RCRA Overview

The Resource Conservation and Recovery Act (RCRA) was passed by the United States Congress in 1976 to address problems caused by municipal and industrial waste. RCRA’s focus is on active and future waste facilities and covers generation, transportation, treatment, and disposal of hazardous wastes. Abandoned and historical sites are managed under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) which is also knows as Superfund (paraphrased from information at the EPA website, here and here).

RCRA waste characterization parameters include:

  • ignitibility (flashpoint);
  • corrosivity (pH);
  • reactivity (reactive cyanide & reactive sulfide);
  • toxicity characteristic leaching procedure (TCLP) pesticides;
  • TCLP herbicides;
  • TCLP volatile organic compounds (VOCs);
  • TCLP semivolatile organic compounds (TCLP SVOCs);
  • polychlorinated biphenyls (PCBs);
  • and the “RCRA 8” metals: silver, arsenic, barium, cadmium, chromium, mercury, lead, and selenium.

Other analyses such as chloride, paint filter, and total petroleum hydrocarbon (TPH) suites may also be needed depending upon site history, the waste generator or contract. TCLP Metals is also occasionally required or useful.

Analytical notes:

  • “TCLP” is not one test, but several, and though some of the sample preparation efforts may be combined, this is not possible for every method, and none of the analyses can be combined; each requires a separate method. It is important to account for this in cost estimates.
  • As shown above, reactivity is two methods, both of which are wet chemistry methods.
  • Additionally, although a large carbon range may be analyzed under a single TPH method, the information needed for specific sites requiring THP analysis usually requires one to three separate TPH methods: TPH-gasoline range organics (GRO), TPH-diesel range organics (DRO), and TPH – oil range organics (TPH-ORO). Site history can help determine which carbon ranges are needed.
  • If analysis for polynuclear aromatic hydrocarbons (PAHs) in required, this usually cannot be grouped with SVOCs, but rather, requires a selected ion monitoring (SIM) analysis. Both analyses may be listed as 8270 methods.
  • “Oil & grease” is generally no longer required.
  • There is no such method as “oil & gas”, and anyone requesting such a method usually needs TPH analyses.

RCRA suites are used on environmental projects to determine if waste is hazardous and what type of disposal is required. Some suites may be dropped if site history is well-known and documented; however, any accepting landfill must approve such measures. If such an approach seems logical, consult with the accepting landfill prior to proceeding.

CERCLA suites vary by site and are based upon site history and investigation data. CERCLA suites are formalized in a Record of Decision (ROD), which is based upon the Remedial Investigation/Feasibility Study (RI/FS).

If you need assistance determining the appropriate analytical suites for your site, please click on the contact page and send us an email for an estimate.

Sustainable Development Goals in the Developed World

The Sustainable Development Goals (SDGS) adopted by the United Nations (UN) in 2015 include clean water and sanitation, an end to poverty and hunger, gender equality and access to quality education, climate action, and good governance. The SDGs are the product of multilateral participatory process and are universal. As such, they are as critical for developed nations as well, and businesses and individuals in developed nations have a great capacity to make progress towards these goals. The UN website provides a list of actions citizens in developed nations can take. Although most people will not be able to implement every action, in countries with large populations and significant resource use, adopting even a handful of new practices can have a huge impact globally.

SDG #17 is “Revitalize the global partnership for sustainable development”. Businesses have a key role to play in re-centering the well-being and the planet as a focus for action and as an action to ensure long-term success. Businesses can take direct action towards achieving SDGs # 1 & 2 “No Poverty” and “Zero Hunger” through fair pay and hiring practices. Individuals can support SDG #5 “Gender Equality” by recommending women for jobs, high-profile assignments, promotions, and job placements. These actions also make progress toward SDG #8 “Decent Work and Economic Growth” since data show that gender parity in the workplace increases profits (DezsÖ and Ross, 2012 and Herring, 2009). Additional actions can be taken by responsible businesses to increase innovation and reduce negative environmental impacts without reducing profits (Illic, Staake, & Fleisch, 2008 and Lash & Wellington, 2007).

Discussions related to some of these issues issue can be found at our website in articles such as Moral Agency & Purpose Driven Business, Water and Agriculture in Colorado and Watershed Health. The full list of SDGS and additional information about each SDG can be found at: http:www.un.org/sustainabledevelopment/sustainable-development-goals. You can learn more about the World Business Council for Sustainable Development at http://www.wbcsd.org.


What Are Your Data Telling You?

A Budget and Schedule Streamlining Review & Summary of Anaerobic Reductive Dechlorination of Chlorinated Hydrocarbons

Several previous articles discuss simplifying and streamlining environmental data acquisition and evaluation.

Mindful consideration of the information covered in the aforementioned articles can increase project margins and provide tools for avoiding some common pitfalls, such as:

  • Misinterpretation of nondetect data as an indication that a site is not contaminated when samples have been diluted such that quantitation limits (QLs) are too high to support the conclusion. This can occur because
    • Matrices are not amenable to the analyses.
    • Contamination concentrations require large dilutions.
    • Analysts are reluctant to analyze samples at lesser dilutions due to not understanding project purposes, inexperience, to avoid instrument maintenance, or to protect expensive and delicate instrumentation.
  • Failure to plan for an approach to achieve site closure when it is not possible to achieve detection limits (DLs) less than regulatory levels
    • Because regulatory levels are usually established using toxicological studies, not instrumental analyses, current methodologies may not be able to achieve these values.
    • Identifying the approach for addressing this issue during the project planning phase, and securing client and regulatory approval of the approach when the plan is finalized, is more efficient than securing approval after samples have been analyzed.
    • Additionally, planning for this issue allows for identification of more sensitive methodologies if they exist and performance of a cost/benefit analysis for the use of such methods with cooperation of clients and regulators.
    • Equally as important, it provides a tool to avoid misinterpretation of such data as an indication that the site is contaminated.
  • Attempting to remediate to levels less than native background.
    • Sometimes Federal regulatory levels are less than native levels (ex: arsenic in the West) and it is crucial to perform site assessments against background data (or perform background studies) in such cases.
  • Long-term monitoring of common contaminants that have been misidentified as contaminants of concern (COC). In such cases, assessment of historical data is necessary and several sampling rounds may be required to identify and gain approval for eliminating these parameters.

These pitfalls are easily avoided with proper assessment of site data and data requirements. However, site data can provide far more information. This may require analysis of parameters that are not COCs so careful planning is important, because analysis for parameters that do not provide relevant information wastes time and money and does not support the protection of human health and the environment.

Natural attenuation is one example of a remediation process where analysis for non-COCs can provide valuable information. Natural attenuation occurs when naturally occurring processes reduce contamination in soil and groundwater. These processes occur in situ and include dilution, dispersion, volatilization and other natural processes. Monitored natural attenuation (MNA) is an approved remedy at some sites and involves collection of data to assess and document the efficacy of the attenuation process.

When MNA is in place, non-COC data can be used to confirm that conditions are amenable to attenuation and the presence of breakdown products. Aerobic or anaerobic conditions (or one and then the other), specific pH values, and the presence of specific metals and/or microbes may be needed. Natural attenuation may be enhanced through forcing a site to anaerobic conditions, introducing bacteria and/or feeding native bacteria, and/or temporarily altering the pH. In each case, data must be collected to determine if the desired conditions have been achieved, and subsequent data must be collected to determine if attenuation was enhanced.

Contaminants that may undergo natural attenuation include chlorinated solvents, certain metals, radionuclides, and oil & gas-related aromatic hydrocarbons such as benzene, toluene, ethylbenzene, and xylenes (BTEX). For this article, the MNA process to be further considered is anaerobic reductive dechlorination (ARD) of chlorinated hydrocarbons, specifically ARD of the volatile organic compounds (VOCs) tetrachloroethene (PERC or PCE) and trichloroethene (TCE).

The primary or initial contaminant for this process may be either PCE or TCE. These contaminants are present in the environment due to past use as degreasers, dry-cleaning agents, and through use in manufacturing processes. The ARD process breaks down PCE to TCE, and TCE subsequently breaks down to cis-1,2,-dichloroethene (DCE) and trans-1,2-DCE. 1,1-DCE may also be produced. The DCE isomers break down to vinyl chloride, and vinyl chloride breaks down to ethene. If all PCE and/or TCE breaks down to ethene, remediation is complete, because ethene is not an environmental risk.

To assess if ARD is occurring, break down products are included in the analytical data set. If TCE (and/or PCE) concentrations are decreasing and vinyl chloride concentrations are increasing, the process is successfully progressing. Regulatory criteria for vinyl chloride are stringent and the concentrations and may exceed the action limit; however, additional actions are not needed to address the exceedances unless the process stalls at this stage or  if vinyl chloride is also present because manufacturing at the site included polyvinyl chloride (PVC) production. .

Because MNA can be unacceptably time-consuming, often taking many decades to progress, various enhancement processes, as previously noted, have been implemented. The ARD process may be bio-attenuated with the microorganisms Dehalococcoides (abbreviated as DHC or DHE), which can be naturally occurring or inoculated into a site. Even when naturally occurring, the native population may not be great enough to speed ARD to the desired extent. In such cases, the microorganisms may be fed with vegetable oil or molasses. The table below shows some of the analyses that may be used at an ARD site.

ARD Table

Additional information about ARD and various analytical parameters can be found at the EPA Clu-In website, here. The information at the link provides more detailed and extensive information as well as links to additional resources. However, in the experience of the authors, if results show that ARD is occurring, assessing other parameters at the frequency indicated at the Clu-In link is not necessary. Some of the tabulated analyses listed are high-cost specialty analyses that may not add value for your specific project. If you are unsure of the frequency and type of analyses needed at your site, we invite you to contact Oak Services, LLC for a consultation.

 References & Resources

2007, Agency for Toxic Substances & Disease Registry (ATSDR), https://www.atsdr.cdc.gov/csem/csem.asp?csem=15&po=5, November.

2014, ATSD, https://www.atsdr.cdc.gov/phs/phs.asp?id=263&tid=48, October.

1999, United States Environmental Protection Agency (USEPA) https://www.epa.gov/sites/production/files/2014-02/documents/d9200.4-17.pdf, April.

2012, USEPA, https://clu-in.org/techfocus/default.focus/sec/bioremediation/cat/Anaerobic_Bioremediation_(Direct), -.

2001, Unites States Geological Survey (USGS), Natural Attenuation Strategy for Groundwater Cleanup Focuses on Demonstrating Cause and Effect, January.

Moral Agency & Purpose-Driven Business

The 22nd Conference of the Parties (COP 22) and the twelfth meeting of the Parties to the Kyoto Protocol (CMP 12) recently concluded in Marrakech, Morocco. More information can be found at the COP 22 website, here.

As we discussed in our article on COP21, COP 21, Sustainable Development Goals & A Step towards Global Thinking, scientists estimate that a global temperature increase of greater than 2º C (3.6 º F) above pre-industrial levels would be catastrophic; however, if temperatures continue to increase at the current rate, an increase of approximately 5ºC (9 º F) is likely within the next two to three decades (Earth Science Data, 2014). At the United Nations Sustainable Development Summit on September 25, 2015, world leaders adopted the 2030 Agenda for Sustainable Development. This agenda included the Sustainable Development Goals (SDGs), 17 measurable goals that range from ending world poverty to achieving gender equality and empowering women and girls by 2030. SDG 13, Climate Action, calls for urgent action to combat climate change and its impacts. Our article discussing COP21 provides a summary of the SDGs. Details about individual SDGs can be found here: http://www.undp.org/content/undp/en/home/mdgoverview/post-2015-development-agenda.html.

The United Nations development Programme (UNDP) has provided support to governments working to achieve the SDGs in efforts to balance what it identifies as the three pillars of sustainable growth: social progress, economic growth, and environmental protection. However, businesses have a large part to play in how well the SDGs are achieved regardless of regulatory framework, government support, or directives. Technologies exist to support companies’ efforts to measure progress towards meeting the SDGs, and these technologies are available to most businesses whether they are based in countries that require such efforts or not.  With the unanticipated paradigm shift that may be happening in the governments of some Western nations, it may soon fall to business to provide the voice of environmental leadership and innovation in the West. This will include integrating the SDGs into the structure of company vision and operation. While these changes will no doubt prove challenging, they may also offer a new opportunity for the business sector to cast a wider net as innovative, integrated and purpose-driven.

Every business model tells a story. A good business model will tell a story that supports a long-range vision and goals for long-term success. Because long-range goals must value employees, clients, and consumers, sound business models cannot be built solely on the motivation for profit. Instead, there must be room for innovative thinking, technical advances, and ethical practice. Practicing business ethically should not be dependent upon regulatory restrictions, but rather be built upon support for approaches that are inclusive of caring about humans and the human condition, with an ability to embrace social and cultural development. All business requires support from humans, as workers, clients, and consumers. And humans are moral beings, with moral agency and responsibility. As such, purpose-driven firms have a mandate to support sustainable development, especially in the midst of moral ambiguity and contradiction. Sustainable development includes socially responsible practices and actions, and environmentally responsible actions are socially responsible actions.

Climate change is the most important environmental issue facing our species, and we must turn our attention to mitigating its effects. Relentless pursuit of profit for its own sake without attention to these issues, in the end, results in no profit, because there will soon be nothing left to profit from.

The strength of the correlation between human activity and climate change is clearly illustrated here: http://www.bloomberg.com/graphics/2015-whats-warming-the-world. The data used for these graphs is from NASA’s Goddard Institute for Space Studies. The lack of a control planet against which to assess the data denies us of the final definitive data set; however, we simply do not have a control planet, and so no reasonable arguments can be made to continue down a path that appears to lead toward planet-wide catastrophe. We must become better stewards of our Earth, and we must incorporate actions to those ends into standard business practice. It’s important to remember that we have nowhere else to go.

 References & Resources

Bloomberg the Company, 2015. What’s Really Warming the World? June.

Earth System Science Data, 2014. Global Carbon Budget 2014, Abstract here: http://www.earth-syst-sci-data-discuss.net/7/521/2014/essdd-7-521-2014.html

Harvard Business Review, 2002. Why Business Models Matter. May.

The National Aeronautics and Space Administration: http://www.nasa.gov

United Nations Conference on Climate Change (COP21/CMP11) website: http://www.cop21.gouv.fr/en/

United Nations Conference on Climate Change (COP22/CMP12) website: http://www.cop22-morocco.com/

United Nations Development Programme Website: http://www.undp.org/content/undp/en/home/presscenter/pressreleases/2015/09/24/undp-welcomes-adoption-of-sustainable-development-goals-by-world-leaders.html


Watershed Health

watershed n.

  1. A ridge dividing the areas drained by different river systems.
  2. The area drained by a river system.

 Webster’s New World Dictionary of the American Language, 1964

 More than 70 percent of the Earth’s surface is covered with water and the natural water cycle provides water to Earth as a recyclable resource. However, Earth’s water supply is not infinite, nor is it infinitely renewable. A powerful graphic on the United State Geological Survey (USGS) website shows how small the volume of water on Earth truly is. In this image, all water on, in, and above the Earth is represented as a sphere. The sphere is not large in comparison to the planet, with a diameter running roughly the distance from Utah to Kentucky. A much smaller sphere represents the volume of all fresh water on Earth. And a tiny sphere represents all of the fresh water in rivers and lakes on the planet. This tiny sphere is the water that sustains us and most of the other life on the planet. You can see this graphic here. This imagery underscores that water is a precious resource. Our local watersheds provide us with the greatest opportunity as individuals to preserve and protect this resource.

The definition of watershed above comes from a dictionary that, as of this writing, is 52 years old. More current dictionaries also include a secondary definition: a time when an important change or event occurs. With rapidly increasing populations creating challenges for meeting and managing urban and agricultural needs, we are facing a watershed moment in protecting and restoring watershed health.

Human factors adversely affecting the volume and quality of water in a watershed include:

  • Creation of impervious land cover, such as parking lots and roads, which inhibit infiltration into the soil, increase incidents of flooding, and decrease water quality.
  • Consumptive use that reduces, and in some cases eliminates, evapotranspiration (Medellín-Azuara, Kyaw, Yufang, Lund, Hart, Kent, Clay, Wong, Leinfelder-Miles, 2015).
  • Extraction and consumptive use creating drought conditions leading to collapse of river and estuary ecosystems (Rosenfeld, 2016).
  • Contaminated run-off from pesticide and herbicide application and chemical lawn fertilizers (Schueler, 2000).

Restoring and protecting watershed health makes sense environmentally, ethically, and economically. Healthy watersheds provide protection from erosion and flooding. Development costs for best management practices (BMPs) protective of watershed health do not increase construction costs while increasing property values (Schueler, 2000). Economic benefit is also derived from protected areas unavailable for land development. Undeveloped areas that provide habitats for wildlife also support recreation such as hunting, fishing, birdwatching and hiking. The State of New Jersey has estimated the value of freshwater wetland services at 9.4 billion dollars per year (Mates, 2007).

Changes in individual behavior can improve watershed health. The increase in household recycling and decreases in littering and oil dumping in the past few decades indicate that environmentally protective changes in behavior can be adopted and normalized. Actions that reduce run-off and actions that reduce the amount of contaminants introduced into the runoff can increase water quality and encourage natural infiltration, which helps protect local watersheds. Conserving and re-using household water where feasible is a good way for individuals to protect the local watershed.

Some other actions individuals can take include:

  • Applying no fertilizer to lawn and/or ensuring chemical fertilizers applied do not contain pesticides and herbicides.
  • Applying pesticides and herbicides to yards and outdoor areas only as a last resort.
  • Inspecting septic systems and pumping them out when needed.
  • Replacing non-native plant cover, such as turf lawns with native fauna, including trees.

The last bullet brings us to urban watershed forestry, which among other benefits, offers an opportunity for municipalities, developers, and individuals to embrace BMPs that protect and increase the quality of local watersheds. The United States Division of Agriculture (USDA) Forest Service has been working to increase general knowledge on the benefits of urban watershed forestry.

Some benefits of trees to the watershed include:

  • Reduction of contaminated run-off through evaporation from the canopy, water uptake through tree roots, and increased soil-drainage in the root zone.
  • Absorption of pollutants such as carbon monoxide and particulate matter.
  • Reduction of air temperature, reducing formation of pollutants and indirectly decreasing energy use by surrounding households.

More benefits and more details regarding urban watershed forestry can be found at the Center for Watershed Protection and US Forest Service. The US Forest Service also provides guidance to planting trees on residential lawns. Information regarding the many other benefits of urban forestry can be explored at the USDA Forest Service Urban and Community Forestry Program site.

 References & Resources

2016, California WaterBlog, Comparing Delta Consumptive Use preliminary Results from a Blind Model Comparison, October.

2016, Center for Watershed Protection, Urban Watershed Forestry, -.

2016, Center for Watershed Protection, Watershed Science Bulletin, -.

2016, SFGATE, SF Bay ecosystem collapsing as rivers diverted, scientists report, October.

2016, United States Department of Agriculture (USDA) Forest Service, Urban and Community Forest Program, -.

2016, Unites States Geological Survey (USGS), What is a watershed?, October.

2015, Medellín-Azuara, Kyaw, Yufang, Lund, Hart, Kent, Clay, Wong, Leinfelder-Miles, Delta Consumptive Water Use Comparative Study, -.

2013, Colorado Conservation Board, Agricultural Economic and Water Resources: Methods, Metrics and Models – A Specialty Workshop, July.

2007, Center for Watershed Protection, Watershed Forestry Resource Guide, -.

2007, Mates, Valuing New Jersey’s Natural Capital: An Assessment of the Economic Value of the State’s Natural Resources, April.

2000, Claytor, Assessing the Potential for Urban Watershed Restoration: The Practice of Watershed Protection, -.

2000, Schueler, The Economics of Watershed Protection, -.

2000, Schueler, On Watershed Education: The Practice of Watershed Protection, -.

2000, Schueler, Watershed Protection Techniques: Understanding Watershed Behavior

Environmental Analyses and Your Project Budget, Part Two

As we discussed in Part One of this two-part series of articles, managing the budget is an important aspect of any project, and with Performance Based Contracts (PBCs), it is critical. In Part One, we discussed streamlining analytical parameters and what to consider when determining when and how to do so. In a previous article, we discussed what your laboratory needs to know to provide you with the most accurate pricing for your project. In this article, we focus on questions about how your analyses will be used and how the answers can further help manage your budget and schedule.

What decisions hinge upon your analytical results? Will you have dig-sites that must be left open as you await the results? Will discharge operations stall while you wait?

In any project where stand-by time is accrued prior to receipt of analytical results, compare stand-by costs to mark-ups for expedited turn-around-times (TATs) for analytical results. Ideally, this comparison is performed while generating your estimate; however, it can also occur during project planning. In almost all cases, the costs for stand-by labor-hours exceed the mark-ups for expedited TATs for results, even at 100% and 200% mark-ups for the expedited TATs. It’s important to confirm that your laboratory can meet your TAT needs and identify any methodological limitations to meeting those TATs (some methods can be performed within 24 hours while some cannot). Sometimes, clients will permit action with preliminary or partial results after an initial wave of full results if results can reasonably be anticipated to be similar for each event. Our article on establishing a relationship with your laboratory  and Part One of this article provide some guidance for communicating with laboratories and clients.

Does your laboratory offer sample pick-up? Can you deliver samples? Does the laboratory offer on-site packing services?

If you subcontract with a laboratory that offers pick-up at your location, compare costs of this service to costs of shipping. Alternately, a local laboratory may make it possible for your field personnel to drop off samples at the end of the day, which can also save shipping costs. Some laboratories also offer sample packing at field sites. It may be worth considering the costs of this service vs. the possibility of burn-out for field staff if you have limited personnel who will otherwise be packing samples after a long day in the field. The potential for mistakes in sample labelling, packing, and Chain-of-Custody procedures increases at the end of a long work day, and such errors can lead to the need to reanalyze or even re-collect samples, thus increasing costs. Personnel turn-over resulting from burn-out can also be costly. While these concerns do not apply to every project, it is worth a forthright, proactive assessment of whether it applies to yours to mitigate the need to solve problems that could have been prevented.

What level of data validation is needed? Is it imperative to wait for final validation or can actions move forward based on preliminary results?

Depending upon the nature and sensitivity of your project, your client may permit action based on preliminary data verification prior to validation, may approved limited validation, or may – if your laboratory and data validation group remain consistent – approve actions based on preliminary data and data verification following one or more rounds of full validation.

It is important to consult with your client and ensure all actions are ethical and support achievement of project objectives prior to taking these actions. In our article about data validation, we discuss how environmental data validation can mitigate risk, including budgetary risk, for projects. We also provide insight on when it is appropriate to perform reduced validation and when validation may not be required at all. Once you have ensured you are performing the proper level of validation, streamlining your analytical parameters as discussed in Part One will result in streamlined validation, further supporting budget and schedule management.

Actions that reduce stand-by time or streamline work by limiting the focus to relevant details will have a positive impact on schedule and budget. Assessing project types for determining when it is ethical and technically sound to approach your client with these questions is beyond the scope of this article. If you are unsure about this for your own work, we invite you to contact us to determine if contracting Oak Services, LLC for a brief consultation regarding these concerns or for other types of Chemistry Program support is right for you.


Environmental Analyses and Your Project Budget, Part One

Managing the budget is an important aspect of any project, and with Performance Based Contracts (PBCs), it is critical. PBCs offer greater opportunities for technical innovation and efficiency but can also pose financial risks. In a previous article, we discussed what your laboratory needs to know to provide you with the most accurate pricing for your project. In this article, we focus briefly on questions you should be asking of your team and actions you can take to help manage your budget, streamline your work, and increase client confidence.

At what stage in the Superfund process is your project? Have Contaminants of Potential Concern (COPCs) or Contaminants of Concern (COCs) been identified? Once a Record of Decision (ROD) has been issued, site characterization has been performed, and your contaminants have been determined.

Ideally, you identified your intention to evaluate only COCs during the proposal stage of your project. Your contract award and approval of your project plans subsequently indicate client and possibly regulatory approval of this approach. Alternately, client approval can be confirmed during scoping sessions.

If analyses for parameters other than COCs are planned on a new or on-going project, why?

It is prudent to discuss changing to COC-only analysis and reporting with clients and regulators, but push-back on ROD-compliant actions is rare. Unless there is a compelling reason to perform or continue performing analyses for non-COCs, there is no ethical or legal reason to do so.

Clients are usually receptive to simplifying approaches. If you are managing an on-going project or taking over an existing project, an historical data review may be prudent. Common laboratory contaminants sometimes show up as COCs. Contaminants that have been remediated may be listed. A thorough review of historical data can identify such parameters and determine if removal from the COC-list is appropriate. This requires formal approval from the client and regulators, but it is not usually an onerous task when taken on by personnel with experience evaluating and interpreting analytical data. It is even possible that parameters that are naturally occurring but exceed Federal action levels are listed (example: arsenic in the Western United States). In such cases, identifying background studies for your client or proposing to your client that one be designed and executed is prudent.

If you are conducting site characterization, your work is key to identifying appropriate COCs. Is site history known? Are you narrowing your focus on contaminants that are reasonably expected to be present or are you taking a “let’s do everything” approach? If the latter, is there a compelling reason to do so? Are there data gaps or suspected historical activities? If not, why do what is not needed? Do background studies exist for the site or region? Should you propose one?

Meetings with clients and regulators may be needed to streamline your analytical parameters, and formal approval may be needed, but these discussions show that you are attending to the details of the project rather than going through the motions. Asking your laboratory to reduce your analyte list only to those parameters that are meaningful to your project is a scientifically sound, ethical way to reduce not only analytical costs, but also reduce internal costs by streamlining data review, interpretation, and reporting.

Water and Agriculture in Colorado

“Whiskey’s for drinking, water’s for fighting” is a quote attributed to Mark Twain often used in discussions about water rights in the American West, a region where water is scarce and water rights have long been contentious. Another elucidating quote comes from Ralph Moody’s “Little Britches, Father and I Were Ranchers”, a book recounting Moody’s experiences after moving from New Hampshire to a Colorado Ranch in 1906. Moody’s quote is etched into the sidewalk at the Lakewood Heritage Center in Lakewood Colorado and reads, “All you got to have for this ground is water, and God help the man that ain’t got it.”

In our home state of Colorado, the average annual precipitation is less than 15 inches (1981 – 2010). To put this into perspective for other regions of the United States, the annual precipitation for North Carolina is approximately 42 inches and for Wisconsin, it’s about 35 inches. This is not a result of recent droughts. Water has always been a scarce and precious resource in the region and this history of water scarcity affects water management and regulations in Colorado. Settlers coming to Colorado in the late 1850s built ditches to divert water from creeks or streams to irrigate crops and for domestic use. Because of the scarcity of water, however, the water source was often not adjacent to the property and head gates were built to divert the water into ditches and reservoirs. This method of water acquisition evolved into the “first in time, first in right” basis of Western water law, with those who filed for water rights first gaining senior rights. Those with junior rights could not divert water until the senior rights were satisfied regardless of location or proximity to the source. These types of regulations are still in place today.

Water originating in Colorado travels to the Atlantic and Pacific Oceans with an average of 10,434,000 acre-feet of water flowing out of the state, supplying water to more than 21,000,000 households across the nation (one acre-foot = 325,851 gallons of water) (Denver Water, 2016). Within Colorado, most of the water originates on the Western slope but most of the state’s population lives on the Eastern slope. To address this, water is moved from the Western slope through trans-basin diversions to the Eastern Slope at a rate of about 475,000 acre-feet per year, with more than a third of the volume going to Denver Water (Denver Water, 2016).

With population growth exceeding the national average, the water supply needs for urban areas in Colorado are rapidly increasing. Currently, cities and municipalities purchase water rights from agricultural lands and transfer the rights to the cities. With water rights in Colorado selling for thousands per acre-foot, selling the rights can be too attractive for struggling farmers to pass up. And when the water rights are sold, agriculture on the impacted land also stops. This practice is known as “buy and dry.” Without the benefits of agriculture, community benefits are lost, tax revenue for the water rights may be lost, open space decreases, and the return of water into the water supply is not guaranteed. With water not returned to the watershed, drinking water is lost for the community and for local wildlife, and there is a significant negative impact to tourism and local activities that rely upon a healthy watershed, such as river rafting, fishing, hunting, skiing, snow-shoeing, snow-boarding, wild-life watching, and hiking. Moreover, the need for imported foods and livestock increases and food security decreases. As succinctly stated in the Project Completion Report for the Agriculture Economic and Water Resources: Methods, Metric, and Models – A Specialty Workshop, (Colorado Water Board, 2013): “No Farm, No Food.”

The impact of loss of agriculture can also be measured economically. There are seven river basins in Colorado: The Yampa/White River Basin, the South Platte River Basin, the Arkansas River Basin, the Rio Grande River Basin, the San Juan/Delores River Basin, and Gunnison River Basin, and the Colorado River Basin (see map). In the Colorado River Basin alone, there are more than a million acres of agricultural lands and most of the water from the Colorado River Basin – an estimated 90% – goes to agriculture. Water from the Basin serves approximately 30 million people and is used in irrigation for almost two million acres of land, producing 15 percent of the nation’s crops and 13 percent of its livestock, which amounts to about $1.5 billion in agricultural benefits.

Efforts to achieve conservation goals so that the needs of both agriculture and the increasing population can be met include water sharing between urban and agricultural communities and improved methods of water delivery and application. However, solutions to the challenge of meeting these water needs in a water-scarce state are not simple or easily achieved. For example, micro-irrigation systems, which are the most efficient method of irrigation are also costly. Micro-irrigation systems such as surface drip, subsurface drip irrigation (SDI), and micro-sprinklers offer flexible water application and decrease water loss; however, they can be costly and difficult to maintain. SDI can cost more than $1,000/ acre to implement, plus $120/acre in annual upkeep. In addition to high costs, the equipment may clog and subsurface clogs may go unnoticed until the entire system has been compromised.

Some alternatives include conservation easements to help protect water supplies and farmers leasing rather than selling their water rights to urban areas. However, water managers for the urban areas feel that owning the water rights is the only guarantee of water supply, creating a conflict with agricultural groups’ desires to retain senior rights to support farming. One thing about which water managers and farmers are in agreement is that that long-term solutions are needed to meet the water needs of the State’s increasing population while protecting the farming industry.

The 2013 Specialty Workshop convened by the Colorado Agricultural Water Alliance (CAWA) and the Arkansas Basin Roundtable (ArkBRT) included experts and stakeholders (such as farmers) and focused on the economics of water resources used for agriculture. Public‐centered messaging needs identified in the workshop included many of the concerns noted above as well as the importance of understanding that “conversion of agricultural land to other uses is almost always irreversible”. Groups such as the Colorado Ag Water Alliance continue to hold workshops to identify solutions to such concerns.

The Statewide Water Plan was finalized in 2015 but is intended to be a dynamic document.  The plan provides detailed information about water supply and demand. The plan goes on to discuss water management and protection and identifies measurable goals for the future. Conservation, innovation, and education are key. Various experts and stakeholders are working together to ensure future water needs are met for urban and agricultural uses. These collaborative efforts can increase our optimism about the future of agriculture in Colorado; however, with such a scarce but crucial resource and an ever-increasing population, it’s important to remain vigilant and educate ourselves so that we may take personal and professional actions to ensure the future of agriculture is secure and examine how our ever-increasing water needs can be met.

References & Resources

2016, City of Lakewood, Lakewood Heritage Center, -.

2016, Colorado Ag Water Alliance, July.

2013, Colorado Conservation Board, Agricultural Economic and Water Resources: Methods, Metrics and Models – A Specialty Workshop, July.

2016, Colorado Foundation for Water and Education, Buy & Dry in Colorado Agriculture, -.

2016, Colorado River Users Association, Agriculture, -.

2016, Eagle River Watershed Council, The Current, January.

2014, Denver Post, Colorado Girds for Proliferating People and Increasingly Scarce Water, November.

2015, Denver Post, Colorado Shies from Big Fix as Proliferating people Seek More Water, July.

2015, Denver Post, Colorado Farmers Grow More Food on Less Water Amid Rising Competition, August.

2016, Denver Water, Denverwater.org, Water Rights Planning, -.

2016, Google, Unit Converter, –.

2013, Lee and Plant, Colorado College, Agricultural Water Use in the Colorado River Basin: Conservation and Efficiency Tools for a Water Friendly Future, -.

1991, Moody, Little Britches: Father and I Were Ranchers, -.

2016, The Nature Conservancy, A “collaborative conservationist” builds relationships with farmers and ranchers along the Colorado River, -.

2005, State of Colorado, Colorado.gov, Department of Natural Resources Map, March.

2015, State of Colorado, Colorado.gov, Colorado’s’ Water Plan – Final 2015, November.

2016, U.S. Climate Data, usclimatedata.com, -.

Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP) – A Consultant’s Overview

In 2005, the Director of the Federal Facilities Restoration and Reuse Office of the United States Environmental Protection Agency (EPA) issued a memo stating:

“The Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) has been approved by the Office of Solid Waste and Emergency Response (OSWER) and the Department of Defense (DoD) for use at federal facility hazardous waste sites. The purpose of this Memorandum  is to inform you that Quality Assurance  Project Plans prepared and approved according  to the UFP-QAPP meet all the requirements of EPA Requirements for Quality Assurance Project Plans, (QA/R-5) issued by the Quality Staff of the Office of Environmental  Information.

…the UFP-QAPP elected to take on topics that had not been addressed  in the past, beginning with the adequacy of sampling plan design, through field sampling activities, to data review, with an emphasis  on the quality of data, related to the decision that requires environmental data.” The EPA memo in its entirety can be read here. http://www2.epa.gov/sites/production/files/documents/oswer_9272.0_20.pdf

In April 2006, the Office of the Under Secretary of Defense released a memorandum stating:

“In March 2005, Thomas Dunne, Acting Administrator for the U.S. EPA Office of Solid Waste and Emergency Response (OSWER) joined me in signing the Uniform Federal Policy for Quality Assurance Project Plans(UFP-QAPP),  thereby formally adopting the policy for use at Federal facility hazardous waste sites. Recently, EPA issued a directive and guidance for EPA Regions to require use of the UFP-QAPP for collection of data at Federal facility hazardous waste sites involving CERCLA, RCRA, and Brownfields type projects. The purpose of this memorandum is to request that Components begin immediate implementation of the policy.” The full DoD memo can be read here: http://www.denix.osd.mil/edqw/upload/ADUSD_MEMO.PDF

UFP-QAPP stands for Uniform Federal Policy – Quality Assurance Project Plan. It is the result of extensive collaborations between the EPA, the DoD, and the Department of Energy (DOE). The original 37 work-sheet version of the UFP-QAPP was released by the EPA in 2005. By 2009, most DoD components had adopted the UFP-QAPP for environmental work. Although the DOE was instrumental in developing the UFP-QAPP, it has not to-date formally adopted the policy; however, its use may be required on DOE projects under specific programs.

The updated, optimized 28 worksheet version released by the EPA in 2012 combines several worksheets to reduce redundancy. The prompts were also updated to be more helpful and relevant to industry than those found in the original version. The optimized format with prompts can be found here: http://www2.epa.gov/sites/production/files/documents/ufp_qapp_worksheets.pdf

The UFP-QAPP is much more than a traditional Quality Assurance Project Plan (QAPP) and if the current optimized template is followed with care, all aspects of project planning except Health & Safety will be considered. The document was intended to be a Sampling and Analysis Plan (SAP) inclusive of a Field Sampling Plan (FSP) and QAPP. It was also intended to be a collaborative document written by project managers, hydrogeologists, chemists, and engineers working together, although it is wise to have a lead author to ensure a coherent and cohesive whole, as is the case with any other project document. In its current form, the UFP-QAPP has the potential to fulfill all Work Plan (WP) requirements except Health & Safety.

Although some Worksheets focus on laboratory actions, data validation, and chemical quality control (QC), this is a small part of the UFP-QAPP. The text below provides a summary of Worksheets for which information must be provided by Project Management and/or technical leads:

QAPP Worksheet #1 and 2: Title and Approval Page

This page requires identification of the contract number, the lead organization’s Project and Quality Managers, the relevant regulatory agencies and other stakeholders, as well as a list of previous reports related to the project. Once the document is complete and finalized, this worksheet is where client and contractor Project and Quality Managers sign off to indicate approval of the final plan.

QAPP Worksheet #3 and 5: Project Organization and QAPP Distribution

This page may simply be an organizational chart. It requires inclusion of specific individuals within the lead agency as well as contractor and subcontractor personnel.

QAPP Worksheet #4, 7 and 8: Personnel Qualifications and Sign-Off Sheet

Names, project roles, education, and certifications are to be listed here. Once the UFP-QAPP is complete, primary personnel should also sign here to indicate that they agree to follow the plan.

QAPP Worksheet #6: Communication Pathways

The prompt for the optimized version of this worksheet states: “This worksheet should be used to document specific issues (communication drivers) that will trigger the need to communicate with other project personnel or stakeholders. Its purpose is to ensure there are procedures in place for providing the appropriate notifications and generating the appropriate documentation when handling important communications, including those involving regulatory interfaces, unexpected events, emergencies, non-conformances, and stop-work orders.” As a general rule, this is a good place to document who is responsible for day-to-day communications as well and with whom and how (email, phone, in person) those communications are to occur.

QAPP Worksheet #9: Project Planning Session Summary

Project kick-off meetings and any other scoping sessions should be documented in Worksheet #9. Ideally, the technical lead(s) and/or contractor Project Manager ensures all of the necessary information is recorded and supplied to the lead author. Although the EPA does not recommend simply taking Worksheet #9 to the scoping sessions, it can be useful as a guidance for what information is needed. In the context of the UFP-QAPP, “scoping session” means any meeting during which the project scope is discussed and alignment is ensured even if there are no modifications to the formal Scope of Work.

The EPA offers workshops for UFP-QAPP preparation and numerous on-line documents to assist in preparation of a UFP-QAPP. One of these is the Participant’s Guide for How to Plan Projects Using the Uniform Federal Policy for Quality Assurance Project Plans, Training Workshop which can be accessed here: http://www2.epa.gov/sites/production/files/documents/participant_guide_ufp_qapp_workshop_v_01.pdf

This document provides examples for planning for projects using the UFP-QAPP including preparing for and conducting scoping meetings (as defined by the UFP-QAPP) with your client.

QAPP Worksheet #10: Conceptual Site Model

The title of this Worksheet is self-explanatory. This is where you develop and/or present your Conceptual Site Model (CSM). The optimized UFP-QAPP template provides prompts for discussing site history; sources of known or suspected hazardous waste; known or suspected contaminants or classes of contaminants; primary release mechanism(s); secondary contaminant migration; fate and transport; potential receptors and exposure pathways; land use considerations; key physical aspects of the site (site geology, hydrology, topography, climate) as pertinent to the project; the current interpretation of the nature and extent of contamination; and any data gaps and uncertainties associated with the CSM. Depending on the nature of your project, the input of your hydrogeologist, geochemist, chemist and/or engineer can be useful for completing this worksheet.

QAPP Worksheet #11: Project/Data Quality Objectives

This worksheet walks the author through a systematic planning process (SPP). The template specifically walks through the EPA’s 7-step Data Quality Objective (DQO) process. For Step 4, it’s important to define temporal (schedule) as well as spatial boundaries. For spatial boundaries, for example, it’s simple to say your team will dig and haul until PALs are met. However, this is risky without indicating at what depth you’ll make another call, or determining what you’ll do if you hit bedrock or groundwater.

Make sure to include reasonable “if/then” statements in Step 5 as well.

If you are unfamiliar with the EPA’s 7-step DQO process, you can find an introduction to this SPP here: http://www2.epa.gov/quality/training-courses-quality-assurance-and-quality-control-activities#intro_dqos

QAPP Worksheet #14/16: Project Tasks & Schedule

The title of this worksheet is self-explanatory. This is where your schedule or task list should be developed or added to the plan.

QAPP Worksheet #17: Sampling Design and Rationale

This is a good place for figures showing proposed and/or known sampling locations. The prompts provide some guidance on developing a sampling plan, and your technical leads in all fields could have valuable insight to be included here.

Other Worksheets

Other worksheets in the plan may appear to be similar to a traditional QAPP and may seem “chemistry focused” from a non-chemist point of view; however, dismissing these worksheets as “fill in the blank” sections is a mistake that can impact your budget, plan, and schedule.

You need to determine or identify what regulatory or project-specific PALs you will use in Worksheet #15, and you will need to address what your decision process and criteria will be if current methodology is unable to achieve these PALs. Levels of validation and QC sample requirements will also need to be identified. The input of an experienced environmental chemist is advised. Copying and pasting from old plans without careful consideration of actual project objectives could lead to unnecessary expenditure of budget and schedule, as you will be bound to following the plan. It’s important not to treat the details as administrative.

The topics addressed in the UFP-QAPP worksheets can help you and your team plan for efficient, effective project execution and assist you in meeting regulatory requirements for project planning. The EPA Frequently Asked Question (FAQ) page provides a tidy overview for understanding the UFP-QAPP: http://www2.epa.gov/sites/production/files/2014-02/documents/ufp_qapp_faq.pdf

It is important to understand the expectations and requirements of your client. While these requirements may seem to be clearly spelled out in your Request for Proposal (RFP), communication is vital. You don’t want to expend budget and schedule on multiple planning documents if your client would be satisfied with a UFP-QAPP and Health & Safety Plan (HASP).

If a UFP-QAPP is required but your team prefers other documentation in the field, it may be time to adjust to a new approach, and this can often be achieved by engaging the team in preparation of the UFP-QAPP for your DoD project. Once the team is comfortable that the contents of the UFP-QAPP are usable and meet their needs, they can identify the individual worksheets needed for their specific tasks and refer to those worksheets alone, as needed.

Some DoD clients require preparation of a UFP-QAPP for any type of environmental sampling, including sampling conducted only in conjunction with demolition for the purpose of confirming demolition has not caused new contamination. However, if there is an installation-wide QAPP in place for your project, or there is an approved and applicable QAPP in place for an on-going project undergoing re-assignment, the UFP-QAPP requirement may be waived or reduced. Even so, you may want to consider preparing a new UFP-QAPP to confirm that your understanding of the project is in alignment with current client expectations. Legacy documents do not always capture changes that can occur over time on long-term monitoring or maintenance projects. Any request to reduce or eliminate a UFP-QAPP requirement should be in the client’s best-interest.

In the author’s experience, use of the UFP-QAPP as an over-arching WP is client–dependent, and sometimes district-dependent. Some DoD clients want a complete UFP-QAPP, plus an FSP and a separate WP, and possibly a variety of additional plans. Some clients prefer only a UFP-QAPP and a HASP. The Naval Facilities Engineering Command (NAVFAC) may expect you to use a NAVFAC specific version called the UFP-SAP. The UFP-SAP is based on the original UFP-QAPP with minor modifications. Regardless of what your client needs or requires, the prompts in the optimized UFP-QAPP template provide useful guidance for planning.

One concern that has been expressed is that failure to address details is generally not acceptable in a UFP-QAPP. However, most clients are aware that project execution can be unpredictable. It is possible to write the UFP-QAPP so that there is room to make real-time field decisions or use alternate approaches. In fact, the UFP-QAPP can better prepare your team to make these decisions. It is also not necessary to repeat relevant information provided elsewhere in the UFP-QAPP.


“Samples will be collected from the approximate former location of the pipeline. Samples will also be collected from the approximate bottom of the disposal pit and/or immediately downgradient of the pit, depending upon site conditions. Approximate locations and depths of the pipeline and pit were identified through use of the historical documents provided in Appendix A. GPS will be used to record exact sampling locations in the field. See Worksheet 18.

If necessary, additional delineation sampling will be performed as step-outs and/or step-downs until analytical results are below the project action levels (PALs) shown on Worksheet 15-1 or no impact to groundwater is identified using downgradient groundwater data with results less than the PALs shown in Worksheet 15-2. See Worksheet 11 for details on boundaries to project decisions and specific if/then questions. See Worksheet 20 for anticipated sample quantities and associated QC.”

Although not intended to be all-encompassing, the above example shows how your team might meet UFP-QAPP requirements, prepare for real-time field decisions, and ensure your engineers, hydrogeologists, chemists, and project manager(s) are aligned.

Clients are seeking a clear, well thought-out plan for project execution, and preparing the UFP-QAPP can help ensure this expectation is met. Initially, the document may seem onerous, but its guidance provides for a thoughtful approach to planning that can better prepare your team for efficient, effective project execution. Careful planning and team alignment saves time and reduces difficulties during project execution. And because efficient, effective project execution is the best path to ethical, profitable project completion, a UFP-QAPP can be an invaluable project planning tool.

If you have questions or comments, please leave them in the comments section below. If you’d like to find out if Oak Services is the right company to prepare or review your UFP-QAPP or other planning documents, please contact us and let us know what you’re looking for.


2013, DoD, DoD Quality System Manual Version 5.0, July.

2006, DoD, Memorandum for Deputy Assistant Secretary of the Army (environmental, Safety, and Occupation Health), Deputy Assistant of the Navy (Environment), Deputy Assistant of the Air Force (Environment Safety and Occupational Health), Director Defense Logistics Agency (DSS-E), April.

2014, EPA, Frequently Asked Questions: Uniform Federal Policy for Quality Assurance Project Plans, February.

2012, EPA, Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans, Optimized UFP-QAPP Worksheets, March.

2011,EPA, Participant’s Guide for How to Plan Projects Using the Uniform Federal Policy for Quality Assurance Project Plans (UFP QAPP), Training Workshop Guide, October.

2005, EPA, Memorandum, OSWER GUIDANCE 9272.0-20, Applicability of the Uniform Federal Policy for Quality Assurance Project Plans (EPA 505-04-900A), December.

2005, EPA, Office of Solid Waste and Emergency Response, OWSER Directive 9272.0-17 Implementation of the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) and Federal Facility Hazardous Waste Sites, June.

2005, EPA, Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans, Evaluating, Assessing, and Documenting Environmental Data Collection and Use Programs, March.


Science, Empathy, Collaboration and Sustainability

The title of this article is taken from the theme for the 2016 Association for Environmental Studies and Sciences (AESS) conference: “Science, Empathy, Collaboration and Sustainability.” The conference will take place on June 8 – 11, 2016 in Washington, D.C. and will show-case the multi-disciplinary strengths of AESS.  If you are reading this prior to 5/22/2106, you can register here.  Suggested topics for proposals can be read here (proposal submission has closed).

As organizations such as AESS support the growth and understanding of sustainability, it is important for those of us in industry to also embrace the full meaning of sustainable development. To perform a project per specifications and make a profit is a meager measure of success. It is no longer enough – was truly never enough – to ensure that we leave a site no more contaminated than we found it. The short and long term impacts to the natural and human ecology must be taken into consideration.

Scientists at Stanford’s School of Earth, Energy & Environmental Sciences, as briefly discussed in a December 4, 2015 article in Science Daily and as published in Nature Geosciences, conducted experiments indicating that naturally occurring arsenic-releasing bacteria in wetlands and groundwater are ‘reactive’ carbon limited (Stuckey, Schaefer, Kocar, Benner, & Fendorf, Arsenic release metabolically limited to permanently water-saturated soil in Mekong Delta.  Nature Geoscience, 2015).  This means the bacteria do not normally release arsenic into wetlands and groundwater because there isn’t enough carbon available in a usable form for the bacteria to metabolize arsenic as an end-product. The experiment further indicates that land development could stimulate the release of toxic levels of arsenic into the groundwater. In such a scenario in real life, an approach to project execution that includes assessing the microbial constituents in groundwater or wetlands, and further includes interacting with the local populace to determine if there is a history of land development or extreme seasonal events followed by illness and deaths isn’t simply respectful, it’s crucial for avoiding disastrous results.

Research also indicates that localized examples of psychological intervention lead to environmental action, and that small changes in the practices of individual families, as well as local measures and incentives encourage energy conservation and help generate new norms (Ross, et. al, The Climate Change Challenge and Barriers to the Exercise of Foresight Intelligence, BioScience, 2016).

Although a shift is being seen on the industry level, as well as the personal and family level, normative shifts in business practices may not be occurring quickly enough. Scientists estimate that a global temperature increase of greater than 2º C (3.6 º F) above pre-industrial levels would be catastrophic; however, if temperatures continue to increase at the current rate, an increase of approximately 5ºC (9 º F) is likely within the next two to three decades (Queré, et. al., Global Carbon Budget 2014, Earth Science Data, 2014).  Global action and rapid shifts in industry norms are essential.

Limited capacity to focus on community engagement or perform an analysis of usage, costs, and differential impacts to the poor can be an Achilles heel for the long-term success of any project if not recognized and addressed early. An understanding of the natural ecology, as well as the human ecology – inclusive of community needs and concerns – is critical not only to achieve community buy-in but also to the long-term success of any project. It is crucial for economic and social sustainability strategies to have a basis in practical knowledge.

At Oak Services, we strive to align our work with the components of this year’s AESS conference theme. Our combination of scientific and technical expertise, our deeply-held beliefs in the importance of gender-equity, and our ethics- and faith-based motivation drive us to execute all work with what we believe to be the key to such a normative shift: empathy and dignity towards the local natural and human ecology, a coordinated application of a variety of scientific disciplines, and a long-range world view that interprets successful projects as those that improve the quality of life for the current community, as well as the quality of life for the community’s children and their children’s children. Our dedication to a respectful, data-driven assessment of any situation serves as a reminder that no one discipline, organization, faith, or organization can have all the answers and we anticipate learning a great deal from the presentations and research to be shared at this years’ AESS conference.

 About the authors:

Catherine Drumheller is the Principal and President of Oak Services, LLC and a certified Qualified Environmental Professional (QEP) with 18 years of experience in chemistry, environmental science, environmental project management, regulatory compliance and permitting, capacity development, International Organization for Standardization (ISO) 14001 Environmental Management Systems (EMS) and 17025.  Ms.  Drumheller holds a BS in Environmental Science with a dual emphasis in Chemistry and a Masters of Theological Studies with an emphasis on Environmental Ethics.

Dianne McNeill is a Proposal Manager and Senior Scientist with Oak Services, with 23 years of experience in the environmental sciences, specializing in developing processes to increase efficiency and manage risk. Ms. McNeill holds a BS in Biology and German. She is the founder and former Chair of the Rocky Mountain Chapter of the Society of Women Environmental Professionals (SWEP), and is active in her community with an environmental ministry group and teaching chess to elementary school students in support of their developing critical thinking and long-range planning skills.


Gutowski, et, al.  International Technology Research Institute, World Technology (WTEC) Division, WTEC Panel Report on Environmentally Benign Manufacturing, 2001.  Full report here: http://web.mit.edu/ebm/www/Publications/WTEC%20Report%20on%20EBM.pdf

Quéré, et.  al., Global Carbon Budget 2014, Earth Science Data, 2104.  Abstract here: http://www.earth-syst-sci-data-discuss.net/7/521/2014/essdd-7-521-2014.html

Ross, et.  al, The Climate Change Challenge and Barriers to the Exercise of Foresight Intelligence, BioScience, 2016.  Abstract here: http://bioscience.oxfordjournals.org/content/early/2016/04/08/biosci.biw025

Stuckey, Schaefer, Kocar, Benner, & Fendorf, Arsenic release metabolically limited to permanently water-saturated soil in Mekong Delta.  Nature Geoscience, 2015.  Abstract here: http://www.nature.com/ngeo/journal/v9/n1/full/ngeo2589.html

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