U.S. EPA Seeks Comments On Draft Interim Recommendations For Addressing Emerging Contaminants PFOA And PFOS In Groundwater

Written by Todd W. Billmire, Bradford A. De Vore, and Richard E. Morton,
Womble Bond Dickinson

The United States Environmental Protection Agency (U.S. EPA) has released its Draft Interim Recommendations for Addressing Groundwater Contaminated with Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonate (PFOS) for public review and comment as part of the Agency’s PFAS Action Plan commitments.

EPA developed the draft recommendations based on the Agency’s current scientific understanding of per- and polyfluoroalkyl substances (PFAS) toxicity. The recommendations are intended to provide clear and consistent guidance for federal cleanup programs, including the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, commonly referred to as “Superfund”). The recommendations are also intended to aide state and tribal cleanup programs, and in carrying out other federal regulatory authorities (e.g., federal facility cleanup programs and approved state Resource Conservation and Recovery Act corrective action programs). When finalized, the recommendations will provide guidance to responsible parties as they make site-specific characterization and cleanup decisions for PFOA and PFOS.

Installations with reported DOD action on elevated levels of firefighting foam chemicals, August 2017 (Source: U.S. Government Accounting Office)

The guidance provides recommendations on:

  • Screening levels, which are used to determine if levels of contamination may warrant further investigation;
  • Preliminary remediation goals (PRGs) to inform site-specific cleanup levels for PFOA and PFOS contamination of groundwater that is a current or potential source of drinking water. PRGs are initial targets for cleanup, which may be adjusted on a site-specific basis as more information becomes available.

EPA is seeking comments on all parts of the recommendations, including the use of EPA’s Lifetime Drinking Water Health Advisory level of 70 ng/L or parts per trillion as the recommended PRG for groundwater, or whether higher or lower values would be supported.

The 45-day public comment period will close on June 10, 2019.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.


About the Authors

Todd W. Billmire is a skilled litigator that defends companies in environmental litigation and related administrative and regulatory matters. His clients value his thoughtful problem solving approach to complex environmental matters and his environmental consulting background.

Todd represents a variety multinational manufacturers, energy companies, utilities, and municipalities in environmental litigation and compliance matters. Todd also has counseled and represented individuals and businesses in a wide range of business litigation matters, including class action litigation, securities litigation, and corporate and commercial disputes.

Brad De Vore is the Team leader of the Environmental and Toxic Tort practice at Womble Bond Dickinson. Toxic torts and high-stakes environmental litigation involve complex legal and technical issues, and multi-million-dollar liability exposure. Such cases can create media concerns and governmental enforcement actions that transcend the individual dispute. Environmental enforcement matters also can present significant business risks, perhaps crippling or even shutting down a company.

When clients face such threats they choose Brad for his and his top-drawer team’s experience and ability to tackle even the most complicated problems. Brad has spent more than 30 years developing a leading practice that includes extensive toxic tort and environmental litigation experience for many domestic and multinational clients in sectors such as energy, chemicals, electronics, construction and real estate development.

Brad’s experience with the fate and transport of chemicals and environmental agents, and their impact on human health and the environment, has led to successful results in many toxic tort, environmental and enforcement matters.

Richard E. Morton is a recognized leader in the environmental regulatory and litigation defense practice at Womble Bond Dickinson.  When clients face multi-million dollar environmental claims and regulatory enforcement challenges they turn to Ric because of his insight, tenacity and ability to untangle even the most complicated matters. Ric counsels companies in federal and state regulatory compliance and dispute resolution. His practice focuses on environmental regulatory compliance, litigation and enforcement defense, as well as toxic tort and products liability litigation.

Ric is particularly experienced in defending clients against bet-the-company damage claims related to chemical exposure; this includes public properties such as wastewater treatment systems. This work includes defending clients in various toxic tort and class action claims for personal injury and property damage from alleged contamination by benzene, chlorinated solvents, metals, particulates, petroleum constituents and other substances.

Global Emergency Spill Response Market forecast to reach $3.8 billion by 2025

Cognitive Market Research recently published their 17th edition of their Emergency Spill Response Market Report: Top Companies, Sales, Revenue, Forecast and Detailed Analysis. The report provides a comprehensive outlook of the Emergency Spill Response Market globally.

The Cognitive Market Research report gives a thorough examination of the market and, provides the market size and CAGR value for the forecast period 2019-2026, taking into account the past year as the base year. The study offers the major key aspects related to industry driving factors, opportunities, challenges, market threats, restraints, new products launch, geographical analysis and competitive tactics developed by key players in the competitive market.

A similar report published in 2018 by Research Trades estimated the global emergency spill response market size was $2.530 billion (USD) in 2018 and it is expected to reach $3.8 billion (USD) by the end of 2025, with a CAGR of 5.2% during 2019-2025.

The 2018 Research Trades report, Emergency Spill Response Market discusses the size, industry status and forecast, competition landscape and growth opportunity. It also provides analysis of the global emergency spill response market by companies, region, type and end-use industry.

The market is expected to have significant growth in the coming years owing to stringent environmental regulations across world to reduce the environmental pollution from spills.

Skimmers held the largest share of the market based on product type
Skimmers held the largest market size, in terms of product, primarily due to the increased demand for mechanical recovery methods for spill recovery. Unlike other methods, the mechanical recovery methods remove the spill material from the spill environment. Thus, skimmers are more effective in mitigating the environmental impact of the spills.

Major players in the global emergency spill response market includes Clean Harbors, Veolia Environnement, OSRL, Desmi A/S, US Ecology, Briggs Marine & Environmental Services and others.

Summary of Environmental Enforcement in British Columbia for 2018

The Province of British Columbia recently released its quarterly environmental enforcement summaries for the third and fourth quarters of 2018 to provide transparency on action taken against polluters.

The summaries detail a total of 1,728 environmental enforcement actions taken by the provincial government during this time period, along with $885,907 in associated penalties and fines.

In total, the Province issued 62 orders, 139 administrative sanctions, 31 court convictions, 14 administrative penalties and 2,412 violation tickets totalling $1,092,465 in fines in 2018. The most frequently contravened acts were the Wildlife Act with 1,040 violations, the Fisheries Act (Canada) with 375 violations and the Off-Road Vehicle Act with 344 violations.

To date, nearly 33,000 enforcement actions have been published in the summary and entered into the ministry’s environmental violations database.

Notable enforcement actions, for this period, include:

  • Radium Resort Group Ltd. was fined $200,000 for introducing waste-causing pollution and open burning of prohibited construction materials. Of that total, $190,000 was directed to Habitat Conservation Trust Fund.
  • Mackenzie Pulp Mill Corporation received penalties of $81,100 for failure to maintain a recovery boiler and failing to comply with permit limits for bivalent sulphur compounds and particulate matter.
  • Canadian Pacific Railway Limited received a penalty for $31,500 for failure to comply with an effluent discharge permit for its rail yard in Golden.
  • Savage Creek Golf Course Ltd. received a penalty of $70,000 for significantly exceeding fill-level maximums, while developing an 18-hole Richmond golf course expansion in the Agricultural Land Reserve.

In addition, B.C. conservation officers issued 95 violation tickets related to activities that could spark a wildfire in the third quarter of 2018. The Province has taken a strong stance to protect forests and communities in the face of one of the worst fire seasons in British Columbia’s history, with more than 1.3 million hectares burned. Fines for these violations were $1,150 each and totaled $108,900 during this same period.

To view the full quarterly environmental enforcement summary, visit British Columbia Natural Resource Compliance & Enforcement website.

What are the pros and cons of simulators for radiation safety training?

Written by Steven Pike, Argon Electronics

Electronic radiation simulators provide trainees with realistic first-hand experience of handling detector equipment that is identical to that which they will use in the field.

But while the use of simulator detectors can offer significant advantages for both student and instructor, as with any form of training method there may be some compromises.

In this blog post we explore some of the pros and the cons of radiation safety training using simulator detectors.

The Pros

Practicality

Ionizing radiation is a powerful, invisible force – which can make creating realistic scenarios a challenge.

By incorporating the use of simulator detectors into training exercises students have the opportunity to both understand and ‘trust’ the values displayed on their instruments.

In doing so they can also develop an understanding of the relationship between the measurements on their survey meter and their own personal dose readings as well as the effects of time, distance and shielding.

Safety

Safe and environmentally friendly radiation training systems can be used in a variety of scenarios – whether indoors, outdoors in confined areas or in public spaces.

With simulators incurring zero safety risk there are no Health & Safety restrictions – and the administrative burden for instructors is vastly reduced.

Immersion

Simulator detectors offer the opportunity for a truly authentic and immersive training experience.

Scenarios can be planned to replicate all the crucial elements of real-life incidents, which in turn exposes trainees to the psychological challenges they may well encounter in high-stress incidents.

Repeatability

With the use of simulators, radiation training exercises can be quickly and easily set up – and repeated as many times as required.

Outcomes

Powerful after action review (AAR) ensures that trainees have followed clearly set out procedures and that they understand when mistakes have been made.

Efficiency

Using simulators can provide some significant time-saving advantages for training exercises.

The costly and time-consuming administrative effort normally associated with the transport, deployment and safe handling of radionuclides is completely removed – and the need to secure specialist facilities where ionizing radiation sources is no longer an issue.

The cons

With any form of training, some compromises will inevitably have to be accepted. The key, however, is to find the happy medium between the optimum training outcome and what is practical and achievable.

Dynamic ranges

The dynamic ranges associated with radiation readings are extremely large, which can contribute to challenges in implementing simulations.

Instructor intensiveness

Simulation training can also be very instructor-intensive – with the trainer finding that too much of their attention is focused on creating the “effect” for their student and not enough on observing the student’s actions.

In these cases, alternative techniques which involve the temporary placement of a means to simulate the presence of radioactivity may be more practical – selection of the ideal simulation equipment is essential.

Shielding

It is the simulation of the effects of shielding where there is the potential for the greatest compromise.

The reality is that safe alternatives won’t be subjected to the same degree of attenuation (or reduction in force) as actual ionizing radiation.

But new technology now means that shielding can be represented to a realistic enough level to enable students to appreciate its importance for protection.

Instructors will of course need to clarify the differences, where appropriate, for the lesson being delivered – and these are likely to vary depending upon the operational responsibilities of the trainees.

While training with simulator detectors has both advantages and limitations, there is no doubt that it is an effective method of ensuring successful training outcomes while at the same time maintaining the safety of student and instructor.


About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators. He is interested in liaising with CBRN professionals and detector manufacturers to develop training simulators as well as CBRN trainers and exercise planners to enhance their capability and improve the quality of CBRN and Hazmat training.

How does After Action Review benefit HazMat training?

Written by Steven Pike, Argon Electronics

Emergency response teams are constantly looking for ways to improve their operations.

Simulated exercises, training classes and seminars can all provide valuable insight into tactics and technologies that can be applied in real life HazMat incidents.

However unless feedback on incident response and command is recorded (and can be easily shared with personnel), a valuable learning opportunity can risk being lost.

An effective way to enhance learning outcomes is through the use of a post-incident critique or After Action Review (AAR).

An AAR is a structured means of analyzing what took place during a particular training exercise or event to identify strengths, weaknesses and areas for improvement.

As well as providing a method to scrutinize the actions that occurred, an AAR is also an opportunity to consider what could have been done differently – both by those who took part in the exercise and by those who were in charge.

The evolution of AAR

The origins of After Action Review can be found in the US military where formal AARs evolved out of the combat action debriefs that were carried out during World War Two and the Vietnam war.

The use of AAR in a military context has also been documented in the memoirs of Chinese military leader Gong Chu’s during the 1934-1938 three-year war in South China; and by Emperor Napolean’s Marshall’s and Generals in the early 19th century.

Military AARs fall into two types – formal AARs (which require detailed planning, preparation and resources) and informal AARs (which take the form of on-the-spot reviews of individual or group training performance).

Over the years, a wide variety of public health and emergency management agencies have recognized the value of AARs – using them within training programs to aid better understanding of the perspectives and expectations of all involved and to capture crucial learning that can be widely shared.

One potential challenge with any form of realistic HazMat training exercise is that much can be going on in a relatively short time-frame. When the exercise ends, participants can sometimes find that many of the events, and the associated learning opportunities, have become a “blur” in their minds.

A 2018 article in the online magazine FireEngineering.com discussed how taking a “stop-and-start” approach to full-scale HazMat training exercises can help to cement learning. By breaking up the scenario into several smaller sections with regular breaks for review, there is the opportunity to discuss what’s just happened, to explore alternative tactics, to quickly correct any misunderstandings and to enhance exercise efficiency.

In addition there is also the advantage of being able to ensure that departmental procedures and guidelines are being followed, and that they are modified when necessary.

The application of AAR in simulator detector technology

The integration of AAR capability into simulator detector technology has been shown to reveal important lessons that improve professional practice, minimize risk and enhance communication.

When we think about AAR in the context of a simulator detector, it is the technology within the device itself (rather than a human) that maintains a record of all the activity.

The simulator version of the LCD3.2 Chemical Hazard Detector (the LCD3.2e) is just one example of a device that keeps a record of all real-time trainee movement – from the initial set-up of the equipment through to the completion of the exercise.

Once the scenario has concluded, the instructor is able to easily switch the device to display a detailed (and indisputable) performance report.

AAR is a powerful and constructive way to obtain valuable knowledge that can improve processes and enhance training efficiency – be it in the form of constructive group discussion, via fact-finding exercises or by harnessing the intelligent technological capability of simulator detectors.

The process of regularly critiquing can serve as a powerful tool for understanding the impact of one’s actions and effecting change.

And by regularly comparing the “expected outcome” with what “actually happened”, adjustments and improvements can continually be made, to improve safety at both an individual and an organizational level.

About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators. He is interested in liaising with CBRN professionals and detector manufacturers to develop training simulators as well as CBRN trainers and exercise planners to enhance their capability and improve the quality of CBRN and Hazmat training.

Environmental Due Diligence And Managing Environmental Risk – Part 1: Overview Of Saskatchewan Environmental Regulatory Landscape

Written by Christopher J. Masich, McKercher LLP

Today environmental due diligence and managing environmental risk are fundamental aspects of most (if not all) commercial transactions. Whether acting for developer, buyer, seller, purchaser, lessor, lessee, or financier, and whether in the context of M&A, real estate, project development or otherwise, some form of environmental due diligence or environmental risk management is necessary. Due diligence leading to the discovery of environmental liability (or even the potential of environmental liability) often causes an instinctive negative reaction. Fortunately, proper environmental risk management may be the difference between closing a transaction with economic success or not. To ensure economic success, it is incumbent upon legal counsel to assist clients in completing environmental due diligence and managing environmental risk.

This Resource Update is the first of a series of updates that will summarize the range of possible environmental issues, the patchwork provincial and federal regulations in Saskatchewan, the differences among Saskatchewan’s key industries, and the nuances of each type of commercial transaction. A prerequisite to any discussion of environmental due diligence and environmental risk management is a strong understanding of environmental regulations and potential liabilities that exist at common law in Saskatchewan. These are discussed in this Resource Update.

The Saskatchewan Environmental Regulatory Landscape

Environmental regulation in Saskatchewan is a patch-work of provincial and federal legislation administered by several government departments. While the management and protection of the environment in Saskatchewan is principally (but not exclusively) provided for under The Environmental Management and Protection Act, 2010, many environmental matters and industries with environmental impacts may also be regulated under the following Saskatchewan legislation and regulations promulgated under these Acts:

  • The Agricultural Operations Act
  • The Cities Act
  • The Conservation Easements Act
  • The Crown Minerals Act
  • The Dangerous Goods Transportation Act
  • The Ecological Reserves Act
  • The Environmental Assessment Act
  • The Environmental Management and Protection Act, 2010
  • The Fire Safety Act
  • The Fisheries Act (Saskatchewan), 1994
  • The Forest Resources Management Act
  • The Heritage Property Act
  • The Management and Reduction of Greenhouse Gases Act
  • The Mineral Resources Act, 1985
  • The Mineral Industry Environmental Protection Regulations, 1996
  • The Municipalities Act
  • The Natural Resources Act
  • The Oil and Gas Conservation Act
  • The Pest Control Act
  • The Pipelines Act, 1998
  • The Provincial Lands Act, 2016
  • The Sale and Lease of Certain Lands Act
  • The Public Health Act, 1994
  • The Reclaimed Industrial Sites Act
  • The Saskatchewan Employment Act
  • The Water Security Agency Act
  • The Weed Control Act
  • The Wildlife Act, 1998
  • The Wildlife Habitat Protection Act

This list is illustrative only and not exhaustive of all Saskatchewan environmental legislation, and not inclusive of applicable Federal legislation. Once due diligence has been “scoped” based on the particular industry and transaction, legal counsel and environmental consultants will fully review applicable Saskatchewan and Federal legislation.

In addition to Government legislation and regulation, environmental liability may be based on traditional common law tort claims of private and public nuisance, riparian rights, strict liability, trespass, negligence and negligent misrepresentation, deceit and fraudulent misrepresentation, breach of the duty to disclose, breach of the duty to warn, breach of fiduciary duty and waste. The following is a brief summary of each of these common law tort claims.

  • Private Nuisance. Private nuisance provides that a defendant may not cause substantial or unreasonable interference with the plaintiff’s use and enjoyment of its land.
  • Public Nuisance. Public nuisance is broader than private nuisance in that it confers a right of action for damages arising from the defendant’s use of its land even though no rights to the plaintiff’s land have been affected, but is restricted in that a plaintiff can only claim if it has suffered special or particular damage over and above that suffered by the public at large.
  • Riparian Rights. Riparian rights protect a plaintiff’s right to the flow of waters over its property without serious alteration in quantity or quality.
  • Strict Liability (Rylands v. Fletcher). Strict liability is a tort that varies slightly from negligence, nuisance and trespass. It generally requires the use of the land to be ‘non-natural’, followed by an escape, leading to mischief and compensable damages.
  • Trespass. Trespass is any invasion of property however slight and, in the context of environmental trespass, it must be proven that the defendant intentionally caused the contaminant to enter the plaintiff’s land.
  • Negligence and negligent misrepresentation. A successful claim of negligence requires the plaintiff to prove that the defendant breached a duty of care owed to the plaintiff, which caused the plaintiff to suffer damages.
  • Deceit or fraudulent misrepresentation. Fraudulent misrepresentation occurs when a defendant knowingly makes a false representation with the intent to deceive the plaintiff, and the representation induces the plaintiff to act, resulting in damages.
  • Breach of the duty to disclose. Similar to fraudulent misrepresentation, a party may be under a duty to disclose information that would be a benefit to the other party. This duty generally arises under the scope of a fiduciary duty, but may also exist under certain contractual relationships, such as real property transactions and lease transactions.
  • Breach of duty to warn. In certain contexts, there is a specific duty to warn that exists separate and apart from the duty to disclose and fiduciary duty. The duty to warn arises when facts or circumstances exists which may cause another person physical damage or harm. In the context of the environment, this duty may arise in manufacturer product liability cases or with the mishandling of hazardous substances.
  • Breach of fiduciary duty. The fiduciary duty is a special duty of utmost good faith and includes a duty of confidentiality and a duty to make full disclosure.
  • Waste. In lessor and lessee relations, a lessee may not commit waste against the lessor’s reversionary interest. Waste in this sense causes lasting injury to the reversion interest and may be due to a positive act or due to neglect or omission.

Environmental claims are often grounded in contract law. It is not possible to summarize the countless ways a contractual breach may occur but, in the context of the environment, such claims tend to relate to: onsite (historic) contamination, migration of contaminants, misrepresentations, indemnity claims, actions or omissions under lease tenancies and insurance coverage denial.

In Part 2 of our series on Environmental Due Diligence and Managing Environmental Risk, we will discuss early stage planning and scoping due diligence to set parameters and establish the framework for the due diligence process – arguably the single most important task of a transaction.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.


About the Author

Christopher J. Masich is a Partner at McKercher LLP practicing in the Firm’s Saskatoon office where he maintains a commercial transactions and project development practice focusing on Saskatchewan key economic sectors – energy, natural resources and agricultural. Additionally, Christopher provides special counsel on environmental risk management and environmental regulation across all industry sectors.

Nanoremediation of soil contaminated with Arsenic and Mercury

Researchers in Spain recently published a paper describing the utilization of nanoremediation technology to clean-up soil at the Brownfield site heavily contaminated with arsenic and mercury.

The research draws on a several lab-scale experiments that have shown the use of nanoscale zero-valent iron (nZVI) to be effective in reducing metal(loid) availability in polluted soils.


The core-shell model of zero-valent iron nanoparticles. The core consists of mainly zero-valent iron and provides the reducing power for reactions with environmental contaminants. The shell is largely iron oxides/hydroxides formed from the oxidation of zero-valent iron. The shell provides sites for chemical complex formation (e.g., chemosorption).

The researchers evaluated the capacity of nZVI for reducing the availability of As and Hg in brownfield soils at a pilot scale, and monitored the stability of the immobilization of these contaminants over a 32 month period. The researchers contend that their study is the first to apply nZVI to metal(loid)-polluted soils under field conditions.

In the study, two sub-areas (A and B) that differed in pollution load were selected, and a 5 m2 plot was treated with 2.5% nZVI (by weight) in each case (Nanofer 25S, NanoIron). In sub-area A, which had a greater degree of pollution, a second application was performed eight months after the first application.

Overall, the treatment significantly reduced the availability of both arsenic and (As) and mercury ((Hg), after only 72 h, although the effectiveness of the treatment was highly dependent on the degree of initial contamination.

Sub-area B (with a lower level of pollution) showed the best and most stable immobilization results, with As and Hg in toxicity characteristics leaching procedure (TCLP) extracts decreasing by 70% and 80%, respectively. In comparison, the concentrations of As and Hg in sub-area A decreased by 65% and 50%, respectively.

Based on the findings, the researchers contend that the use of nZVI at a dose of 2.5% appears to be an effective approach for the remediation of soils at this brownfield site, especially in sub-area B.

Investment Firm commits $1 billion toward innovative companies building a sustainable economy

Generation Investment Management LLP, with offices in London and San Francisco, recently announced the close of its $1 billion Generation IM Sustainable Solutions Fund III. The monies in the fund will be invested in innovative companies with high-growth potential. Investments will be in the range of $50-150 million.

“We believe that we are at the early stages of a technology-led sustainability revolution, which has the scale of the industrial revolution, and the pace of the digital revolution,” said Al Gore, Chairman and Co-Founder.

The Generation Sustainable Solutions Fund will focus on investments in growth-stage businesses with well-established technology and commercial traction in three areas:

1. Planetary health: low carbon solutions transforming mobility, food, energy, and enterprise

2. People health: enabling health outcomes and a lower-cost, accessible healthcare system

3. Financial inclusion:supporting accessto finance and an equitable future of work.

“Sustainability is about both what a company does (the products and services it sells) and how a company operates,” said Lila Preston, Partner and Co-Head of the Growth Equity platform. “A hallmark of our investment approach is that we take a systems-level view and leverage our long-term horizon and deep industry insights.”

Generation Investment Management LLP is dedicated to long-term investing, integrated sustainability research, and client alignment. It is an independent, private, owner-managed partnership established in 2004 and headquartered in London, with a US office in San Francisco. Generation Investment Management LLP has approximately $22 billion of assets under management.

New Brunswick Marine Research Centre to study impact on spill clean-up chemicals on aquatic life

The Canadian Ministry of Fisheries, Oceans and the Canadian Coast Guard recently announced that it is investing $2.4 million in scientific research at the Huntsman Marine Science Centre in New Brunswick.

With this investment, the Centre will study how spill response measures, such as the use of dispersant chemicals, affect fish and other aquatic species of interest. The goal of the project is to ensure the use of effective response measures, without harming ocean life in the event of a spill.

The Huntsman Marine Science Centre is located in St. Andrews, New Brunswick. The Centre is engaged in a broad range of marine science and applied research initiatives.

Huntsman Marine Science Centre (Source: huntsmanmarine.ca)

British Columbia’s New Groundwater Protection Model

The British Columbia Ministry of Environmental Protection and Sustainability recently posted a renewed version of the Province’s Groundwater Protection Model (GPM). The latest model version has been posted to the ministry’s webpage at: Policies & Standards – Province of British Columbia. Users will need to download the new model version to conduct calculations under Protocol 2 – Site-Specific Numerical Soil Standards (SSS) and Protocol 13 – Screening Level Risk Assessment.

Questions regarding the GPM and associated Technical Guidance 13 should be directed to George.Szefer@gov.bc.ca andAnnette.Mortensen@gov.bc.ca.

Also, the B.C. Environment Ministry has posted a draft version of seventeen new analytical methods for public comment. The analytical methods can be found at “Methods Posted for Review”.

Public comment on the new methods will be accepted until June 17, 2019. All public comments should be direct to  Joyce Austin, Senior Provincial Laboratory Specialist, Knowledge Management Branch at Joyce.Austin@gov.bc.ca.

Technical questions regarding the proposed new methods should be directed to Mark Hugdahl (BCELTAC Chair) atMark.Hugdahl@alsglobal.com.