Category Archive: Industry News

Cooling tower for HVAC system with coils and fins on display wit

Boosting Safety and Compliance with Effective Water Management Planning and Legionella Monitoring

Legionella bacteria is a pathogenic group of gram-negative bacteria that grows naturally in the environment. In freshwater lakes, rivers, and streams, the bacteria is usually harmless to humans.

Things change, however, when Legionella bacteria enters and multiplies within water and plumbing systems, and the contaminated water becomes aerosolized. When legionella is inhaled at high enough levels, the bacteria can enter the lungs and cause one of the two forms of legionellosis, Legionnaires’ disease or Pontiac fever.

To be sure, chemicals get much of the focus from a water safety perspective these days, with plastics, pesticides and per- and polyfluoroalkyl substances (PFAS) at the top of the contaminants lists. But Legionella is still a serious microbiological public health problem when it is not properly monitored or managed. In the U.S., Legionella has become the leading cause of waterborne disease.

Elderly or immunocompromised people have a greater risk of contracting legionellosis, making it especially problematic in hospitals and other health care settings.

Good Water Management Planning Critical to Maintaining Healthcare Facility Certification

In order to cause legionellosis, Legionella bacteria must multiply in the water system before becoming aerosolized. This can happen in various ways as water moves through cooling towers, fountains or showers.

The Centers for Medicare and Medicaid Services (CMS) issued a memo in June 2017 requiring Medicare-certified healthcare facilities to reduce risks associated with Legionella and other waterborne pathogens in their building water systems. The memo outlines how Hospitals, Critical Access Hospitals, and Long-Term Care facilities must institute preventative measures to minimize the growth and transmission of Legionella to maintain certification. 

ONE Environmental Group has extensive experience performing industrial hygiene sampling and assessment services for large enterprises. This includes preparing comprehensive Water Management Plans for multiple hospitals and other healthcare facilities specifically designed to manage the risk of Legionella.

In addition to prevention, ONE also works with healthcare clients on risk analysis initiatives and emergency response planning in the event of positive test results. This critical planning provides staff clear direction on exactly what needs to happen if a water contamination incident occurs onsite. Plans designed by ONE Environmental Group satisfy the stringent requirements set forth by CMS.

The ONE team also helps hospitals monitor for Legionella by strategically collecting samples from water system locations determined in Water Management Plans as most likely to have Legionella. ONE has the samples analyzed by an Environmental Legionella Isolation Techniques Evaluation (ELITE) certified laboratory, ensuring that sampling processes meet standards set by the Centers for Disease Control and Prevention (CDC). By partnering with ONE Environmental Group, healthcare leaders can develop robust water management planning and monitoring practices that keep patients safe while maintaining compliance with governmental regulations.

city water purification top view

Tapping the Power of Continuous Digital Modeling for Industrial Lagoon Management

Lagoon systems are used by industrial operators to meet a variety of wastewater management requirements. But lagoons themselves must also be managed, both above and below the surface.

Conventional lagoon management and monitoring methods are highly manual and require significant coordination to get a comprehensive “as-is” representation of above ground and underwater features.

Recently, hydrographic survey capabilities have advanced greatly thanks to continuous digital 3D modeling technologies and techniques.

The ONE team has experience creating continuous digital 3D models of industrial lagoons that present a detailed view of the contoured terrain above and below lagoon water levels. These 3D models can be used to create a baseline for existing lagoon conditions, and periodic model updates can easily be made to detect changes in important metrics.

In addition, the 3D model interface can be accessed and shared online to support real-time collaboration across project teams. Unlike traditional methods that involve preparing figures with CAD software and emailing attachments that quickly become outdated, this method ensures team members have the most current information at their fingertips.

The ONE team recently put its continuous digital 3D modeling tools and expertise to work for one of the world’s leading manufacturers of wood products.

The project began with aerial mapping conducted with an Unmanned Aerial Vehicle (commonly referred to as a drone). The aerial drone followed a prescribed flight pattern to achieve the specified ground sampling distance.

The mapping process then took to the water. A hydrographic survey of two client lagoons was performed using another type of drone – an unmanned surface vehicle (USV) or “drone boat.” The drone boat is equipped with state-of-the art technology such as: autonomous navigation (autonav) system, survey-grade Global Navigation Satellite System (GNSS), Real-Time Kinematic (RTK) Receiver, and echosounder.

The drone boat’s autonav system provided precise control for the vessel to accurately follow prescribed grid patterns to detail lagoon terrain below the water surface. Manual measurements of sludge thickness at the bottom of the lagoons were collected along with surveyed ground control.

Georeferenced data collected from the drones were compiled and processed into 2D and 3D representations of the industrial lagoons. Ground control data were utilized to confirm the models were accurate and could be used for purposes such as:

  • Taking precise sludge volume measurements.
  • Calculating soil volumes needed to raise berms to specified elevations.
  • Identifying specific utilities that will be affected as proposed construction plans are considered.

Ultimately, by leveraging these new models facilitated by the ONE team, the client can complete a variety of important lagoon management tasks more efficiently, with less risk and greater accuracy.

Groundwater Collection

From Permits to Plans, ONE Keeps Industry Compliant with Stormwater Requirements

ONE Environmental Group offers a range of stormwater consulting services, which include assisting industrial clients with applying for a stormwater discharge permit, developing an ensuing stormwater prevention plan and ensuring all requirements are met to maintain compliance.

 The Clean Water Act established the National Pollutant Discharge Elimination System (NPDES) program in 1972 to limit pollutant discharges from industrial facilities and prevent them from reaching streams, rivers and bays. In Virginia, the state’s Department of Environmental Quality (DEQ) administers the Virginia Pollutant Discharge Elimination System (VPDES) program

Why is monitoring stormwater discharge a priority? ONE Principal Jeff Duncan likes to drive that point home during facility employee training, which  is one of the stormwater permit requirements. He will ask for a show of hands to these questions:

  • Who likes to fish in our rivers and the Chesapeake Bay
  • Who enjoys swimming, boating or recreating in these areas?

Who would want to do these activities in impaired or polluted water? While enforcement measures in the form of penalties and fines are in place, it’s important for employees to understand why a stormwater plan cannot be an overlooked priority.

Stormwater runoff, if not handled properly, can carry industrial pollutants, which are then discharged into the waterbodies where we swim, boat, fish or simply enjoy from the shore. Contaminants can impair waterbodies, degrade biological ecosystems and even affect drinking water sources.

“It really helps employees to hear what’s behind why we do what we do,” Duncan says. “In reality, we’re keeping stormwater clean from the facility because it leads to that ditch that leads to that river and ends up in the bay where we fish, swim or boat.”

Contaminants can range from oil, grease, and metals to toxic chemicals and debris. Essentially any discharge from an industrial facility can impact stormwater runoff, which has the potential to pollute the water. A transportation facility is going to be focused on the impact of Total Suspended Solids (TSS). A material recycling facility would add monitoring for metals.

Check your Standard Industrial Classification (SIC) code to determine if your facility needs an Industrial Stormwater Permit. This four-digit code is a descriptor of the kind of work being done at your facility. It’s up to the owner/operator of the facility to know if a permit is required; ONE can verify whether a permit is necessary.

“Many owners/operators aren’t aware they need a permit,” Duncan said. “If they purchased the facility from another operator and the previous operator never had a permit, it might not be on their radar.”

A facility that operates under roof without exposure to stormwater can apply for a no-exposure certificate, which will likely require a site visit from DEQ prior to approval.

ONE can handle each of the steps required to obtain and comply with the permit, starting with the development of a Stormwater Pollution Prevention Plan (SWPPP). The plan specifies the party responsible for implementing the actions, lists best management practices and details monitoring requirements.

It’s imperative that best management practices are ongoing to ensure compliance continues. Once the permit is received, the process is ongoing, not over.

“We conduct facility inspections, monitoring and preparation of Discharge Monitoring Reports (DMRs),” Duncan said. “We are full service and can perform our services as an augmented staff member. We can implement the entire stormwater program.”

KEY STORMWATER CONSULTING CONTACTS: Jeff Duncan

Pressure gauge on the cylinder of the industrial refrigeration.

Assisting Industry with Refrigerant Reporting and Compliance

It’s not just good business to have a plan regarding refrigerant use — it’s the law. ONE Environmental can make sure your company complies with current regulatory requirements.

ONE Environmental Consultant Austen Meyer has expertise in this area and new regulations that went into effect in 2020.

Facilities must document and retain service and maintenance records for appliances containing refrigerants, depending on the unit type and refrigerant capacity. Often, facilities are unaware of the specific requirements (i.e., calculated leak rate, successful initial and follow-up verification tests, leak inspections, etc.) and inadvertently are not in compliance with the refrigerant regulations.

Facilities are also required to submit a report to EPA (due March 1st each year) for specific types of units, if in the calendar year 125% of the unit’s capacity is added to the appliance.

Refrigerants, specifically hydrochlorofluorocarbons (HCFCs), fall under Section 608 of the EPA’s Clean Air Act. Facilities with units greater than 50 pounds that leak or are serviced with more than 125% of the unit’s capacity in the previous calendar year are subject to reporting requirements under the federal regulation found in 40 CFR 82.157. The latest update became law on April 10, 2020.

Units with refrigerants that contain 50 pounds or more of any Class I or Class II Ozone- Depleting Substances (ODS) fall into this category. One caveat, substitute refrigerants (R-410a) are now exempt from the recordkeeping and reporting requirements, so realistically only older units that contain R-22 or R-123 are subject to the March 1reporting deadline.

A leak rate must be calculated for any appliance that requires service.  Keeping strict records for these calculations is essential, and often, this is where missteps can occur, Meyer said. Facilities often rely on the servicing contractor to calculate the leak rate, whereas the responsibility falls on the owner/operator.

“The regulations can get a little confusing,” Meyer said, noting ONE can assist clients with knowing their responsibility and ensuring all necessary documentation is complete.

Performance and recordkeeping of verification tests are another compliance area often overlooked. There are two types of verification tests: the initial test that must be completed to make sure that repairs were successful before refrigerant is added back into the appliance and a follow-up verification test that must be completed within 30 days of the successful initial verification test.

Another troublesome area is leak inspection. If a leak exceeds a certain threshold, depending on the capacity and type of the unit, an inspection must be performed either annually or every three months.

“The leak inspection must be conducted by a certified technician, but the owner/operator must document that the inspection was completed,” Meyer said.

When ONE works with a new client, the first step involves a comprehensive review of the facility and an audit of their current refrigerants program to determine compliance with the applicable regulations.

Researchers are checking the soil and collecting soil samples.

Vapor Intrusion: Another Reason Due Diligence Matters

Due diligence is a critical step for any prospective property owner for multiple reasons.  One of the risks is not something you can see or even smell, but rather affects the air we breathe.

If the property, or a nearby property, is or was previously operated as a dry cleaner or related to anything in manufacturing or industry, vapor intrusion is a potential underlying threat, said ONE Environmental Group Project Manager Jenny Tang. These industries are known for using chemicals in their processes that contain volatile organic compounds (VOCs).

“Historically, these chemicals were used often and routinely without many regulations on proper disposal,” she said.  “The remnants of these chemicals hang around for a long time.  Mishandling of them has typically resulted in the contamination of soil and groundwater. They can also vaporize and seep through surfaces. They go through cracks in building foundations, travel through networks of pipes and ultimately find their way indoors. Once indoors, these gases can accumulate to harmful concentrations. With more than 80% of our lives spent indoors, the importance of clean air is indisputable.”         

Today, regulatory agencies attempt to prevent those types of contaminants from posing a health risk but determining historical use of a property is important.

ONE can identify the presence of these chemicals by scoping out a plan for due diligence. The first step is typically completion of a Phase I Environmental Site Assessment (ESA), which involves heavily researching the property’s current and historical uses as well as its surrounding area.

The results of the Phase I ESA can lead to a call for a Phase II ESA, which involves the collection of samples. If a risk of vapor intrusion is discovered or a complete vapor intrusion pathway is confirmed, the risks are calculated against regulatory standards. If concentrations are determined to exceed regulatory acceptable levels, the property owner must determine the best way to mitigate. The decision will depend on many factors, including the severity of contamination, the current use of the property, and even time. 

One of the most common ways to handle vapor intrusion is to install a vapor mitigation system.  A mitigation system prevents soil vapors from entering the building by either creating an active vacuum in the subsurface or by passively venting. 

“We leave it to the property owner to decide the course of action,” Tang said. “We take into consideration the characteristics of the contamination and the property itself to provide a recommendation of how to eliminate the risk of vapor intrusion without sacrificing any future planned use of the property. ONE works with the property owner and the appropriate regulatory agencies to see the mitigation through.” 

In North Carolina, the Dry-Cleaning Solvent Cleanup Act (DCSA) established a fund to assess and clean up contamination related to dry cleaners. Enacted in 1997, its purpose is to create a healthy environment for current and future generations. In addition, both federal and state Brownfields Programs can provide technical assistance for assessment and cleanup of a variety of contaminants. Their goal is to promote the redevelopment of contaminated and underused sites.  

“You may have the responsibility to report if you find contamination, but that doesn’t necessarily mean you’re the responsible party,” Tang said. The key takeaway Tang cannot stress enough: “Do your due diligence.” 

ONE Principals Part of DEQ Technical Advisory Committee Implementing a TMDL for PCBs

Polychlorinated Biphenyls (PCBs) aren’t a new concern. These persistent organic pollutants do not break down easily and linger in the environment for extended periods of time.

ONE Environmental Group Principals Kerry McAvoy and Jeff Duncan are part of a new Virginia Department of Environmental Quality (DEQ) Technical Advisory Committee (TAC) that will implement TMDLs — Total Maximum Daily Loads or cleanup plans — for PCBs.

The intentional production of PCBs was banned by the Environmental Protection Agency in the late 1970s, but once bottom dwellers absorb the material, PCBs aren’t easily excreted and the food chain is affected. They make their way into the tissues of aquatic animals, including fish, and can invade human digestive, neurological, and reproductive systems when people consume fish. Another growing body of research suggests that PCBs can be produced unintentionally through certain industrial processes – such as pigment production used in paints and inks.

These more recently created PCBs, along with PCBs produced in the past, continue cycling through the environment today. That’s the major reason why Virginia’s Department of Environmental Quality (DEQ) is implementing a TMDL — the calculation of the maximum amount of a pollutant allowed to enter a waterbody so that the waterbody will meet and continue to meet water quality standards for that particular pollutant.

In representing Virginia Manufacturing Association (VMA) on the TAC, McAvoy and Duncan will focus on two sets of waterways:

  • What’s known as the upper James River, which includes 13 miles of the Jackson River, 17 miles of the Maury River and 182 miles of the James River. Since 2004, the Virginia Department of Health (VDH) issued fish consumption advisories on portions of the Maury and James rivers based on the high levels of PCBs that DEQ monitoring revealed in fish tissue.  DEQ began collecting fish tissue in state waters in 1993. The initial elevated fish tissue PCB levels resulted VDH issuing fish consumption advisories, which grew in number and size as more data was collected through following years of monitoring.
  • What’s known as the Tidal James or the lower part of the James River and the Elizabeth River. Fish tissue monitoring began on the Elizabeth River in 1993, and in the tidal James River and tributaries in the following years. In 2004, the VDH issued a fish consumption advisory for the Elizabeth River, the tidal James River and its tidal tributaries. Water quality monitoring to support the development of a cleanup plan began in 2009, with around 275 water column and sediment samples collected. Data from this monitoring effort allowed for an assessment of PCB sources and also identified additional PCB hotspots in six tributaries.

McAvoy and Duncan are the eyes and ears for their clients and stewards of the environment for what promises to be a lengthy, ongoing process.

“We’re participating in the public meetings, noting the questions and comments, and compiling any input that our clients in the VMA want to submit to the DEQ,” McAvoy said. Public input from a wide variety of stakeholders throughout the TMDL development process is integral to ensure that the final outcomes are reasonable, realistic, and reflect local insight.