3e News

EPA and DEQ Issue Guidance on COVID-19 Implications for Enforcement and Compliance Programs

April 02 2020

The Environmental Protection Agency (EPA) and the Virginia Department of Environmental Quality (DEQ) have issued similar guidance addressing the enforcement of select environmental regulations during the on-going COVID-19 pandemic. The temporary policies are being applied retroactively beginning March 13, 2020. Federal regulations and compliance monitoring affected include, but are not limited, to:

  • Spill Prevention, Control, and Countermeasures Plan (SPCC):   Monthly Inspections, Formal Integrity Inspections, Annual Training, and Implementation of SPCC Plan Action Items. 
  • RCRA Subpart J – Hazardous Waste Aboveground Storage Tanks:  Integrity Inspections, Training, Daily/Weekly Inspections, and Formal Integrity Inspections.
  • RCRA Hazardous Waste Generation:  Accumulation Requirements & Generator Status. 
  • Permitted Solid Waste Facilities:  Groundwater and Vapor monitoring.
  • NPDES Monitoring - Public Drinking Water Facilities:  Monitoring & Sampling for Permit compliance.
  • Municipal Separate Storm Sewer System (MS4) and Industrial Stormwater Pollution Prevention Plan (SWPPP) Inspections and Monitoring

Important Notes:    

  1.  The temporary policy does not apply to activities carried out under CERCLA Superfund and RCRA Corrective Action Enforcement Instruments.  The EPA noted that any changes in those requirements would be addressed in separate guidance.
  2.  Any deviations to the regulations should be documented through EPA correspondence as required, or through an internal memo or other notification process.  Documentation should be prepared and maintained in a manner to satisfy the requirements of an internal or regulatory agency audit. 

 

EEE Consulting, Inc. is Providing Compliance Inspections and Monitoring During This Time

EEE Consulting, Inc. (3e) can help you develop protocols, communicate with regulators, assist with creating amendments or consult with your facility personnel to determine documentation requirements. Our experienced staff includes certified/qualified field personnel that can perform inspections and monitoring while your staff are working remotely or if your site is temporarily closed.

3e is ready to help you meet your compliance obligations during this unprecedented time. If you have questions about how this impacts your facility, or if you need help with inspections, monitoring, or documentation please contact Chris Lalli at (540) 953-0170 x310 or Jennifer Jones at (804) 442-3330 x214. You can also contact us through our website.

For more information please review the following:

EPA Memo: EPA Memo dated March 26, 2020

DEQ News Release: DEQ Enforcement and Compliance Guidance dated March 31, 2020


Survey Windows Approaching

March 19 2020

small whorled pogonia

Plan ahead if you may be impacting terrestrial habitats, wetlands, or waters requiring construction-related permits on your project. 3e environmental scientists can complete the habitat assessments and surveys your project may need. Contact us to schedule your survey today. Upcoming survey windows for listed plants include:

Small whorled pogonia

Survey window for the small whorled pogonia (Isotria medeoloides) is May 25 to July 15 for areas south of Caroline County, or June 1 to July 20 for Caroline County and counties to the north.

Swamp pink

Survey window for the swamp pink (Helonias bullata) is April 15 – May 31 (in flower or fruit) and/or June 1 – September 30 (basal leaves).

Virginia Spiraea

Survey window for the Virginia Spiraea (Spiraea virginiana) is May 1 – September 30 (leaves present)

Juniper sedge

Survey window for the Juniper sedge (Carex juniperorum) is approximately April 15 to May 31

 

For more on survey times for Virginia’s federally listed species visit the U.S. Fish and Wildlife Service's list here:

https://www.fws.gov/northeast/virginiafield/pdf/endangeredspecies/20120125_VIRGINIAsurveytimeframeforplants.pdf

(pictured: Isotria medeoloides, small whorled pogonia)


Legionellosis cases on the rise in Virginia

February 25 2020

Reports of Legionellosis cases are increasing in Virginia, according to the Virginia Department of Health (VDH). The disease is caused by Legionella bacterium and it becomes a health concern when it is found in building water systems, as it can cause pneumonia (Legionnaires’ disease) or a flu-like illness (Pontiac fever) when a person breathes in water droplets containing Legionella bacteria. According to VDH, the root cause of the recent rise in Legionellosis cases is largely due to a lack of prevention planning and inadequate routine maintenance on water systems. State lawmakers in the General Assembly are responding with a proposed bill (Senate Bill 410) that would require public schools to maintain a water management program for the prevention of Legionella bacteria.

EEE Consulting, Inc. Offers Routine Testing and Water Management Planning Services

EEE Consulting, Inc. (3e) staff are experienced in Legionella testing, having collected over 750 samples from entry and recirculation lines, backflow preventers, cooling towers, hot water storage tanks and heaters, dishwashers, showers, tubs, faucets, sinks, and whirlpools located in more than 50 healthcare, school, and military facilities throughout Virginia. 3e works with the facilities and their architects and engineers to develop comprehensive Water Management Plans and establish testing protocols for Legionella and other parameters (e.g., residual chlorine, pH, temperature) in accordance with the Centers for Medicare and Medicaid Services (CMS) 2017 mandate, the Center for Disease Control (CDC) guidance, and American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE) Standard 188-2018. 3e partners with an American Industrial Hygiene Association (AIHA) accredited laboratory that uses conventional culture methods with multiple selective media for Legionella analysis. 3e also provides proactive voluntary sampling, follow-up testing for reported detections, and confirmation sampling following cleaning and disinfection of water systems. 

Services offered include:

  • Review of building water systems;
  • Identification of high-risk areas and control measures;
  • Inspections in accordance with CDC guidance and ASHRAE standards;
  • Documentation of the Water Management Plan; and
  • Reporting for facilities, school boards, and healthcare facilities

Review Your Water Management System Today

Water Management Plans and testing for Legionella bacteria are critical tools for protecting the public from the risk of Legionnaires’ disease and Pontiac fever. For more information on how 3e develops Legionella testing protocols and Water Management Plans, please contact Sharon Harless, CHMM, at 804-442-3330 x 207 or through our website at: http://www.eee-consulting.com/contact.


Sandra Brinson Joins 3e!

January 09 2020

Sandra Brinson - Senior Environmental ScientistMechanicsville, Virginia – EEE Consulting, Inc. (3e) is pleased to announce that Sandra (Sandy) Brinson has joined the firm as a Senior Environmental Scientist leading our natural resources discipline team. Sandy brings 30 years of diverse environmental experience in natural resources, NEPA, and hazardous and regulated materials.  She has extensive experience working on military, aviation, highway, municipal and private projects governed by the National Environmental Policy Act (NEPA) guidelines, the Clean Water Act and the Code of Virginia. 

Sandy will be establishing a 3e field office in Newport News, Virginia, to enhance service to our clients in the Tidewater Region.

Sandy comes to 3e from Integrity Environmental, Inc., which she founded in 2004 in Newport News, Virginia. She is a Virginia Certified Professional Wetland Delineator whose natural resource expertise has centered on wetland delineations and permitting (tidal and non-tidal), areas regulated by the Chesapeake Bay Preservation Act, endangered species surveys, botanical identification, wetland mitigation design and specifications, mitigation site searches and mitigation bank planning.  She has extensive experience in the preparation of various NEPA documents including Environmental Assessments, Environmental Impact Statements and Categorical Exclusions on federally funded projects throughout the Mid-Atlantic and in several mid-western states.  Sandy has also worked extensively on hazardous and regulated materials including RCRA/CERCLA investigations Phase I, II and III Environmental Site Assessments, Underground Storage Tank (UST) Closures, Spill Prevention Control Countermeasure Plans and Lead-based Paint and Asbestos Risk Assessments, Surveys, Operations and Maintenance Plans and Pre-renovation Asbestos Assessments.

Sandy is a member of the Virginia Association of Wetland Professionals and the American Society of Highway Engineers.

For more information, please reach out via our Contact Us page.


Waters of the US: Going Back in Time

November 04 2019

On October 22, 2019, EPA and the Department of the Army published a final rule to repeal the 2015 WOTUS rule that impermissibly expanded the definition of “waters of the United States” (WOUS or WOTUS) under the Clean Water Act. This action also recodifies the longstanding 1986 definition of Waters of the US—providing regulatory consistency across states.  The final rule will become effective on December 23, 2019. Read the final rule. 

 

Primarily because of patchwork legal holdings, continuing regulatory uncertainty, and lingering litigation, the Agencies are starting from scratch on redefinitions of waters of the U.S. that were initiated by a rule in 2015. All previous rulemaking on the so-called WOTUS rule is formally rescinded and is being re-examined afresh. A reversion of the 2015 Rule has little impact in Virginia. 3e will continue to monitor this process and will provide updates and details as more information becomes available. If you would like to discuss how these changes could affect your current or future projects, please contact Robert Wright in our Mechanicsville office or Jason Steele in our Blacksburg office.


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