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.

Rusty with family

Meet J. Rusty Field, PE, Managing Principal

Richmonder Rusty Field envisioned a customer-centered company that prioritizes lasting, meaningful relationships over the bottom line when he and his partners founded ONE Environmental Group, LLC in 2009.

“What started as a crazy idea in the midst of a recession has grown from a few people to over 25 team members with offices across four states,” he says. “Most startups don’t make it past five years, and here we are, which is pretty amazing. I attribute our success to an awesome team and a great strategy.”

Serving clients’ needs trumps metrics and bureaucracy, a point of pride for Rusty.

“That allows us to stay focused on what is important — working with clients to gain their trust, having fun, and not being caught up in some big corporate business model,” he says.       

The Virginia Tech graduate never wanted to sit in a cubicle wearing a suit and tie. He favors flip flops, jeans and being outdoors, where the professional engineer is driven to do his part to sustain the environment.  “It is not always glamorous, but I am proud of the work we do and continually impressed by our clients’ efforts to improve the environment.”

Rusty and his wife, Katherine, sweethearts from Midlothian High, live in rural Powhatan County with daughters Kaileigh and Aubrie and their two dogs, Chase and Charlie.

The parents spend the bulk of their free time supporting Aubrie in competitive dance and Kaileigh, an active soccer player and horseback rider.

Municipalities Encouraged to Apply for a VBAF Grant to Revitalize Brownfields

Grant funds are available to transform your brownfield into an economically viable property.

FY21 applications are available from the Virginia Brownfields Restoration and Economic Redevelopment Assistance Fund Review Committee, the Virginia Department of Environmental Quality and Virginia Economic Development Partnership.

The deadline to apply is April 1, 2021. Find the application here. Awards are expected to be announced in May 2021.

Jeff Duncan, Principal at ONE Environmental Group with offices located throughout the Commonwealth, encourages municipalities, eligible for awards up to $500,000, to apply.

“If you have a property in need of assessment or planning or if you want to remediate the site, these funds could be just what is needed to support revitalization,” he said.

Grants help fill a financing gap for projects or phases of work for restoration and redevelopment of brownfield sites as well as address environmental problems or obstacles to reuse so that these sites can be effectively marketed to new economic development prospects that have not already commenced.

Virginia Brownfields Restoration and Economic (VBAF) Site Assessment and Planning Grants, in amounts of up to $50,000, are available to assist with the costs of:

  • Environmental and cultural resource site assessments.
  • Development of remediation and reuse plans. 
  • Necessary removal of human remains, the appropriate treatment of grave sites, and the appropriate and necessary treatment of significant archaeological resources, or the stabilization or restoration of structures listed on or eligible for the Virginia Historic Landmarks Register.
  • Demolition and removal of existing structures, or other site work necessary to make a site or certain real property usable for new economic development.

VBAF grants do not reimburse costs already incurred for a project or phase of work that has begun or is already completed.

Remediation grant funds, in the amounts of up to $500,000 can be used for:

  • Remediation of a contaminated property to remove hazardous substances, hazardous wastes, or solid wastes.
  • Necessary removal of human remains, the appropriate treatment of grave sites, and the appropriate and necessary treatment of significant archaeological resources, or the stabilization or restoration of structures listed on or eligible for the Virginia Historic Landmarks Register
  • Demolition and removal of existing structures, or other site work necessary to make a site or certain real property usable for new economic development.

Duncan said ONE recently completed a successful project for the Parks and Recreation Department of a municipality in the west-central portion of the state. ONE assisted with the application and obtaining grant funds to complete assessment and remediation work to obtain a Certificate of Satisfactory Completion within the DEQ Voluntary Remediation Program (VRP). The property was remediated to render the property available for future recreational use by the Department.

The grants are coordinated, administered and awarded by DEQ and VEDP.

Duncan can answer questions about the application and help with its completion. Contact him at .

Join the team at ONE Environmental Group

ONE Environmental Group is looking to add an Environmental Consultant/Project Manager to its team.

This new hire will be responsible for business development, expanding the company’s network and supporting the overall growth of ONE, while ensuring consistency with company culture and vision.

ONE offers environmental consulting and industrial services to commercial, industrial and government clients that are regulated by environmental state and federal regulations or transactional requirements of lending institutions. ONE strives to provide value-based consulting services through innovation, integrity and a profound respect for our client’s objectives.

The position will support the Richmond and Norfolk offices primarily but will be remote during the COVID-19 pandemic.

The essential job functions include:

  • Focusing on increasing business opportunities in the Carolinas and South Atlantic regions.
  • Managing all aspects of projects, including setup, performance tracking, invoicing and collections. This includes taking responsibility for the quality of work product on all projects, meeting project budgets, and ensuring deadlines are met.
  • Interfacing directly with regulatory agencies on behalf of customers, with focus on environmental compliance and project management.
  • Supervising, mentoring and delegating project tasks to junior staff.
  • Preparing technical compliance documents required by local, State, and Federal regulations with minimal supervision, oversight and revisions. Examples include (but are not limited to) Permit Applications for various media (air, water, waste); SPCC Plans; and SWPPPs and associated documents (SOPs, DMRs, Inspection Reports and Corrective Action Reports).
  • Scheduling and performing Phase I and Phase II Environmental Assessments (ESAs) in accordance with ASTM standards with minimal supervision by an Environmental Professional.
  • Completing risk assessment analyses. Examples include (but are not limited to) surficial and subsurface soil, groundwater, soil gas, vapor intrusion and encroachment, and indoor air.
  • Scheduling and performing field work, including (but not limited to) sample collection, compliance inspections, soil borings, monitoring well installations and various remedial activities. All field work must be completed in accordance with both company and customer health and safety guidelines.

The ideal candidate must have either a bachelor’s or master’s degree in engineering or a scientific discipline with at least six to 10 years of experience working in the environmental industry. Preferably that experience would involve environmental compliance projects involving both federal and state regulations, such as RCRA, CAA, CWA and OPA. 

Preferred qualifications include a 40-hr HAZWOPER certification and licenses in Asbestos and/or Lead Based Paint. A physical exam is required to obtain medical clearance for hazardous waste work. Passage of a drug test and a background check are additional requirements. Candidates must have a valid driver’s license and be flexible to work outside of normal business hours if necessary.

The position may require up to 20% overnight travel.

Salary range is $50,000 – $100,000 with benefits.

Achievement-oriented, innovative independent candidates encouraged to apply. At ONE, our culture is both detail- and outcome-oriented with a focus on team and people.

APPLY NOW!