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Engineering Services Best Practices and Blog

EPA INSPECTIONS: Preparing for a surprise inspection

Posted by Rebecca McDaniel

By Laurence Hren, Onsite Support Services Coordinator

In my recent experience with EPA inspections focused toward laboratory and hazardous waste management, it has become apparent that preparation for a surprise inspection is every bit as important as properly responding to an inspection. While this is by no means an all-inclusive guide to successfully handling an EPA inspection, the following should serve as an outline of key points to consider prior to and during an inspection:

  • Is your emergency contact information accurate and up to date?
    • This may be one of the first things an inspector delves into upon arrival at your facility. Additionally, it is important to test your primary and secondary methods of acquiring an MSDS in the event of an emergency. For example: if you have identified that MSDS's will be obtained via the internet in the event of an emergency, you should also be sure that you are familiar with an alternative method such as calling an emergency MSDS hotline and that an MSDS can be faxed to your facility on short order.
  • Is your Main Accumulation Area (MAA) well maintained, in compliance, and is your weekly MAA inspection log complete and up to date?
    • Proper MAA maintenance is intrinsically linked to running a top notch Haz-Waste management program at your facility. Deficiencies during this portion of an EPA inspection will most likely lead to a higher level of scrutiny during the remainder of the inspection. Be sure that you are completely in compliance with MAA regulations and that the space is as clean and organized as possible. Don't forget to make sure all emergency contact info is conspicuously posted and a phone is located inside of or very close by the MAA
    • Weekly MAA inspection logs are to be kept on file for 3 years. It is crucial that there are no gaps in the records. Be sure to take into account long weekends and holiday schedules. If you can present a simple SOP geared towards accommodating for such circumstances, all the better!
  • How well are your laboratories maintained? Are training records kept on file and readily available?
    • Once inside the lab, an inspector will most likely ‘interview' lab staff. Questions will focus on waste management, safety procedures, and chemical compatibility issues in your chemical storage cabinets. 
    • RCRA is all about records. Be sure that all laboratory training records and lab SOPs are available. 
    • Out of date, unusable, or excessive amounts of chemicals should not be stored in the lab. Chemical storage/labeling issues raise a red flag, and are viewed as an indicator of poor lab practices

The main thing to keep in mind during an inspection is to remain calm and answer all questions honestly and to the best of your ability. Never try to down-play compliance issues as a means to dissuade the inspector from looking into them. Dedication to running an exemplary program goes a long way.

Tags: Environmental Protection Agency, MAA, Main Accumulation Area, emergency, Inspections, RCRA, EPA, MSDS, hazardous waste management, EPA inspections, laboratory and hazardous waste management, laboratory waste management, is your emergency contact information up to date?, MAA inspection, MAA inspection log, weekly MAA inspection log, proper MAA maintenance, MAA maintenance, Haz-Waste management, MAA regulations, inspector, lab SOPs, chemical storage, chemical labeling

Results to indoor air quality from PCB caulk

Posted by Rebecca McDaniel

By Kristina Florentino, Environmental Compliance Specialist

An emerging environmental health issue is information published by the Environmental Protection Agency (US EPA) that caulk containing polychlorinated biphenyls (PCB) was used in many nonresidential buildings, including schools, throughout the 1950s through the 1970s. PCBs are man-made toxic chemicals that persist in the environment and bioaccumulate in animals and humans. Exposure to PCBs can affect the immune system, reproductive system, nervous system, and endocrine system and is potentially cancer-causing. Caulk is used in construction to seal gaps to make windows, door frames, masonry and joints in buildings watertight or airtight. Before the prohibition of PCBs in all U.S.-manufactured products in 1977, caulk was prepared with PCBs due to the flexibility and other valuable properties of the compound such as persistence and low reactivity. Buildings that were constructed or renovated during this period could contain caulking with elevated levels of these hazardous compounds.

Until recently, testing was seldom conducted for PCB levels and there have been few studies to determine the environmental exposures to building occupants, remediation or construction workers, or related environmental contamination. The material will evidently deteriorate and leach PCBs into nearby soil, concrete pads, bricks, mortar, storm drains and potentially volatilize. Studies have shown a correlation between PCBs in caulking and elevated levels of PCBs in indoor air and dust, in addition to ambient soil surrounding the buildings. The deteriorating caulk has the highest potential for creating dust exposing occupants via inhalation. In addition to inhalation from PCBs in the air or dust, dermal exposure may occur when a person comes in contact with the caulk, surrounding porous materials, or PCB-contaminated soil adjacent to buildings.

The US EPA recommends indoor air monitoring to determine if PCB levels exceed the suggested public health levels. If testing reveals PCB levels above these levels, the potential sources of PCBs need to be identified. Typically testing of samples of caulk, dust, and soil is performed. If elevated air levels of PCBs are found, it is also recommended that the ventilation system be evaluated to determine if it is contaminated with PCBs, since it may have been contaminated before other sources of PCBs were removed from the building and may be contributing to elevated air levels. Contaminated ventilation systems need to be decontaminated along with removal of any sources of PCBs that are found to avoid recontamination of the system.

EPA is currently researching PCB exposure related to contaminated caulk and looking into methods for mitigating exposure and potential risks associated with PCBs in caulk. In addition to the risk posed by PCBs caulk can also contain as much as 20 percent asbestos, requiring additional management during sampling and disposal.

Resources:MA DEP PCB Q&A,US EPA

Herrick, R. F., Lefkowitz, D. J., & Weymouth, G. A. (2007). Soil Contamination from PCB-Containing Buildings. Environmental Health Perspectives , 115 (2), 173-175.

Look for future consulting blogsabout environmental health and safety, and industrial hygiene topics including mercury, lead and heavy metals. Please contact Triumvirate’s consulting group for more information. We have Environmental Engineers and Consultants ready to answer your questions.

Tags: caulk, Environmental Protection Agency, US EPA, PCBs in caulk and indoor air quality, indoor air quality, environmental health issues, caulk containing polychlorinated biphenyls, PCB-contaminated soil, kristina florentino, PCBs, EPA, PCBs in schools, PCBs health concerns, polychlorinated biphenyls, PCB levels

Perchlorate Safety

Posted by Rebecca McDaniel

By John Bailey,  Environmental Compliance Advisor

Perchlorates are the salts derived from perchloric acid. They are used as oxidizers for fireworks, airbags and in solid rocket fuel. The solid rocket boosters of the space shuttle contain 350 metric tons of ammonium perchlorate each.

Perchlorate compounds are derived from perchloric acid (HClO4), a strong mineral acid that is an explosion hazard. When perchloric acid vapors combine with organic or metallic ions they form perchlorate compounds. Common organic and metallic perchlorates include ammonium perchlorate (NH4ClO4), potassium perchlorate (KClO4) and sodium perchlorate (NaClO4). Dry crystals of perchlorate pose an explosion hazard if disturbed. Perchlorates are strong oxidizers that are widely used because they are generally stable, however if heated or shocked they may ignite or detonate.

Perchlorate residues can be encountered within fume hoods and exhaust ductwork of laboratories in which perchlorate or perchloric acid is used. Perchlorate residues can be identified in the field using methylene blue solution, which forms a violet precipitate after reacting with the perchlorate ion. In addition to field testing, perchlorate residues can be detected by laboratory analysis of wipe samples. Best management practices for laboratory cleaning include drenching with water following use to remove potential residues, and the disposal of solutions by dilution in copious amounts of water.

Perchlorates have also been identified as a contaminant in soil and groundwater in Massachusetts, and as an Emerging Contaminant by the US EPA. Perchlorates are also naturally occurring compounds that have been detected at low concentrations in arid areas and on Mars. Perchlorates are extremely soluble in water, making them relatively easy to remove in laboratory conditions; however the solubility makes cleanup of perchlorates in the environment difficult because they do not readily degrade.

Resources:

MA DEP Perchlorate Q&A: http://www.mass.gov/dep/toxics/pchlorqa.htm

US EPA: http://www.cluin.org/download/contaminantfocus/epa505f09005.pdf

Look for future engineering blogs about Industrial Hygiene topics including mercury, lead and heavy metals. Please contact Triumvirate’s engineering group for more information. We have Environmental Engineers ready to answer your questions.

Tags: US EPA, disposal, waste disposal, industrial hygiene, perchlorate safety, perchlorate, perchloric acid, best management practices, lab cleaning, emerging contaminant, engineering blogs, EPA, Triumvirate, MA DEP, engineering, Environmental Engineers, oxidizers, fume hoods

EH&S Strategies for Green Remediation

Posted by Rebecca McDaniel

By John Bailey, Environmental Compliance Advisor

Green remediation is the practice of considering environmental impacts of remediation activities at every stage of the remedial process in order to maximize the net environmental benefit of a cleanup. Considerations include selection of a remedy, energy requirements, efficiency of on-site activities, and reduction of impacts on surrounding areas. -US EPA, 2009

The goal of green remediation is to minimize the environmental impact of remedial activities, without compromising the effectiveness of the clean-up. This can be accomplished by reducing:

• Total energy use – fuel burning vehicles, shipment of materials and supplies (from the point of manufacture to the site), computers, lights heat and air conditioning at the office where reports are prepared, fuel or energy required to operate remediation system;

• Byproducts of remediation – CO2, heat, and other byproducts emitted as a result of vehicle use, remedial system operation, and sometime breakdown of contaminants.

A key component to minimize environmental impacts is determining the impacts of off-site activities such as manufacturing, transportation, and power use. For example if a part for a remediation system located in Boston is sourced from a manufacturer in China the amount of energy required for transportation alone can be tremendous compared to local sourcing of parts. As you can see, the environmental impact of a remediation system can be reduced just by changing vendors.

Other ways to reduce environmental impact include:

• Minimize vehicle usage to reduce energy loss through fuel consumption. This does not mean not using vehicles at sites, but rather planning work to make the most effective use of vehicle time.

• Minimize soil and water disturbance during remediation by using in-situ remediation technologies such as monitored natural attenuation and chemical oxidation versus ex-situ remediation technologies such as pump-and-treat groundwater remediation or soil excavation.

There are many ways to make remediation activities more “green,” pre-project planning and on-going analysis during remediation are key components to identify what the true “environmental cost” of remedial activities are.

Tags: environment, green, remediation activities, on-site activities, reduction of impacts, goals of green remediation, goal of green remediation, fuel burning vehicles, minimize environmental impacts, environmental cost, EPA, remediation, green remediation, environmental impact of remediation, environmental impact, energy

The Dangers of Lead Contaminated Soil

Posted by Rebecca McDaniel

By Ross Hartman, Corporate Service Director

Lead Prevention

Some products that contain lead exhibit hazardous characteristics that can be harmful to your health. Typically industrial manufacturing activities with poor house-keeping practices will lead to releases to the subsurface. Some products that contain high levels of leachable lead are:

• Waste Oils
• Fly Ash
• Paints
• Foundry Sands
• Metal Slag

What can happen if you do not decontaminate soil that contains lead?

Both organic and inorganic contaminates can come from sources including agricultural runoffs and industrial waste materials. Soil pollution can result in water pollution if lead spreads to groundwater, or if soil runoff reaches a water source. Lead in the soil can also be a hazard for children who may be exposed to impacted areas. Furthermore, people who walk impacted areas track the contaminated substance into their homes with little to no awareness of the impact. Great care must be taken when handling or treating lead soil to prevent further cross contamination from the work place to the home.

According to the EPA, you can get lead in your body by breathing or swallowing lead dust or soil. Lead is extremely harmful to children and adults, and can lead to nerve disorders, memory problems, high blood pressure, and muscle pain among other consequences.

 

What happens if I need my soil decontaminated?

Soil remediation is conventionally performed by excavating the impacted soil and disposing of the material at a landfill. More and more we see the necessity to treat soil on-site through soil stabilization. Essentially, the lead in the soil needs to be stabilized by effectively changing the pH and eH levels. Treatment of lead contaminated soil effectively reduces the leachability. This allows property owners to benefit lower disposal costs or potentially reuse the material on-site.

Contact the National Lead Information center (http://www.epa.gov/lead/pubs/nlic.htm) for more information on lead hazards and prevention.

 


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