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October 1st, 2015

Midwest Environmental Compliance Conference

MECC-rotate-gif

 

The first annual Midwest Environmental Compliance Conference (MECC) will be held October 29-30th at the Chicago Marriott O’Hare and will focus on EPA’s Region 5 (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin, and 35 tribes).

MECC events are hosted by state business and manufacturing associations and supported by U.S. EPA and State Agencies. These Midwestern environmental conferences:

  • Provide an insider perspective on key regional issues
  • Offer valuable, up-to-date information on rapidly-changing areas of regulation and law
  • Create a forum for valuable networking with regulators, clients and potential clients/customers
  • Foster meaningful, professional conversation with federal, state and local regulators
  • Deliver great speakers and thought leaders with unique insights, real experience, and a seasoned perspective
  • Provide an environmental “boot camp” training opportunity for those relatively new to environmental compliance and permitting or new to a particular environmental medium

 

Chicago’s conference will include sessions featuring administrators from U.S. EPA and state environmental agencies, including Illinois Environmental Protection Agency (IEPA), Indiana Department of Environmental Management (IDEM), and Wisconsin Department of Natural Resources (WDNR).

Some of the conference sessions will discuss:

  • U.S. EPA Regional Priorities
  • Emerging Water Issues
  • Hot Topics in Remediation and Waste Materials Management
  • Regional Air Issues Roundtable
  • Compliance Auditing

More information, the conference schedule, and registration can be found at mecconference.com.

May 19th, 2015

It’s TACO Tuesday!

All cleanup programs in the state of Illinois are based on TACO limits, but not everyone knows exactly what TACO IEPA-logomeans – or why it makes cleaning up your property easier.

TACO is an acronym for “Tiered Approach to Corrective Action Objectives.”  Prior to the implementation of TACO standards in the mid-1990s, the Illinois EPA (IEPA) took a “one size fits all” approach to cleaning up contaminated properties.  All sites, regardless of their location, use, contaminants, etc., had to be cleaned up to the same standards.

This regulatory climate changed as cleanup programs across the U.S. continued to mature.  Environmental agencies realized that cleaning up an industrial property that was only going to be used for a parking lot was a lot different than cleaning up a former gas station to become apartments.  Remediation objectives became risk-based and site-specific.

Today, TACO takes into account three main components to determine environmental risk:

  1. Contaminant(s) – ie: chemicals
  2. Exposure route(s) – eg: air, drinking water, etc.
  3. Receptor(s) – eg: people, plants, or animals

Through both the Site Remediation Program (SRP) and Leaking Underground Storage Tank (LUST) program, environmental consultants such as Gabriel conduct a site investigation consisting of soil, groundwater and/or vapor testing.  Once these results are analyzed for each of the above components, the environmental consultant can work with the IEPA project managers to determine the best way to clean up the property.  The three most common risk management tools are:

  1. Active remediation – eg: contaminated soil removal; bioremediation; chemical remediation; etc.
  2. Engineered barriers – eg: asphalt parking lot, concrete floor, building control technologies (BCTs), etc.
  3. Institutional controls – eg: drinking water restriction, commercial/industrial use restriction, etc.

Once a property owner has satisfied the applicable program requirements and documented that the contaminants had either been reduced below TACO standards or controlled through engineered barriers or institutional controls, the IEPA will issue a No Further Remediation (NFR) Letter.

These TACO standards mean that you’ll often be able to clean up your property with less expense and hassle, which promotes progressive reuse of contaminated property.

If you have more questions about how the TACO regulations work, contact John Polich, P.E. at jpolich[at]gabenv.com or 773-486-2123.

May 4th, 2015

Gabriel is considering launching a webinar series. We need your feedback.

webinar clipartDue to the popularity of our ongoing seminar series, Gabriel is considering launching a webinar series on various environmental issues.  We understand that not everyone can easily join us in person at our Chicago headquarters.

Would you be interested in attending free webinars hosted by Gabriel?  We welcome your opinions in the quick 7 question survey below:

https://www.surveymonkey.com/s/H2BJ3TJ

Thank you for your feedback. We will keep you posted on topics and dates for upcoming webinars, depending on results of the survey.

Survey will close May 8th, 2015.

March 26th, 2015

When to conduct vapor sampling

When working to get a No Further Remediation (NFR) letter through the Illinois EPA’s Leaking Underground Storage Tank (LUST) program, an investigation of three pathways of concern must be conducted: soil, groundwater, and vapor.  IEPA has required soil and groundwater evaluations for over 20 years, but they only recently started requiring vapor intrusion assessments.

Because vapor assessments are not required for all LUST Incidents, IEPA has published a flowchart to help determine when soil gas sampling is necessary:

lust-flowchart

Gabriel’s Project Managers work with the Illinois EPA’s LUST division to determine the appropriate sampling for each specific site, including if this indoor inhalation exposure route must be investigated.

The Site Remediation Program (SRP) also requires the investigation of vapor in certain circumstances, but because the contaminants of concern vary greatly within the SRP program, they don’t have a similar flowchart established.  Each site is addressed on a case-by-case basis.

If you have any questions about vapor assessments or a specific site, contact John Polich at 773-486-2123 or jpolich[at]gabenv.com.

February 25th, 2015

Certified Hazardous Materials Manager (CHMM) Overview Course

Gabriel is pleased to sponsor the upcoming Certified Hazardous Materials IHMM logoManager (CHMM) Overview Course at DePaul University.

This course provides a thorough overview of the major topics and concerns in hazardous materials management.  Completion of this course will enable attendees to take the CHMM exam, satisfy training requirements, enhance their competence in the profession, and get updated information.

This three-day course will be taught by approximately 25 hazardous materials management professionals who will cover the following topics:

  • Hazardous Waste Treatment Technologies
  • Environmental Law & Regulation Overview, including Liability and Compliance
  • Industrial Toxicology
  • Chemistry of Hazardous Materials, Proper Laboratory Practice and Data Validation
  • RCRA
  • RCRA Corrective Action
  • Hazardous Waste Storage
  • Storm Water & Oil Pollution Prevention Act
  • Management of Underground Storage Tanks
  • Clean Water Act (CWA) & Safe Drinking Water Act
  • National Contingency Plan/Worker Right-to-Know
  • Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
  • OSHA Requirements Pertaining to Hazardous Materials Management
  • Toxic Substance Control Act (TSCA)
  • Hazardous Materials Transportation Act (HMTA) and Hazardous Waste Transportation
  • The Clean Air Act (CAA) and 1990 Amendments
  • Radiation Principles
  • Facility Environmental Audits and Environmental Site Assessments
  • Waste Minimization and Pollution Prevention
  • Superfund:  The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) with 1986 Amendments (SARA)
  • Emergency Planning and Community Right-to-know Act of 1986 (EPCRA)
  • Environmental Management Principles & ISO 14000
  • NEPA
  • Incident Response
  • Hazardous Waste Treatment Storage and Disposal
  • Oral Sample Examination

 

Comprehensive 3-Day Overview Course
March 25 – 27, 2015
8:30 am to 5:00 pm daily

Registration Deadline: March 1, 2015

Cost for course $595

Groups of three or more from the same organization receive a 10% discount.  Alliance of Hazardous Materials Professionals (AHMP) attendees for recertification receive a 25% discount.

DePaul University
McGowan South Room 401
1110 W. Belden Ave.
Chicago, IL  60614

Offered by:
DePaul University
Department of Environmental Science and Studies
in cooperation with the Chicago Chapter of the Alliance of Hazardous Materials Professionals
and
Gabriel Environmental Services

 

For registration and other information, visit margaretworkman.weebly.com/chmm-course-information

 

For Further Information:
General
Margaret Workman
DePaul University

mworkman[at]depaul.edu
(773) 325-7445

Course Content
Steven Sawyer, CHMM
Gabriel Environmental Services

ssawyer[at]gabenv.com
(773) 486-2123

Examination
Institute of Hazardous Materials Management

www.ihmm.org
(301) 984-8969

 

July 25th, 2014

EPA Closes Comment Period for AAI Rule Amendment

Effective July 17th, 2014, U.S. Environmental Protection Agency (EPA) has closed the comment period for its proposed rule amending the All Appropriate Inquiries (AAI) regulations.  This proposed change would remove reference to the older Phase Iepa_logo2 Environmental Site Assessment ASTM standard (E1527-05) and confirm that Phase I assessments should be completed to the current ASTM standard (E1527-13).  EPA believes this change would promote the use of the current standard and reduce any confusion by having two standards in the regulatory reference documents.

EPA confirms that any Phase I’s conducted between November 1, 2005 and the date of the proposed rule implementation that were conducted to the ASTM E1527-05 standard would comply with the All Appropriate Inquiries regulations.

Only five comments were submitted during the comment period, with four in favor of the rule change for clarification purposes.  The one negative comment urged the EPA to continue allowing the use of 1527-05 in order to avoid the investigation of vapor as a pathway of concern.

EPA is reviewing the comments and will issue their final rule shortly.  Implementation of this amendment is expected to occur one year after the final rule is published in the Federal Register.

For further information about this proposed change, visit the EPA’s Proposed Rule webpage.

May 28th, 2014

HUD Adopts E1527-13 for all Phase I Requirements

The U.S. Department of Housing and Urban Development (HUD) has updated its guidance documents for the Office of Housing and Federal Housing Administration (FHA) to require the latest ASTM standard (E1527-13) effective May 16, 2014.  This change affects several guidance documents throughout Office of Housing/FHA, including, but not limited to, the Multifamily Accelerated Processing (MAP) Guide, the Condominium Project Approval and Processing Guide, Handbook 4600.1 REV-1, Section 232 Mortgage Insurance for Residential Care Facilities, and Handbook  4615.1, Mortgage Insurance for Hospitals.

HUD specifically details the addition of the term CREC (Controlled Recognized Environmental Condition) and inclusion of vapor to the migration pathway as important reasons to require ASTM E1527-13.

“The new CREC definition will result in some environmental conditions being listed as CRECs if they have been remediated to restricted levels, as opposed to an unrestricted or de minimis level, and will be a great tool for Office of Housing/FHA staff to assess whether the site is appropriate for residential use,” stated Carol Galante, Assistant Secretary for Housing – Federal Housing Commissioner.

If you have any questions about the new Phase I standard, contact Natalie Neuman (nneuman[at]gabenv.com or 773-486-2123).

April 11th, 2014

3 Things To Know About the New Phase I Standard

ASTM finalized E1527-13, the latest Phase I Environmental Site Assessment  standard on November 6, 2013.  EPA subsequently approved E1527-13 as being compliant with All Appropriate Inquiry (AAI) regulations on December 30, 2013.
Here’s the top 3 things you need to know about these updated regulations:

VAPOR

ASTM updated the definition of a REC (Recognized Environmental Condition) to specifically include vapor as a potential concern. Previously, it was left to the Environmental Professional’s discretion or their client to determine if vapor should be considered when performing a Phase I.  Environmental Professionals (EPs) must now consider solid, liquid and vapor releases of hazardous substances or petroleum products.

Bottom Line:  You may see more RECs now that include vapor issues.

CREC

ASTM added the term CREC (Controlled Recognized Environmental Condition) to better define sites which have past releases that have been properly addressed but still have a required control (eg: commercial/industrial land use restriction, engineered barrier, etc).

Bottom Line:  If you see a CREC, don’t panic.  A CREC is a “good REC.”  Gabriel can advise you and your client about any site-specific requirements regarding the continuing obligations.

FILE REVIEWS

ASTM states that agency file reviews should be conducted if the subject property or adjoining property is identified in any of the standard environmental records sources.  Previously, some EPs would review these government records during their Phase I assessments but many would not.  Now, these reviews must be included unless records are not reasonably ascertainable.

Bottom Line:  Other firms might increase their prices to include this additional work.  Gabriel has always done file reviews for these types of sites, so you will not see an increase in our prices to add in the file review.