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Environmental Checkpoint Newsletter Spring 2010

SAK provides environmental monitoring of synthetic turf athletic field

SAK Environmental has initiated a 5-year environmental monitoring program of a newly constructed synthetic turf football field at a local, public high school in the Boston metropolitan area. Public involvement by residents had raised concern about potential human and environmental exposure to Lead and other hazardous materials from the crumb rubber in-fill. SAK has implemented a multimedia monitoring program that includes storm water, groundwater, wetland, and evaluation of the field's surface for Lead dust. SAK is also developing an inspection protocol to quantitatively and consistently evaluate the amount of crumb rubber entering the field's storm water drainage system. The reports will provide city officials, residents and MADEP important data that can be used as a case study.

The US Environmental Protection Agency (USEPA) released a study in December 2009, which completed comprehensive chemical testing as a small number of synthetic fields in the United States. The study is entitled "A Scoping-Level Field Monitoring Study of Synthetic Turf Fields and Playgrounds" can be found at http://www.epa.gov/nerl/features/tire_crumbs.html. While the fields included in their study did not find significant exposure concerns, it was accepted that results do not represent the wide variability in the quality of crumb rubber. USEPA is planning a 2010 meeting with federal and state agencies to review all new study data and determine next steps.


2010 Environmental Reporting Deadlines

  March 1 Tier II reporting
  March 1 Biennial hazardous waste report
  March 1 Hazardous waste recycling annual report
  April 15 Greenhouse gas emissions report
  July 1 Federal TRI Form R
  July 1 Massachusetts TUR Form S
  July 1 Massachusetts TUR planning year
  August 8 First triennial third-party inspection of USTs

 

Other annual requirements (dates vary by facility):
  Massachusetts annual above ground tank inspection
  Storm water training
  Hazardous waste contingency plan training


EPA imposes numerical effluent limits to construction storm water

On December 1, 2009, EPA published effluent limitations guidelines (ELGs) and new source performance standards (NSPS) to control the discharge of pollutants from construction sites. The Construction and Development ELG, or C&D rule, becomes effective on February 1, 2010. After this date, all permits issued by EPA or individual states must incorporate the final C&D rule requirements. The rule requires all construction site owners and operators to implement a range of erosion and sediment control best management practices (BMPs) to reduce pollutants in stormwater discharges. Permittees are also required to implement a range of pollution prevention measures to control discharges from activities such as dewatering and concrete washout. The rule contains stringent requirements for soil stabilization as well. EPA is phasing in the numeric limitation over four years to allow permitting authorities adequate time to develop monitoring requirements and to allow the regulated community time to prepare for compliance with the numeric limitation. Beginning August 1, 2011, construction sites that disturb 20 or more acres at one time will be required to conduct monitoring of discharges and comply with a turbidy limitation of 280 NTU (nephelometric turbidity units). On February 2, 2014, the monitoring requirements will apply to sites that disturb 10 or more acres at one time.


Property foreclosure forces environmental issues to the surface

SAK Environmental, LLC assisted a confidential major lending institution in determining environmental risks at a commercial property as part of foreclosure proceedings. The slow economy took its toll on a commercial real estate owner and forced the bank's hand to initiate foreclosure on a privately owned retail gasoline station. Phase I and II investigations revealed that a release of gasoline occurred at the facility and was migrating off-site, potentially putting down gradient residential neighborhoods at risk. Earlier investigations conducted by others concluded that conditions were similar to environmental response actions closed-out years earlier, but SAK determined the high concentration of the gasoline additive methyl tert butyl ether (MTBE) and low concentrations of petroleum hydrocarbon chains indicated that a new release had occurred. Testing of the underground tank system found that supply lines were leaking. The magnitude of the release was determined and planning costs for remediation was estimated. SAK's work quantified environmental conditions at the site and facilitated successful auction of the property.

"MTBE is an excellent indicator of the relative age of a gasoline release," says Stephen Sakakeeny, Principal and Licensed Site Professional for the project. Unlike petroleum hydrocarbons such as Benzene, Toluene, Ethyl Benzene, Xylenes, and hydrocarbon chains, MTBE is water soluble. Thus, MTBE travels much faster than the other compounds. A spike in MTBE levels is commonly observed far before the heavier hydrocarbon compounds arrive - like smoke before a fire. "This is why the relationship of MTBE to other measured petroleum compounds must be scrutinized to determine if releases are actively occurring," says Sakakeeny. SAK's work for the lending institution provided early detection of a problem missed by others and preserved the property's inherit commercial value.