ASTM Guide for Green and Sustainable Site Assessment and Cleanup

ASTM International Committee E50 on Environmental Assessment, Risk Management and Corrective Action is developing a proposed standard guide in response to requests to minimize greenhouse gases and resource use during site cleanup. Proposed standard WK23495, Guide for Green and Sustainable Site Assessment and Cleanup, is an effort to help the regulated community to develop more sustainable ways to balance the social, environmental and economic aspects of a cleanup operation. Work on the new standard is being guided by a task group on green and sustainable corrective action within Subcommittee E50.04 on Corrective Action, a part of ASTM International Committee E50 on Environmental Assessment, Risk Management and Corrective Action.

The effort to develop a new standard began in 2009 when the U.S. EPA requested a guide incorporating best management practices that minimize energy and water usage, the consumption of materials that emit greenhouse gases, waste generation and impacts on water resources, land and ecosystems.

The Standard is expected to include sections covering planning and scoping requirements for green and sustainable corrective actions, as well as elements that characterize greener, more sustainable approaches to remediation; the proposed standard includes a scalable, three-tiered decision process similar to ASTM’s risk-based corrective action guides.

The three-tiered process consists of a matrix where users can choose from screening, qualitative and quantitative evaluations, or tiers, and environmental, societal and economic categories. The proposed standard will also describe processes for monitoring, tracking and documentation. Finally, the proposed standard will include appendices with examples of the decision-making process, information about off-the-shelf technologies for green cleanup and references, and information from state programs about green and sustainable processes.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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Review of Pulp - Paper Industry NESHAP and NSPS

EPA's Office of Air Quality Planning and Standards (OAQPS) has initiated an integrated NESHAP Risk and Technology Review for Pulp and Paper Industry and Chemical Recovery Combustion Sources, and a NSPS review for Kraft Pulp Mills. Section 112(f)(2) of the Clean Air Act directs EPA to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards, and to determine if additional standards are needed to reduce residual risks, to be completed 8 years after promulgation. Section 112(d)(6) of the CAA requires EPA to review and revise the MACT standards, as necessary, taking into account developments in practices, processes and control technologies, to be done at least every 8 years.

The NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (Subpart MM) was promulgated in 2001 and has not been reviewed. Similarly, the NESHAP for the Pulp and Paper Industry (Subpart S) was promulgated in 1998 and also has not been reviewed. Section 111(b)(1)(B) of the Clean Air Act mandates that EPA review and, if appropriate, revise existing NSPS at least every 8 years. The Kraft Pulp Mill NSPS was promulgated in 1978 and is in need of review. This NSPS component of the review will include evaluating existing emission limits for particulate matter, total reduced sulfur, and opacity and evaluating the appropriateness of developing emission limits for other pollutants such as sulfur oxides, nitrogen oxide, and carbon dioxide.

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HUD Section 50 Section 58 Environmental Review & Environmental Assessment

The U.S. Department of Housing and Urban Development (HUD) requires environmental reviews for housing projects to be completed prior to approval of financial assistance. The objective of the review process is to ensure that due diligence has been undertaken in identifying potential impacts, including both environmental and non-environmental impacts, associated with projects that use HUD funds. An Environmental Review required by HUD is not equivalent to a Phase I Environmental Site Assessment.

The HUD Environmental Review process is driven by two regulations: 24 CFR Part 50 and 24 CFR Part 58. Part 50 pertains to the Department of Housing and Urban Development and those entities that have legal responsibilities to the Secretary of the Interior. In most cases this is HUD itself and state/city housing authorities. Part 58 pertains to those entities that do not have legal responsibilities to the Secretary (e.g., community housing and “faith-based” organizations).

The level or extent of the HUD Environmental Review is dependant on the type of proposed work, the number of units, or a percentage of total area can be a threshold. Under both Part 50 and Part 58, exemptions, categorical exclusions, documented categorical exclusions exist.

Caltha LLP provides expert consulting services to public sector and non-profit sector clients around the county to address HUD Environmental Review and HUD Environmental Assessment requirements.

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Endosulfan Uses To Be Ended Under FIFRA

U.S. Environmental Protection Agency (EPA) is taking action to end all uses of the insecticide endosulfan in the United States. Endosulfan, which is used on vegetables, fruits, and cotton, was determined to pose unacceptable neurological and reproductive risks to farmworkers and wildlife and can persist in the environment. EPA is currently working out the details of the decision that will eliminate all endosulfan uses, while incorporating consideration of the needs for growers to timely move to lower-risk pest control practices.

Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA must consider endosulfan’s risks and benefits. While EPA implemented various restrictions in a 2002 re-registration decision, EPA’s phaseout is based on new data and scientific peer review, which have improved EPA’s assessment of the ecological and worker risks from endosulfan. EPA’s 2010 revised ecological risk assessment reflects a comprehensive review of all available exposure and ecological effects information for endosulfan, including independent external peer-reviewed recommendations made by the endosulfan Scientific Advisory Panel.

Caltha LLP provides expert environmental review consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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Chemical Assessments On Hold Pending Review

US Environmental Protection Agency (EPA) is putting on hold four of its ongoing IRIS (Integrated Risk Information System) assessments pending a review of some of the underlying studies used in the assessments. EPA is holding these assessments due to a report from the National Toxicology Program (NTP) that outlines a recent review of a research study completed by the Ramazzini Institute, a lab in Italy that conducts animal testing to evaluate the potential cancer-causing effects of chemicals.

To ensure the agency’s chemical assessments are grounded in the soundest possible science, EPA undertook a thorough review of all ongoing and previous chemical assessments to determine which, if any, relied substantially on cancer testing from the Ramazzini Institute. EPA found six assessments that significantly rely on data from Ramazzini cancer studies: ongoing chemical assessments for methanol, MTBE, ETBE and acrylonitrile, and previously completed assessments for vinyl chloride and 1,1- dichloroethylene. EPA plans to continue its review to determine if any other assessments are significantly impacted.

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Revised Health Standard For Sulfur Dioxide - SO2

USEPA has issued a final new health standard for sulfur dioxide (SO2). EPA sets the one-hour SO2 health standard at 75 parts per billion (ppb), a level designed to protect against short-term exposures ranging from five minutes to 24 hours. EPA is also revoking the current 24-hour and annual SO2 health standards because the science indicates that short-term exposures are of greatest concern and the existing standards would not provide additional health benefits.

EPA is also changing the monitoring requirements for SO2. The new requirements assure that monitors will be placed where SO2 emissions impact populated areas. Any new monitors required by this rule must begin operating no later than Jan. 1, 2013. EPA is expecting to use modeling as well as monitoring to determine compliance with the new standard. The final rule also changes the Air Quality Index to reflect the revised SO2 standard.

The final rule addresses only the SO2 primary standards, which are designed to protect public health. EPA will address the secondary standard, designed to protect the public welfare including the environment, as part of a separate review to be completed in 2012.

EPA expects to identify or designate areas not meeting the new standard by June 2012.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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Proposed Minnesota Waste Injection Well

U.S. Environmental Protection Agency Region 5 has invited residents of Crow Wing County, Minnesota and surrounding area to comment on a proposed permit for a waste injection well. EPA has proposed issuing an injection well permit to Cooperative Mineral Resources of Brainerd, Minnesota so that it can test the feasibility of injecting water underground to mine iron-manganese ore. EPA seeks comments from the public before making a final decision on the permit.

The public comment period will run through June 25, 2010.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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