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The Standard December 2013


Staff Members Complete Offshore Water Survival Training


Many of Environmental Standards’ oil and gas industry clients operate offshore.  To serve our offshore clients, two Environmental Standards staff members successfully completed Offshore Water Survival Helicopter Underway Egress Training (HUET) Modular Egress Training Simulator (METS) Model 5 training, which is required by many companies and recommended by the US Coast Guard prior to working offshore or traveling over water by helicoptor.

Senior Advisor Michael R. Green, Ph.D., MBA, CPEA, and Project Geoscientist Shaun M. Gilday, PMP completed four hours of classroom instruction followed by a written exam and then four hours of practical, in pool, simulator training.

Mike and Shaun successfully completed the training signifying they demonstrated the ability to:

  • escape from a downed helicopter in water
  • utilize personnel transfer baskets and swing ropes (necessary to board a platform from another vessel)
  • survive in offshore water

Classroom instruction included principals of water survival, emergency situations, use of personal flotation devices (PFDs), signaling equipment and pyrotechnics, helicopter safety, risks and precautions of swing ropes and personnel baskets, and survivor emergency first aid treatment.

Simulator (pool) training included:

  • helicopter water crash simulation escape
  • using a swing rope
  • water entry from a height
  • swimming while donning a PFD
  • group survival techniques including survival chain, group huddle, and signaling
  • rescuing a drowning or injured person
  • escaping fire on the water surface
  • floating for 5 minutes in full gear
  • life raft boarding and exiting
  • hypothermia protection

As if this was not extreme enough, the students wear flame retardant clothing (FRC) coveralls, water shoes, a helmet, and life jacket during the practical simulations.

According to Mike and Shaun, helicopter underwater escape training was the most intimidating exercise of the entire training course.  During the final stage of training, the simulator crashes into the pool then capsizes and sinks.  Students must brace for the impact, remain strapped to their seat while the simulator rotates upside down and sinks, knock out the window, remove their seatbelt, and then swim to safety while wearing full gear.  See a video of a typical last stage simulator run on YouTube:

Senior Consulting Geoscientist Paul Ressmeyer also previously completed the HUET training course.

Toxicity Testing Quality Assurance: Strengths and Weaknesses

This article is the third in a series of three by Senior Biologist James Markwiese, Ph.D., discussing the quality control and quality assurance measures for state-of-the-practice toxicity testing.  The series focuses on mechanisms to facilitate the establishment and documentation of quality procedures for toxicity testing laboratories.

To date, we have considered consequences of mischaracterizing (over- or underestimating) the toxicity of an environmental medium (soil, sediment, and water) and the role of laboratory audits in ensuring the quality of toxicity testing results.  This final segment will highlight the strengths and weaknesses of toxicity testing to highlight what can be expected regarding the use of toxicity test results for decision making.

Toxicity testing represents a powerful line of evidence for assessing impacts from chemical contaminants in the environment.  Toxicity test results are more ecologically realistic than basing conclusions on literature values because they incorporate site specificity and toxicity testing can provide transparent scientific input to decision-makers regarding certainty (vs. uncertainty), importance, and significance of results.  For example, literature-based estimates are typically based on exposures to single chemicals.  But because contaminated media typically represents a mixture of chemicals, bioassays can integrate effects from multiple stressors using site-specific media.

While there are many benefits from toxicity testing, there are also many hurdles to proper implementation.  Shortcomings associated with toxicity testing are myriad and include the following:

  • insistence on using only standardized toxicity tests
  • conducting testing because it is possible, not because it will provide necessary information/answer the questions that need answering
  • endpoints may be limited
  • test taxa may not be the same or even similar to those in the real world (different sensitivities)
  • failure to apply data quality objectives

Appropriate quality assurance and quality control can also be employed to reduce uncertainty and increase test acceptability.

If you have questions about toxicity testing quality assurance, please contact James Markwiese, Ph.D. at 865.376.7590.

Data Change Management

Have you ever arrived at work to find your project in the process of an audit or entering the beginning stages of litigation?  Have you ever questioned a data change, not knowing why it occurred?  If your answer is yes, you might next question whether or not you tracked changes to your data.  Think ahead with data change management as the solution to your headache.

What is data change management?  Data change management automates changes by capturing edits in electronic format, allowing reviews prior to application and retaining a record following the edits.

Data change management is a relatively new concept in the information technology world as more and more companies are faced with reporting challenges and increased scrutiny.  Reasons to use data change management on a project include: transparency assisting with database audits, effectively and efficiently managing data changes to existing data, resolving known issues, and assisting with normalizing data across multiple contractors or projects.

You may think this is a large work effort.  It is for some; however, Environmental Standards, Inc. has created a data change management process that provides data users a resource tool to automatically accept documented changes to existing data.  Data change management reports are used to inform the client about data history.
For more information about data change management, contact Information Technologies Principal Dennis Callaghan at 610.935.5577.

Teaming Up to Take on the Boiler MACT Compliance Challenge

Guest article provided by our strategic alliance partner, All4 Inc.

In August 2013, Environmental Standards, Inc. and All4 Inc. (ALL4) announced a strategic alliance between the two consulting firms.  After working side by side with each other on numerous high-profile environmental projects in recent years, the companies have now joined forces to offer their focused professional services.

ALL4 was founded in 2002 and is headquartered in Kimberton, Pennsylvania, with a regional office in Kennesaw, Georgia.  Employing over 35 full-time professionals, ALL4 provides a wide range of air quality consulting services for small and large industrial manufacturing clients, on an individual facility basis and at the corporate level, including:

  • Air Quality Compliance
  • Air Quality Permitting
  • Air Quality Dispersion Modeling
  • Continuous, Ambient, and Meteorological Monitoring
  • Environmental Program Management
  • Multimedia Regulatory Analysis
  • Climate Change

Our team is a passionate collection of engineers, scientists, and meteorologists that are environmental industry experts, ex-regulators, and life-long environmental consultants dedicated to our clients’ environmental needs.  While we have worked with clients providing “ala carte” services, our clients more often utilize our services on a continuous basis.  Clients utilize ALL4 services for:

  • ongoing, continuous support as their sole consultant – an extension of their staff;
  • individual projects;
  • “high end” strategic consulting and planning, and
  • unique, innovational projects.

For ALL4, much of 2013 has been spent working with our clients and regulators to develop strategies for complying with the federal Boiler MACT regulations (40 CFR Part 63, Subparts DDDDD and JJJJJJ).  Boiler MACT refers to two standards finalized in late 2012 by US EPA that regulate the emissions of certain air pollutants from boilers and process heaters.  These long-contested regulations will impact facilities across a variety of industrial and institutional sectors such as pulp and paper mills, chemical manufacturers, refineries, colleges, and universities.  The two separate regulations address emissions from boilers located at “major” and “minor” sources of hazardous air pollutants (HAP), and depending on the type of boiler at a given facility, the rules specify emissions limits; work practices such as conducting tune-ups and energy assessment; process monitoring; and fuel and emissions sampling requirements to demonstrate compliance with the rules.  Because of the complexities of the rules themselves, coupled with the variety of compliance options within the rules, ALL4 has been waist-deep working together with our clients to develop strategic compliance plans that consider input from all levels of a facility, from engineering, EHS, accounting, maintenance, and executive management, to corporate representation and oversight.

So what’s all the fuss?  US EPA estimates there are approximately 197,000 boilers in the U.S. that are affected to some degree by these rules.  Furthermore, the minor source MACT standard has a compliance date of March 21, 2014, and the major source MACT rule has a compliance date of January 31, 2016.  Facilities still have a lot of work ahead of them to demonstrate compliance with all of the initial performance testing, required tune-ups and energy assessment recordkeeping, and installation of add-on control devices, if necessary.  In many cases, modifications to existing boilers may require permitting, which can take several months to a year or more to accomplish; from planning the modifications, developing the permit application, time for agency review of the application, reviewing the draft permit, and time for public comment.  Therefore, the time to start preparing a compliance strategy is now.  Some specific considerations include:

  • Capital Costs: Many facilities have struggled to set plans for future expansion amidst the uncertainty of how much capital expenditure will be required to comply with the Boiler MACT regulations.  Now that the final rules are effective, the costs of compliance can be defined.  However, the process of defining that cost is not always simple because controlling certain pollutants such as CO could increase emissions of other pollutants such as nitrogen oxides (NOX), resulting in the potential applicability of New Source Review (NSR) permitting regulations.  In rare cases, modifications made for Boiler MACT purposes could trigger NSR permitting and control requirements for other pollutants and complicate the process of defining required capital costs.  Understanding how these rules potentially interact now will be critical in planning for other projects.
  • Resource Access: Many facilities will be required to install new particulate matter (PM) emissions controls or upgrade existing controls.  These installations and upgrades will be resource intensive.  They will require access to the equipment, access to engineering resources, and access to stack testing firms to measure PM emissions in support of the engineering efforts.  These resources are not unlimited, particularly when many facilities are drawing from them at the same time, as they likely will, to comply with Boiler MACT. Once again, the earlier these resources are addressed the better.
  • Construction Permitting Timelines: There are very few Boiler MACT modifications that will not require some level of Clean Air Act construction permitting.  Most states require permit application submittals for control device installations and air system modifications, particularly since with those modifications will come the regulatory provisions of Boiler MACT that will be incorporated into facility operating permits.  Like any other construction permitting process, it will take time to receive the appropriate permits authorizing installation and construction of control devices from state agencies.  Further, there are some facilities that have limited windows of time (shutdowns, rampdowns in production, etc.) during which these projects can be implemented.  When state permitting timelines are overlayed with the available windows to complete the physical changes and the above mentioned items are considered, the compliance deadlines may not look so far away.

One of the primary hurdles that facilities are encountering as they begin their compliance journey is the lack of robust historical data regarding stack emissions and fuel characteristics.  Obtaining reliable environmental analytical data on which to base critical decisions is the ultimate goal for regulated entities, parties involved in litigation, or businesses responsible for environmental compliance activities.  While ALL4 is very familiar with developing and managing stack testing programs, we recognized a gap in our expertise with respect to fuel sampling and the overall environmental analysis that is required for this portion of Boiler MACT.

Environmental Standards fills that gap through its Chemistry Quality Assurance group, which is the premier provider of solutions developed to provide compliant and usable environmental analytical data by integrating its services in a comprehensive program that defines the systems necessary to obtain reliable data.  In particular for Boiler MACT, Environmental Standards develops and implements a Quality Assurance Project Plan (QAPP) that leads to a consistent quality of field sampling efforts and the generation of reliable analytical data.  Environmental Standards prepares project-specific QAPPs by carefully documenting the sampling and analysis quality assurance and quality control procedures necessary to achieve project data quality objectives.  This planning avoids common project pitfalls such as delays, excessive costs, and jeopardizing a client’s relationship with regulators.  Environmental Standards has the expertise to implement a site-specific fuel monitoring plan for Boiler MACT compliance.  Analytical results that are generated from the implementation of the QAPP become the basis for assessments and compliance decisions.  The degree to which data are valid can make the difference between a correct assessment and unnecessary efforts.  Environmental Standards examines raw data to determine if a particular analysis conforms to client, method, and regulatory agency specifications.  Data validation offers justification and reassurance that analytical data are usable for their intended purpose and will withstand agency scrutiny.

A compliance strategy will vary based on the facility and the types of boilers.  However, ALL4 has developed a flexible, common approach for developing Boiler MACT strategies that includes the following:

  1. Identify applicable boilers and classify into subcategories based on:
    1. Fuel and design type
    2. New vs. existing sources
    3. Unit size (rated heat input capacity)
  2. Identify applicable emission limits and compliance requirements:
    1. Review existing stack testing, continuous emission monitoring system (CEMS), and fuel sampling data to benchmark against limits (with assistance from Environmental Standards as described above)
    2. Review compliance requirements and options related to performing stack testing, operating CEMS, and conducting fuel analysis
    3. Identify work practice standards
    4. Determine if controls or process modifications are required to comply
    5. Review current planned capital projects
  3. Prepare Air Permitting Strategy:
    1. Consider schedule
    2. Establish a baseline emissions inventory
    3. Review recent projects and permitting history for contemporaneous increases and decreases and other inventory considerations such as debottlenecking as it relates to changes in steam demand
    4. Review the status of current air permit (In the renewal phase? Recently issued? Will it need to be re-opened?)
    5. Evaluate NAAQS considerations related to Boiler MACT projects based on previous air dispersion modeling or conduct modeling as part of the Boiler MACT strategy.

The compliance dates for Boiler MACT are approaching.  Will you be ready?  Do you have the data available to make informed and sometimes tough decisions?  Whether you are spinning your wheels in the midst of your Boiler MACT compliance planning, or if this is the first time you have heard of Boiler MACT, Environmental Standards and ALL4 can guide you through the compliance journey.

Split Sample Discrepancy: A Forensic Data Review

Environmental Standards chemists were retained to assist an industrial client with an investigation and forensic data review.  The client had received split sample results from the on-site laboratory and a regulator laboratory that were vastly different.  The samples were analyzed for toxicity characteristic leaching procedure (TCLP) for arsenic.  TCLP is meant to simulate the potential leaching from a waste sample when disposed of in a landfill.  It is analyzed to classify whether a sample is hazardous or not.  Results that are < 5 mg/L are considered non-hazardous and can be disposed of in a non-hazardous landfill.  Results that > 5 mg/L must have additional chemical treatment performed prior to disposal or need to be disposed of in a landfill permitted to accept waste classified as hazardous.

In this case, the on-site, project laboratory reported results that were < 5 mg/L and the sediment was hauled to the landfill where it was disposed.  Subsequent to the disposal, the regulator laboratory reported split sample results that were > 5 mg/L.  Regulators threatened to stop operations on-site which could delay the entire timeline for the project and be very costly for the client.  Which results were correct?  Was hazardous sediment disposed of in a non-hazardous landfill?  Environmental Standards was retained to help answer these questions and lead the quality assurance investigation.

As part of the investigation, raw data packages were reviewed from both laboratories.  No preparation, dilution, analytical errors or issues were identified during the review of the raw data packages.  After ruling out analytical issues, the investigation honed in on the TCLP extraction procedure performed.

Review of the TCLP extraction logs revealed that the laboratories were performing the TCLP extraction using different TCLP fluids; the fluid determination step is detailed in the method.  Essentially, the fluid is determined based on the pH of the sample after the addition of 1N HCl and heating the sample for 10 minutes.  After the addition of acid, the on-site project laboratory recorded pH values that were > 5 and selected fluid #2.  Alternatively, the regulator laboratory recorded acidic pH values < 5 and selected fluid #1.

By design, the TCLP method (SW-846 Method 1311) is a prescriptive method.  Because the method is used to classify hazardous waste, it must be exactly followed.  How were both laboratories performing this prescriptive method and determining different fluids to use during the extraction?

In order to answer this question, Environmental Standards recommended a pH study wherein the laboratories swapped samples and performed the fluid determination step of the method.  The on-site laboratory again recorded pH values > 5 and selected fluid #2 for all samples.  The regulator laboratory recorded pH values < 5 for all but two of the samples.  For the two samples, the regulator laboratory recorded pH values > 5, this constituted a switch in the pH fluid for these two samples.  In discussions with the laboratory, the fluid determination step was performed by the same personnel using the same exact protocol.  The switch in pH values and hence a switch in the TCLP fluid selected could not be explained.  It was noted that although the method is prescriptive, some of the language in the method may be interpreted differently by different people and that the method lacked specificity in several areas.

Due to the switch in fluid by the regulator laboratory for two of the samples, the regulators agreed to stand behind the on-site project laboratory results.  The sediment was deemed not to be hazardous and operations on-site continued without interruption.  Environmental Standards chemists quickly helped to identify the aspect of the analysis that was leading to the different results and worked with both laboratories, the regulators, and the responsible party to bring the issue to a conclusion that satisfied the regulators and allowed the project to continue without interruption.

Baseline Analytical Guidance and Requirement Across States

A number of states and coalitions/guidance bodies have developed recommended or required baseline and post completion analytical lists for horizontal drilling.  Environmental Standards has compiled a sampling of these lists from the organizations listed below.  Additional details and analytical method specifications are available from our chemistry department.  In addition to the laboratory based methods, some of these organizations have also required or recommended field parameters that are to be measured.  Our geosciences department has complete information and guidance on the field monitoring and sampling requirements.  For more information, contact Senior Technical Chemist David Gratson at 281.752.9782.


Measurement of Radionuclides – Part 2: Radon in Produced Gas

In the previous article we discussed the basic components of the PA DEP study to evaluate the potential association of Naturally Occurring Radioactive Materials (NORM) and Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) with oil and gas activities.  This PA DEP study includes the analysis of natural decay chain radionuclides in produced and flowback water, drilling waste, and associated equipment.  The sampling and analysis plan in that study includes a short discussion for the monitoring of TENORM in ambient air and natural gas.  The most likely sources of radionuclides in the gas phase would be radon, though there are other NORM species that have some volatility, but these would generally require high temperatures or particulate formation.  Radon is a noble gas with significant vapor pressure, but relatively low water solubility.  Many homeowners are familiar with radon measurement via basement monitoring.  Basements and mine adits are areas where humans are most commonly expected to be exposed to radon due to the emanation from the source rock/soil.  Without an on-going supply of radon in the gas phase via decay from its radium predecessor, exposure would be acute, due to the short half-life of each of the radon radionuclides associated with NORM.  The common approach for measurement of radon in household basements entails adsorption of radon gas on activated carbon, followed by gamma analysis in the laboratory.  Scintillation analysis has also been used, but the charcoal canister approach is the most common for home monitoring.  The atmospheric gas (basement environment) matrix is much less complex than an environment that contains soil/water/biota/natural gas; this provides for a relatively simple adsorption and analysis procedure via activated carbon canisters.  However, a hydrocarbon-rich wellhead is a much more complex matrix containing hydrocarbons, water, and potentially other elements that could adsorb to the charcoal.

Measurement of concentration or flux of radon in this hydrocarbon rich environment requires accurate measurement of the amount of gas (or gas per area) to which the activated carbon is exposed.  In many situations this is complex, as one must measure both the volume and/or flux of gas to which the canister had been exposed, and also ensure that the activated carbon has not become saturated with radon and/or other sorbed chemicals.

All radionuclides are dynamic analytes.  In the case where radon is entrained in the hydrocarbon gas produced at a well, blended, and transported, the decay of radon during this journey must also be considered.  A first step in this evaluation is to compare ratio of the half-life of radon to the flow rate and residence time of the gas.  In many cases a significant amount of radon will decay to a non-volatile radionuclide within this system and radon would be an unlikely contaminant in the final product gas.  Decay of radon during transport does mean there is potential for the decay product to be plated on the carrier system (piping).  Thus the dynamic nature of radon production, on-going decay, the relatively complex matrix, and the need to measure the volume of gas to which the adsorption device was exposed, all complicate radon measurement in this particular environment.

This dynamic system with radionuclide decay, range of half-lives, solubility, and sorption of each decay-chain member is what makes radionuclide measurement, fate and transport, and risk modeling complicated.  It is these same principles that are at work with the fate and transport of the fission products cesium-137 and strontium-90, released during and after the Fukushima, Japan event in 2011.  In a future article we will discuss the fate, transport, and accumulation of these radionuclides as a result of the Fukushima event.

Marcellus Shale Infrastructure Growth Continues

Gas production in Pennsylvania and West Virginia has increased over 50% for the first half of 2013 compared to the same time period last year (US Energy Information Administration).  The increase in production is due to new infrastructure (pipelines and compressor stations).  Several projects from 2012 have aided in the expansion of the production capacity of Pennsylvania and West Virginia.  Those projects include: Equitrans pipeline between Wetzel County, West Virginia, and Greene County, Pennsylvania; the installation and operation of four new compressor stations by Dominion Transmission that provides capacity to an interconnect with the Texas Eastern Transmission Line; and a new Equitrans compressor station in Monongalia County, West Virginia.  Additional growth in West Virginia is forecast as Texas Eastern plans to build a pipeline lateral to Dominion’s Natrium processing plant in West Virginia.

In related news, Williams Companies, Inc. is teaming with Boardwalk Pipeline Partners, LP to build the Bluegrass Pipeline from the Utica and Marcellus shale plays in Ohio, West Virginia, and Pennsylvania to processing and storage facilities in Louisiana.  In a similar teaming agreement, the Pittsburgh Business Times reports that Hess Corporation and PVR Partners, LP are joining forces to build and operate a 45-mile pipeline to move gas out of the Utica Shale.  The capacity to move the gas is slowly catching up with the supply.