Intrusion Services, Megan Hamilton, is one those individuals keeping us on the cutting edge, and she’ll be imparting some of that wisdom on an international stage this week!

Hamilton is headed to the Air and Waste Management Association’s Vapor Intrusion, Remediation, and Site Closure Conference in San Diego, California. This is the 8th specialty conference hosted by AWMA focused on the critical and changing area of Vapor Intrusion, and one of the few conferences in the world to focus on this particular exposure pathway.

Director of VI Services, Megan Hamilton, is presenting this week at the AWMA Vapor Intrusion, Remediation, and Site Closure Conference in San Diego, California.
Director of VI Services, Megan Hamilton, is presenting this week at the AWMA Vapor Intrusion, Remediation, and Site Closure Conference in San Diego, California.

Hamilton will be presenting a poster in the exhibit hall entitled, “The Cost and Liability of Evolving VI Technical Guidance.” The research for her presentation was a team effort with EnviroForensics Executive Vice President, Jeff Carnahan, LPG, and Professional Staff members Grace Randall and Kathleen Nazareth pitching in. This presentation evaluates how high levels of uncertainty and conservatism during the early years of VI regulation may have affected the exposure assumptions and costs associated with the investigation and mitigation of the VI pathway at remediation sites. In this study, a portfolio of sites consisting of nearly 40 subsurface releases of PCE or TCE have been reevaluated based on a series of guidance milestones since 2002.  Actual assessment and mitigation costs have been compared with those that would have been occurred if performed under older state and federal VI guidance, and the latest version of the Final U.S. EPA VI Guidance.

This week’s event is expected to draw internationally-recognized scientists, engineers, regulators, and attorneys with experience in getting sites to closure and focuses on the critical sustainability and technical issues that need to be considered in doing so.

Hamilton is no stranger to this kind of attention. She has presented at several national and international Environmental conferences, is a member of the National EPA VI Science Advisory Committee, and was just awarded a second term on the Board of Directors for the Midwestern States Environmental Consultants Association (MSECA). Her credentials in the area of VI speak for themselves; she oversees VI investigations and mitigations for all EnviroForensics projects, and she was the main author of the current Indiana Vapor Intrusion Guidance during her time at the Indiana Department of Environmental Management’s (IDEM) Office of Land Quality.