The Active Army MMRP and How the Technical Project Planning Process Has Helped Us Succeed
Laura Paugh, US Army Environmental Command, APG, MD

AAI Compliant Regulatory Database Searches: Some Are More Equal Than Others
Robert P. Blauvelt, EWMA, Parsippany, NJ  
David Fullmer, EWMA, Parsippany, NJ  

Changes to EPA’s Spill Prevention, Control, and Countermeasure (SPCC) Program
Melanie Morash, U.S. EPA New England Oil Program, Boston, MA

1,4-Dioxane – Regulatory Developments, Uses, Properties, Assessment, and Remedial Options
Ellen E. Moyer, Greenvironment, LLC, Montgomery, MA

Regulation of Hydrogen Sulfide (H2S) at C&D Landfills: Health Risk & Esthetic Considerations
Douglas J. Covert, Hazardous Substance & Waste Management Research, Inc., Tallahassee , FL
Kennard F. Kosky, Golder Associates, Gainesville, FL,
Bruce J. Tuovila, Hazardous Substance & Waste Management Research, Inc., Tallahassee , FL Christopher M. Teaf, Florida State University, 2035 E. Dirac Dr., Tallahassee, FL

The Active Army MMRP and How the Technical Project Planning Process Has Helped us Succeed
Laura Paugh, US Army Environmental Command, 5179 Hoadley Rd. Bldg 4480, APG, MD 21010-5401, USA, Tel: 410-436-1531, Fax: 410-436-1548, Email: laura.paugh@us.army.mil

Since 2003, the United States Army Environmental Command (USAEC) has been initiating and conducting Military Munitions Response Program (MMRP) Site Inspections (SI) at Active Army Installations across the US . Since the beginning, the USAEC has recognized that a process was needed to ensure quality stakeholder involvement and participation. Because of its demonstrated past success, the Army Corps of Engineers’ Technical Project Planning (TPP) process was selected as a means to include stakeholders early and often. Through the TPP process, the Active Army has been successful in obtaining stakeholder input and concurrence on critical decisions at MMRP sites. These decisions include data quality objectives, screening value selection, identification and removal of non-impacted areas within Munition Response Site (MRS) boundaries, No Further Action (NFA) for MRSs that pose no risk to human health or the environment, and identification of high risk MRSs that require further investigation or an immediate response. This presentation will cover a brief overview of the Active Army MMRP SI program and its desired outcome, an overview of the TPP process, lessons learned, an overview of successes to date, and a comparison of the TPP process to the EPA Systematic Project Planning (SPP) process. To date, the Active Army has been successful at obtaining NFA on approximately 50% of the MRSs that were included in the Historical Records Review (HRR) and a 94% overall acreage reduction at the end of the SI.

 

AAI Compliant Regulatory Database Searches: Some Are More Equal Than Others
Robert P. Blauvelt, EWMA, 100 Misty Lane , Parsippany , NJ   07054 , Tel: 973-760-1400 ext 168, Email: bob.blauvelt@EWMA.com
David Fullmer, EWMA, 100 Misty Lane , Parsippany , NJ   07054 , Tel: 973-760-1400 ext 191 Email: david.fullmer@EWMA.com

The 2002 Brownfields Revitalization and Environmental Restoration Act or BRERA curtailed the Federal government’s ability to seek damages and initiate cost recovery actions under certain sections of CERCLA.  These “enforcement bars” against innocent landowners, contiguous property owners, and prospective purchasers were promulgated to encourage Brownfields redevelopment.  However, as a condition of liability protection offered under BRERA, a prospective purchaser must perform All Appropriate Inquiry (AAI) in accordance with rules developed by USEPA (40CFR Part 312) and commercialized by ASTM in its 1527-05 Standard Practice for Environmental Site Assessments.

A major component of the AAI due diligence process is compliance with 40CFR Part 312.26: Review of Federal, State, Tribal and local government records. EPA requires that a long list of permit records and spill reports be examined for the subject parcel and other sites within defined radii.  Given the extensive and complex nature of both Federal and state record-keeping systems, a number of data management companies have emerged that specialize in assembling and summarizing publically available environmental information. Usually combining these records within a GIS format, these companies are able to quickly and cost-effectively provide very useful maps and data tables, often including them with other required components of Part 312 (aerial photographs, historic topographical maps, etc.).

In order to compare the completeness of these data base searches, we selected a well known Superfund site in the northeastern US and ordered regulatory database searches from four specialty providers: Environmental Data Resources (EDR); BBL Environmental, MapPro, and Environmental First Search. While each company offered a package that claimed to meet 40CFR Part 312.26 requirements, there were wide disparities in the quality, format and timeliness of deliverables, responsiveness to follow-up questions, and available geographic coverage. Our comparison of each data package is summarized and validated against our own search of the same EPA records. Recommendations are provided for those environmental professionals that frequently depend on data base service companies to help ensure that they are using the most current and reliable information available.

 

Changes to EPA’s Spill Prevention, Control, and Countermeasure (SPCC) Program
Melanie Morash, U.S. EPA New England Oil Program, One Congress Street (HBR), Boston, MA 02114, Tel: 617-918-1298 , Fax: 617-918-0298, Email: morash.melanie@epa.gov

For more than three decades, EPA’s Spill Prevention, Control, and Countermeasure (SPCC) Program has worked at several hundred thousand oil storage facilities throughout the country to prevent the discharge of oil into the waters of the United States .  EPA’s SPCC Regulation was promulgated under the authority of the Clean Water Act and became effective on January 10, 1974.  Oil storage facilities subject to the SPCC Regulation must prepare written SPCC plans detailing the facility’s spill prevention and control measures.  Substantial revisions to the SPCC Regulation were passed on July 17, 2002, December 12, 2006, and May 10, 2007, in the first instance revising the Regulation with stricter spill control requirements but extending the compliance date for certain facilities to October 31, 2007, in the second case providing relief to many qualified facilities within the regulated community, and in the last instance further extending the compliance date for certain facilities to July 1, 2009.  On October 1, 2007 the EPA Administrator signed a proposed rule to amend the SPCC Regulation, which includes a provision allowing a certain subset of facilities to fill in an SPCC plan template in lieu of preparing a site-specific SPCC plan.  Some facilities may now self-certify SPCC plans, as opposed to obtaining a Professional Engineer’s certification.  This presentation will review the scope of the SPCC Regulation and discuss compliance tools and educational resources available to the regulated community.  Alternative methods now available to facilities for compliance with the new requirements will be discussed, as well as the recently proposed amendments to the Regulation.

1,4-Dioxane – Regulatory Developments, Uses, Properties, Assessment, and Remedial Options
Ellen E. Moyer, Greenvironment, LLC, 258 Main Road, Montgomery , MA 01085 , US , Tel: 413-862-3452, Email: ellenmoyer@em-green.com

1,4-Dioxane (dioxane) has received increased attention at the Federal and State levels in recent years.  There is no Federal Maximum Contaminant Level for dioxane, however in 2008, the USEPA included dioxane on its Contaminant Candidate List.  Also this year, several states in the Northeast increased regulatory requirements relative to this chemical.  Regulatory requirements for dioxane in the Northeast states are reviewed.  Existing information on dioxane’s properties, uses, analysis, and remediation are also reviewed.  Dioxane’s physical and chemical properties include high water solubility, low tendency to adsorb, and low volatility.  These properties make dioxane difficult to analyze because dioxane will not readily leave the water phase.  Recently developed modifications of analytical methods (usually 8260 or 8270) must be employed to detect dioxane at the low concentrations that are often of concern.  Dioxane has been used in a wide variety of processes and products, but it was mainly used as a solvent stabilizer for 1,1,1-trichloroethane (TCA).  Because of its higher boiling point, dioxane tends to become concentrated in vapor degreasing wastes.  Other properties of dioxane are very different from those of TCA, which has implications for fate and transport and remediation.  Dioxane is more mobile, therefore plumes can be much larger than accompanying TCA plumes.  Remediation technologies that may work well for TCA may not work well for dioxane, and often a treatment train is necessary to treat all the contaminants of concern.  Granular activated carbon is typically ineffective for dioxane remediation, as are air stripping, air sparging, and zero-valent iron walls.  Although dioxane is thought to be relatively resistant to biodegradation, bioreactors have been used to treat dioxane at several sites.  Chemical oxidation technologies have proven to be effective for dioxane remediation.  To date, most full-scale dioxane remediation systems have used ozone with hydrogen peroxide or ultraviolet light with hydrogen peroxide.