The Standard June 2015 - Environmental Standards, Inc.

THE STANDARD – JUNE 2015

Our Charlottesville Office is Moving

Please note the new location and mailing address for Environmental Standards, Inc.’s Charlottesville, Virginia office, effective July 1, 2015:

1412 Sachem Place, Suite 100
Charlottesville, VA 22901
434.293.4039

Use of Unmanned Aerial Vehicles in the Environmental Sector

Unmanned Aerial Vehicles (UAVs), sometimes referred to as drones, are well known for their military applications related to both reconnaissance activities and support for ground forces. More recently, consumer drones have been used to monitor beach erosion in Florida (view video on YouTube) and survey tree growth in England (YouTube video). Additionally, the University of Nebraska has developed a proof-of-concept in the use of drones to collect a water sample from a surface water body (YouTube video).

It is important to understand what capabilities these devices have and for what applications they are best suited. As an example, one of the more popular consumer drones, the DJII Phantom Vision, is reported to have an operating range of approximately 500 meters with a battery life of approximately 1 hour. The camera can record both still images and high-definition video. Additional sensors and cameras can be mounted to the device, but the resulting addition in weight reduces the flight range and time aloft.

In February 2015, the Federal Aviation Administration (FAA) announced proposed regulations that will allow routine use of small drones in the United States. The public comment period closed in April 2015.

Key components of the regulations are:

Unmanned aircraft must weigh less than 55 lbs (25 kg).
Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer.
At all times, the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.
Small unmanned aircraft may not operate over any persons not directly involved in the operation.
Daylight-only operations (official sunrise to official sunset, local time).
Must yield right-of-way to other aircraft, manned or unmanned.
May use visual observer (VO) but not required.
First-person view camera cannot satisfy “see-and-avoid” requirement, but it can be used as long as requirement is satisfied in other ways.
Maximum airspeed of 100 mph (87 knots).
Maximum altitude of 500 feet above ground level.
Minimum weather visibility of 3 miles from control station.
No operations are allowed in Class A airspace (18,000 feet and above).
Operations in Class B, C, D, and E airspace are allowed with the required ATC permission.
Operations in Class G airspace are allowed without air traffic control (ATC) permission
No person may act as an operator or VO for more than one unmanned aircraft operation at one time.
Proposes a microUAS option that would allow operations in Class G airspace, over people not involved in the operation, provided the operator certifies that he or she has the requisite aeronautical knowledge to perform the operation.

Unmanned aerial vehicles have the potential to be a useful tool in the collection of data for environmental activities, provided that the limitations for their use, as stipulated by the FAA, and the current hardware limitations are understood.

Dissolved Methane in Groundwater – A Measurement Uncertainty

Data variability of dissolved light gas analyses among laboratories has been observed by the oil and gas industry for years. The concentration of light gases, particularly methane, in domestic groundwater wells is a contentious issue resulting in multiple legal cases. The public and industry need data that can be relied upon for decision making.

Environmental Standards, Inc. was contracted by the Marcellus Shale Coalition (MSC) to conduct a study that would investigate and characterize the variability of dissolved methane concentrations in domestic groundwater wells. The study was conducted in a manner that meets scientific standards and included 15 participating laboratories, made up of 14 commercial laboratories and one state government operated laboratory.

Prior to receiving samples, each participating laboratory provided Environmental Standards with a completed Laboratory Key Elements Questionnaire. In total 102 questions were included in this survey that focused on laboratory practices as they related to the handling, storage, preparation, and analysis of dissolved light gases in the aqueous medium. Statistical and non-statistical data analysis of the laboratory practices questionnaire against the reported methane results was performed. Each participating laboratory also provided its internal standard operating procedures (SOPs) for sample receiving, sample preparation and handling, and analyzing dissolved methane in groundwater, as applicable. These SOPs were also reviewed by Environmental Standards for consistency and completeness. Based upon the 102 process questions and SOPs reviewed, there is a very broad range of laboratory approaches to the measurement of dissolved methane in water. No two participating laboratories analyzed methane exactly the same way.

The study entailed the collection of split samples from two domestic groundwater wells at two locations. Each laboratory analyzed the split samples, with each sample analyzed in triplicate, using its routine, internally-derived, dissolved light gas procedures. Sample analysis was requested on an expedited basis, with all analyses completed within 24-48 hours from the time the laboratory received the samples, or approximately 48-72 hours from sample collection.

Each laboratory completed the analysis for methane using its internal laboratory procedures. While there are several published analytical procedures for the analysis of dissolved light gases, and one current published state headspace method (e.g., PA DEP 3686) there is not currently a US EPA-published method for the analysis of dissolved light gases. For the published procedures that do exist (e.g., RSK SOP-175), they do not provide adequate specificity for a significant number of laboratory procedures that can substantially impact the quantitative analysis of samples. Confounding the issues associated with these gaps in the published procedures, is the fact that there is currently no standard reference material or certified reference material for dissolved light gases in water. Accordingly, each laboratory performing dissolved light gas analysis is tasked with developing specific internally-derived procedures with no accuracy assessment to rely upon.

The results of the study identified large variability across the 15 participating laboratories. Within Well 1, the reported methane concentrations ranged from 7,440 to 34,600 microgram per liter (µg/L). For Well 2, the reported methane concentrations ranged from 8,260 to 44,000 µg/L. Greater than 33% relative standard deviation (RSD) across the laboratories was noted for both study well locations. Figure 1 shows a graphical representation of the Well 2 reported results. This variability of reported concentrations verifies the MSC observations and concerns.

Based on the review of the dissolved methane data as compared to the varying laboratory procedures, no single procedure or variable provided evidence as to why dissolved methane concentration results may be higher or lower among laboratories.

The study recommendations include:

Using best practice procedures specific for instrument calibration, sample handling/preparation, analysis, and calculations;
Seeking collaboration from participating laboratories to develop a consensus procedure. Until such time as a consensus procedure can be developed, adopted, and demonstrated to have acceptable precision and repeatability, the usability of current dissolved methane concentrations, particularly at or near a regulatory limit, should be limited and well understood by the user;
Development of a certified performance sample. Pending the development of a dissolved phase light gases in water reference standard, the use of proficiency tests to assess the comparative performance of analytical methods, laboratories, and the individual analysts is also recommended; and
Performing additional studies such as repeat study at lower dissolved methane concentrations, sample collection study to determine how varying procedures affect dissolved methane concentrations, and another round robin study using a controlled dissolved gases analytical procedure developed by the MSC.

Turn Off the Tap! Helping the Planet and Your Bottom Line

A recent study by the 2030 Water Resources Group has determined that by the year 2030, water demand is expected to exceed current supplies by 40%. This startling prediction highlights one of the most important emerging concerns among industry today: Planet Earth is running out of fresh water.

Many consumer products require large amounts of water to produce. According to a variety of studies, it takes approximately 2.64 gallons of water to produce one 8.5×11 sheet of paper; 250 gallons to produce one 2-L bottle of soda; 1,860 gallons to produce one pound of beef; 3,000 gallons to produce one pair of jeans; and 39,000 gallons to produce the average domestic automobile. A large portion of that water is consumed to grow the plant materials or animal stocks used as raw materials for these products; however, a significant portion is also used in industrial processes such as material transport, pulp processing, dyeing, equipment cooling and lubrication, refrigeration, and sterilization/sanitation.

More and more companies are realizing the wisdom in adopting sustainable practices that minimize the use of fresh water. The reduction of overall processing costs allows for more competitive pricing of products and services. The reduction in front-end water usage can also reduce the costs associated with back-end treatment of contaminated water through conventional wastewater treatment processes.

There are a number of sustainable practices a company can adopt to achieve significant savings in their water management costs:

Perform a comprehensive water audit to identify and map water usage throughout the entire manufacturing process.
Recycle/reuse existing water; for example, capture cooling water from a refrigeration unit and divert it to use for hosing down livestock barns.
Use alternative sources of water; for example: rainwater collection from hard surfaces can be a significant source of fresh water, depending on climate. One and one-half inches of rain on a 50,000 square foot parking lot can produce 46,725 gallons of fresh water, which over time, can pay for the upfront costs of collection, storage, and distribution.

With current supplies of fresh water rapidly shrinking amidst seemingly insatiable demand, shortage or interruption of the water supply represents a material risk to almost every industrial and manufacturing process. Proactive companies have realized that sustainable water management practices can mitigate this risk, improve reputation, and improve the bottom line.

Contact Gary Yakub (610.935.5577) at Vitale Scientific Associates, LLC for more information.

Retail Stores Experiencing Increased Regulatory Scrutiny

For retail stores, dumping hazardous waste is a serious environmental issue. From home improvement stores to big box stores to grocery stores and pharmacy chains, the news often reports stories of court cases against various retail outlets for illegal dumping of hazardous waste. Stores have been fined anywhere from $2 million to $22 million.

The cases follow a common theme of illegally dumping hazmat products like batteries, paints, corrosive liquids, and e-waste into landfills or sewer drains. By and large these are not cases of retailers trying to save money by illegally disposing of regulated substances in the common trash. The issues are directly related to a lack of corporate oversight, and in particular, employee training. Although it appears the US EPA has identified and is focused on issues with retail stores, most organizations large and small across numerous industries struggle with waste disposal – be it e-waste in the form of antiquated computer equipment, universal waste in the form of batteries and fluorescent bulbs, or other potentially hazardous waste generated during periodic cleanouts.

In the case of one major retailer, according to a plea agreement with the US EPA, before 2004, workers at the retailer’s stores in California discarded household and pool cleaning products in dumpsters. They also disposed of liquids by pouring them down drains, which were connected to the local public water treatment plant.

In response to the increased scrutiny, many retailers have created programs to remain in compliance with regulatory guidelines. In 2006, Wal-Mart created an environmental compliance program, which includes implementing procedures to support enhanced compliance. For instance Wal-Mart implemented a “color-coded bucket system”, which allows employees to scan the labels of potentially hazardous items that have been returned, damaged, or spilled, to determine which of several buckets to use for their safe disposal (May 2013, Wall Street Journal). The products include products as seemingly innocuous as mouthwashes and nail polishes.

For companies engaged in activities that fall under a regulatory agency, Environmental Standards, Inc.’s auditors provide technical support and focused guidance based on over 30 years of industry experience. We help our clients identify environmental compliance issues and implement programs and procedures to develop the employee buy-in that is integral to ongoing compliance. For more information, please contact
Tim Cory, P.G. at 434.293.4039 or Shaun Gilday, PMP, CPEA at 610.935.5577.

New Regulations for Bakken Crude Oil Transported by Rail

There has been an increased amount of news reports regarding crude-oil-by-rail regulation. On May 1, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Administration, in coordination with Canadian authorities, issued a final US DOT rule governing the transportation of flammable liquids by rail (i.e., crude oil). The order represents the culmination of 2 years of calls for enhanced regulation and public outcry for stricter standards arising from the tragic Lac-Megantic incident, in which 47 people were killed in the aftermath of a crude oil train derailment.

Recently, two Environmental Standards auditors and compliance specialists,
Dr. Michael Green and Mr. Shaun Gilday, spent significant time in North Dakota – logging 20 straight days and over 3,000 vehicle miles – while conducting several laboratory audits and field sampling audits along the crude oil transportation path (from well head to refinery).

As discussed in a series of blog posts by Environmental Standards, crude oil from the Bakken region of North Dakota (i.e., shale oil) has been reported to be more volatile than traditional crude oils from the US. At the heart of this increased volatility is the presence of high amounts of light end gases (i.e., methane, ethane, propane, butane) that are present in the crude oil mixture. In fact, the initial boiling points of these crudes are quite low; some Bakken crudes may begin to boil on an average warm summer day. Curiously, these oils that have high light end gas content display properties that cause experienced oil and gas industry professionals to compare them to a can of soda when shaken.

The US DOT rule comes just on the heels of another new rule promulgated by the North Dakota Industrial Commission (NDIC) which became effective on April 1, 2015, in which the NDIC required that anyone who offers crude oil for transportation must “treat” the crude to remove some of the light ends thereby lessening the volatility.

The recent US DOT rule does four things:

Unveils a new, enhanced tank car standard and an aggressive, risk-based retrofitting schedule for older tank cars carrying crude oil and ethanol;
Requires a new braking standard for certain trains that will offer a superior level of safety by potentially reducing the severity of an accident, and the “pile-up effect”;
Designates new operational protocols for trains transporting large volumes of flammable liquids, such as routing requirements, speed restrictions, and information for local government agencies; and
Provides new sampling and testing requirements to improve classification of energy products placed into transport.

As the crux of the matter centers around the volatility of crude oil, proper handling and management of samples, from collection through analysis, is extremely important. In order to obtain representative results, measures must be taken to minimize the loss of the volatile components from the crude during field sampling, transport to the laboratory, and testing in the laboratory. Published work has documented that up to a 2-psi difference in true vapor pressure (the measurement of light ends in crude oil) can result just from using different sampling equipment alone. A 2-psi difference may not seem like much; however, in North Dakota it can mean a large monetary fine (e.g., a $12,500 per day fine, up to $1,000,000 total) for willful improper classification that results in significant injury.

Environmental Standards’ Senior Advisor Dr. Mike Green served on the industry team that developed the ANSI/API recommended practice for Classifying and Loading of Crude Oil into Rail Tank Cars (RP3000) which provides information for consideration when developing a crude oil sampling and testing plan – a requirement of the new US DOT rule (see number 4). Both Dr. Green and Mr. Gilday stand ready to provide assistance to companies that are in need of support in developing sampling and testing plans or desire to have an assessment performed on the implementation of those plans vs. applicable regulatory, industry and internal company requirements. Dr. Green and Mr. Gilday will be traveling to North Dakota again in the coming months. If you are a producer, a transporter of crude, or a buyer of oil from the Bakken or other shale plays, contact Mike (mgreen@www.www.envstd.com) or Shaun (sgilday@www.www.envstd.com) to assess your organization’s compliance with recent crude oil-by-rail regulations.

US EPA Releases Draft Report on Hydraulic Fracturing

On June 4, 2015, the US EPA released a much-anticipated draft report on the effects of hydraulic fracturing (fracking) on drinking water supplies. The draft report is titled “Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources” and it was created in response to a congressional request from 2010. The study concluded that the US EPA did not find evidence that fracking has led to widespread, systemic impacts on the drinking water resources of the United States. However, the US EPA did identify specific instances where fracking led to impacts on drinking water resources, including contamination of drinking water wells, but the number of identified cases was small compared to the number of hydraulically fracked wells.

The study focused on the hydraulic fracturing lifecycle, which includes five main activities: water acquisition, chemical mixing, well injection, flowback and produced water, and wastewater treatment and waste disposal. The report also specifically pointed out the activities related to hydraulic fracturing that were not addressed in the study. These activities include: acquisition and transportation of constituents of hydraulic fracturing fluids besides water (sand mining and chemical production); site selection and well pad development; other infrastructure development (road, pipelines, and compressor stations); site reclamation; and well closure.

The study went on to say that there are above- and below-ground mechanisms by which hydraulic fracturing activities have the potential to impact drinking water sources. These mechanisms include: water withdrawals, spills of fracking fluids and produced water, fracturing directly into groundwater drinking water sources, below-ground migration of liquids and gases, and inadequate treatment and discharge of wastewater. The US EPA did not offer a probability or likelihood of groundwater contamination in the report.

While the study notes the rarity of fracking having an effect on drinking water sources, it also presents some limitations of the study. The US EPA identified that there is insufficient pre- and post-fracking data on the quality of drinking water resources which inhibits a determination of the frequency of impacts. Other limiting factors cited by the US EPA include: the presence of other causes of contamination, the short duration of existing studies, and inaccessible information related to fracking activities.

Non-cancer Health Hazards of PCB Congeners to be Evaluated

The US EPA Integrated Risk Information System (IRIS) recently released “Scoping and Problem Formulation for the Toxicological Review of Polychlorinated Biphenyls (PCBs): Effects Other Than Cancer” (April 2015). Based on this scoping document, a new IRIS assessment will evaluate non-cancer human health hazards associated with PCB exposure through oral, inhalation, and dermal routes. At present, the IRIS database contains separate quantitative oral reference doses (RfDs) for Aroclor 1016 and Aroclor 1254, a qualitative discussion regarding non-cancer effects of oral exposure to Aroclor 1248, and cancer slope factors for environmental PCB mixtures via oral and inhalation routes. As stated in the document, there is no IRIS RfD for complex PCB mixtures in general, nor is there an IRIS inhalation reference concentration (RfC) for PCBs.

The new IRIS assessment could significantly impact the regulated community. First, the additional consideration of these potential non-cancer health impacts could only serve to lower the RfD. Secondly, the assessment could lead to regulation based on PCB congeners rather than Aroclor mixtures. The scoping document identifies one of the key issues to the assessment as “Impact of Congener Profile on the Toxicity of PCB Mixtures” and discusses the possible differences in toxicity between commercially available PCB mixtures (e.g., Aroclors) and “environmental” PCB mixtures (e.g, altered through volatilization, microbial degradation, and/or metabolic processes).

The US EPA requested and received public comment on the key issues identified in the scoping document. A number of the key issues were discussed during the June 17-18, 2015 IRIS Bimonthly Public Science Meeting in Arlington, Virginia. US EPA staff acknowledged the challenges in assessing the human health risks of exposure to mixtures of PCBs, but will continue to move forward with their efforts to craft an IRIS assessment.

Environmental Standards, Inc. will keep an eye on this important issue and will provide an update when additional information is available.

Covering Liabilities with Field Audits

When most people discuss audits in the environmental arena, they think of laboratory audits, facility audits, or environmental data audits. In short, the audits mentioned are focused on the data and generation of defensible data and they typically occur after the samples have been collected. One critical aspect that is often overlooked from an audit standpoint is the collection of the samples. Sample collection (soil, groundwater, surface water, air, waste) is the first step in the generation of environmental data. You can use the old adage from the computer modeling and groundwater modeling professions – “junk in equals junk out”. The same can be applied to environmental sampling. If your samples are not collected properly, the resultant laboratory data is of little use and could lead to faulty conclusions and potential financial implications.

You may ask, how bad can the sampling issues be? In short, they can be quite alarming. A few examples of issues identified during review of sampling activities include:

improper well purging whereby samples are collected before the well has been adequately purged;
no Standard Operating Procedures (SOPs) for sampling which resulted in inconsistent or faulty sampling techniques;
improper decontamination that may lead to cross contamination between sampling locations;
sample tubing being laid on the ground surface which could introduce impacts into the well from cross contamination;
improper waste management that could lead to increased liabilities;
incorrect sample preservation; and
incomplete Chain-of-Custody records.

All of these issues could lead to faulty laboratory results before the samples are even shipped to the laboratory.

How do you know your sampling teams or sampling contractors are collecting quality samples? One way to assess the quality of sampling is with a field audit, whereby the sampling teams are audited against the project control documents (SOPs, work plans, quality plans, and standard practices). A field audit provides for a critical review of the sampling and custody procedures by a third party. A field audit generally evaluates the following field activities:

planning,
preparation,
health & safety,
bottleware selection and use,
sample collection,
preservation of samples,
custody of samples,
waste management, and
transportation of the samples to the laboratory.

Field audits identify processes that need improvement or deviate from SOPs and best practice guidelines. After a field audit, Environmental Standards will provide a detailed report listing its findings and corrective action recommendations. Field sampling procedures will improve, resulting in the generation of higher quality of data. For more information or to arrange a field audit, contact Stephen D. Brower, P.G. at 610.935.5577.