- These six PFAS compounds should be considered contaminants of concern (i.e., they are no longer “emerging contaminants”). It is prudent to consider PFAS compounds when conducting All Appropriate Inquiry (AAI) for property acquisition/divestiture.
- Given the EPA’s recent proposed rule designating PFOA and PFOS as “hazardous substances” under the Superfund law, it is likely that Ecology’s ability to order cleanups and recover costs will be strengthened.
- Until PFAS compounds are regulated federally, Ecology will likely rely on these preliminary cleanup levels until newer values are developed or unless stricter Federal ARARs are developed. We anticipate that Ecology will continue to refine its CULs as it has with other compounds and to expand the list of PFAS compounds for which it has CULs.
- It is not yet clear how materials impacted with PFAS compounds can be disposed. The Washington Dangerous Waste Regulations have not been updated to include PFAS compounds and there has been no applicable guidance issued by Ecology on waste disposal. It appears likely that due to their chemical nature, PFAS compounds will initially be regulated as Washington State “Special Wastes” under WAC 173-303-100, although the specifics of how the regula
Author: Keith Woodburne | September 21, 2022
Washington State continues on its path to developing and promulgating cleanup levels for per-and polyfluoroalkyl substances (PFAS compounds). The Washington State Department of Ecology (Ecology) recently published a list of 6 PFAS compounds that now have soil and groundwater cleanup levels under the Model Toxics Control Act (MTCA). The cleanup levels have been incorporated into the most recent update to the Ecology Cleanup Levels and Risk Calculation (CLARC, July 2022) database.
The Washington State Department of Health (DOH) had previously issued a final rule that included State Action Levels (SALs) for five of the six PFAS compounds. The Ecology update builds on the DOH SALs using methods established under MTCA for cleanup level development.
The new Cleanup Levels apply to the following compounds:
- Perfluorooctanonic acid (PFOA),
- Perfluorooctane sulfonic acid (PFOS),
- Perfluorononanoic acid (PFNA),
- Perfluorohexane sulfonic acid (PFHxS),
- Perfluorobutane sulfonic acid (PFBS), and
- Hexafluoropropylene oxide dimer acid (HFPO-DA; GenX).
How were the Cleanup Levels Developed?
Effective January 1, 2022, soil and groundwater SALs were established by the DOH for five of these PFAS compounds (excluding HFPO-DA). The DOH concluded that, since there is limited data available to support a quantitative assessment of cancer risk, SALs would be used based on the Environmental Protection Agency’s (EPA’s) non-cancer reference doses (RfDs). Future SAL recommendations from DOH for surface water, sediment, air, and terrestrial/ecological exposures are pending. Ecology adopted the SALs for the five compounds and developed cleanup levels for HFPO-DA using established MTCA equations, EPA non-cancer RfDs, and default exposure assumptions under the MTCA Cleanup Rule.
- Soil cleanup levels (vadose and saturated) were established direct exposure via incidental ingestion, with values for unrestricted and industrial land use scenarios, and for protection of groundwater.
- Ecology elected not to not use the June 15, 2022 EPA Health Advisory Levels (HALs) in establishing the cleanup levels for PFOS, PFOA, PFBS, and HFPO-DA.
The groundwater cleanup levels for the first five PFAS compounds are the DOH SALs. The cleanup level for HFPO-DA was calculated using a standard MTCA equation and EPA RfDs. The MTCA preliminary cleanup levels are summarized below.
MTCA Preliminary Soil and Groundwater Cleanup Levels
Chemicals | MTCA Protective Cleanup(CULs) | ||||||||
---|---|---|---|---|---|---|---|---|---|
Groundwater CUL(ng/L) | Soil CUL Protective of Groundwater (ng/kg) | Soil Direct Contact CUL (mg/kg) | |||||||
Vadose Zone | Saturated Zone | Method B | Method C | ||||||
New PFAS Compounds | |||||||||
Perfluorooctanoic acid (PFOA) | 10 | 63 | 4 | 0.24 | 11 | ||||
Perfluorooctane sulfonic acid (PFOS) | 15 | 170 | 9.9 | 0.24 | 11 | ||||
Perfluorononanoic acid (PFNA) | 9 | 80 | 4.8 | 0.2 | 8.8 | ||||
Perfluorohexane sulfonic acid (PFHxS) | 65 | 410 | 26 | 0.78 | 34 | ||||
Perfluorobutane sulfonic acid (PFBS) | 345 | 1800 | 120 | 24 | 1100 | ||||
Hexafluoropropylene oxide dimer acid(HFPO-DA;GenX) | 24 | 100 | 7.2 | 0.24 | 11 | ||||
Notes: ng/L = nanograms per liter ng/kg = nanograms per kilogram mg/kg = milligrams per kilogram CUL -Cleanup Level |
How will the Cleanup Levels be Applied?
Under the MTCA Cleanup Rule (WAC 173-340-710(4)), cleanup levels must comply with all relevant and appropriate requirements (ARARs). There is not a Federal ARAR to be considered under MTCA since Federal maximum contaminant levels (MCLs) have not yet been established. The newly established cleanup levels for the PFAS compounds are based on the DOH ARARs and EPA research and data. Ecology has indicated that they should be applied on a site-specific basis. Until a site-specific determination can be made by Ecology, these soil and groundwater screening levels should be considered preliminary. We are not yet aware of any sites where these cleanup levels have been applied under Ecology oversight. Generally, if a site has concentrations of PFAS compounds in soil or groundwater greater than the preliminary cleanup levels, then further investigation is likely warranted. While Ecology guidance indicates that these cleanup levels will be evaluated on a case-by-case basis they should be considered the functional cleanup levels.
- Additional PFAS SALs are being developed by DOH for other media and for terrestrial and ecological exposures. These additional SALs may be used to develop preliminary cleanup levels under MTCA, and will likely result in more sites in Washington being investigated for PFAS.
- The timeline for the EPA to establish water regulatory standards (MCLs and possibly secondary standards) includes a proposed rule in fall 2022 and a final rule in fall 2023.
- The primary consideration is to understand that PFAS are no longer “emerging” contaminants but must be considered as a contaminant that should be assessed, where appropriate, at sites in Washington State. PFAS should be considered in AAI and if present should be considered when developing regulatory and closure strategies.
- PFAS are not like other more commonly understood compounds. Specialized sampling techniques and trained personnel are necessary. The cleanup levels are extremely low (e.g., parts per trillion) and these compounds are pervasive in the environment. “False positives” are common when poor sampling methodology is used.
- Due to the potentially pervasive nature of these compounds different sampling strategies may also be appropriate. Those strategies should be tied to known uses and releases versus a general screening for these compounds. Because these compounds are pervasive and long-lived and the cleanup levels and detection limits are exceedingly low, a general screening may identify compounds, which are actually a background condition rather than related to an on-site release.
- Unlike other discontinued contaminants (e.g., PCBs, DDT), PFAS chemicals are still in common use. At operating facilities, consider conducting an audit of the processes and chemical formulations used on site.
- Consider replacing PFAS materials with non-PFAS products.
- Dispose PFAS materials appropriately and understand the potential for PFAS discharges in your process or waste streams.
- Take actions to prevent further PFAS contamination/migration, including operational changes, removal and/or cleanup if necessary.
TRC is prepared to assist you with your PFAS-related environmental evaluation and regulatory screening questions.
For more information, please contact Clint Miller at cmmiller@trccompanies.com or Keith Woodburne at kwoodburne@trccompanies.com.
Sharing Our Perspectives
Our practitioners share their insights and perspectives on the trends and challenges shaping the market.
Changes to EPA’s Risk Management Program (RMP) Regulations Are Coming
April 14, 2023
Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.
EPA Finds Trichloroethylene Presents Unreasonable Risk in Final Risk Evaluation
April 6, 2023
On Jan 9, 2023, the United States Environmental Protection Agency (EPA) revised the Toxic Substance Control Act (TSCA) to reflect a new risk determination for trichloroethylene (TCE).
Proposed Use of a Hazard Index for PFAS National Primary Drinking Water Regulation (NPDWR)
April 4, 2023
The Proposed MCL and MCLG for the four PFAS, PFNA, PFHxS, GenX, and PFBS, considers their toxicity as additive. The EPA has proposed a HI of 1.0 as the MCL and MCLG for the four PFAS combined.
Using the R2 Guidance in Indiana
March 21, 2023
TRC outlines the new R2 Guidance in Indiana
Routinely Evaluating the Health & Effectiveness of Integrated Systems to Manage EHS/ESG Risks – Part I
March 1, 2023
Once established, an EHS/ESG management system must be routinely evaluated to ensure it remains effective to identify and control risks, as well as accommodate and adjust for changes that occur to/within the organization.
Consequences of a Lowered NAAQS for PM2.5
February 16, 2023
TRC breaks down the significance of EPA lowering the NAAQS for PM₂.₅
EPA Announces $2 Billion in Funding to Address Emerging Contaminants in Drinking Water
February 14, 2023
Environmental Protection Agency Administrator Michael Regan announced $2 Billion in infrastructure funding to help the nation’s rural water supplies.
EPA Publishes Effluent Guidelines Program Plan 15
February 14, 2023
The EPA announced updated effluent limitations guidelines under Plan 15, focusing on the evaluation and rulemaking process for per- and polyfluoroalkyl substances (PFAS) discharges.
Phase I ESA ASTM Standard Update: The Wait is Over
December 21, 2022
The USEPA published a Final Rule making the ASTM E1527-21 Phase I ESA standard AAI compliant.
Proactive Enforcement is Key in the EPA FY2022-2026 Strategy
October 19, 2022
A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.
Preparing for EPA Inspections in Environmental Justice Communities
October 4, 2022
The EPA Office of Enforcement and Compliance Assurance Have Expanded Goals to Strengthen Enforcement and Protections Within EJ Communities
New National Emerging Contaminants Research Initiative
September 12, 2022
The Executive Office of the President of the United States announced a National Emerging Contaminant Research Initiative
NERC Proposes Implementation Guidance for PRC-019-2
August 22, 2022
NERC has proposed implementation guidance for PRC-019-2, the standard that verifies coordination of generating unit facility or synchronous condenser voltage regulating controls, limit functions, equipment capabilities and protection system settings.
Optimizing EHS/ESG Information Management and Reporting Systems by Leveraging Innovative Digital Technology Solutions
August 10, 2022
A single, integrated enterprise wide EHS/ESG IMS can significantly improve performance and communicate progress towards organizational requirements and goals.
Revisions to FAC-001 and FAC-002 Submitted for FERC Approval
July 12, 2022
Reliability Standards FAC-001-4 and FAC-002-will resolve uncertainty regarding the meaning of “materially modify” under the currently effective standards.
FERC Order No. 881-A Has Implications for NERC Compliance Programs
June 23, 2022
Updated Order will have significant impact on NERC compliance programs related to both PRC standards and facilities ratings. Utilities should review the Order’s requirements and prepare for changes needed to remain compliant.
Integrating Sustainability, Digital Connectivity and Design Optimization in Wastewater Treatment Systems
June 20, 2022
Some organizations rarely think about water and wastewater treatment, until there is a problem. American industry depends on the ability to treat wastewater discharges while complying with regulatory standards and addressing emerging contaminants. If wastewater treatment fails, our environment is negatively impacted, and companies are exposed to shutdowns, delays and fines.
Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan
June 14, 2022
The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.
Support an Integrated EHS/ESG Management System
June 10, 2022
What is FERC and NERC Compliance? At its May 2022 meeting, the Federal Energy Regulatory Commission (FERC) issued Order No. 881-A, to clarify a December 2021 order that represented a major change in utility operating practices and planning. In the new order, FERC denied requests for rehearing Order No. 881, and reaffirmed its Ambient Adjusted Ratings (AAR) pronouncements. These actions will have a significant impact on NERC compliance programs related to both PRC standards and facilities ratings. Utilities should review the Order’s requirements and prepare for changes needed to remain compliant. Order 881-A Requirements The new FERC order specifically requires: Public utility transmission providers to deliver transmission service; Regional transmission organizations and independent system operators (RTO/ISO) to establish and implement the systems and procedures necessary to allow transmission owners to electronically update transmission line ratings at least hourly; Public utility transmission providers to use uniquely determined emergency ratings Public utility transmission owners to share transmission line ratings and transmission line rating methodologies with their respective transmission provider(s) and with market monitors in RTOs/ISOs; and Public utility transmission providers to maintain a database of transmission owners’ transmission line ratings and transmission line rating methodologies on the transmission provider’s Open Access Same-Time Information System (OASIS) site or other password-protected websites.
NERC’s Revised PRC-024-3 Standard for Inverter-Based Generation Effective in October 2022
May 11, 2022
Changes to PRC-024-3 in support of inverter-based generation performance are going into effect in October of this year. Interconnection programs and documentation procedures may need to be updated in order to maintain compliance.
FERC Issues Notice of Inquiry Regarding Dynamic Line Ratings
April 25, 2022
There are significant technical challenges involved in implementing Dynamic Line Ratings in the planning and operation of utility systems. Utilities should be prepared to modify their NERC compliance programs as necessary to address the potential introduction of DLR in their businesses.
How to Use an Integrated Approach To Manage EHS and ESG Risks
April 20, 2022
Inverter-based resources are being added to the power system at an increasing rate due to renewable energy mandates and clean energy goals. Because the current NERC standards were written long before this trend, many are being updated to ensure continued reliability and resilience under new and emerging conditions. Most notably, changes to PRC-024-3 in support of inverter-based generation performance are going into effect in October of this year. Interconnection programs and documentation procedures may need to be updated in order to maintain compliance. Generation Losses Highlight Need for Change From August 2016 to May 2018, there were numerous instances where renewable inverter-based generating resources performed inadequately after what should have been routine transmission system disturbances such as lighting strikes or trip and reclose situations. Power generation losses in these events varied from a low of 30 MW to a high of 1,200 MW, compounding reliability and resilience concerns.
Why Are ESG Frameworks Important?
April 13, 2022
ESG standards significantly impact long-term growth, leading many companies to integrate ESG reporting into their corporate social responsibility (CSR) strategies. ESG frameworks are broad and diverse, and establishing a reporting system that covers your industry’s most relevant metrics can be challenging.
EPA Coal Ash Compliance Expectations Updated
March 28, 2022
New EPA Communications highlight new Coal Combustion Residual compliance expectations, a shift from the current program.
New NERC Guidance Supports the Implementation of Grid Forming Inverters
March 8, 2022
NERC has issued a new report highlighting the key attributes of various inverter controls to support proper implementation and to protect reliability.
NERC Recommends Approaches for Underfrequency Load Shedding Programs
February 24, 2022
In a recently released reliability guideline, NERC recommends additional approaches for Underfrequency Load Shedding (UFLS) program design to help utilities effectively consider the effects of Distributed Energy Resources (DERs). The guidance was developed to address the accelerated transition of the power system to locally installed, decarbonized resources that depend on inverters. These new technologies introduce operational controls issues into the electric grid. UFLS data gathering and analysis methodologies may require modification to address reliability risks.
NERC and FERC Recommend Protection System Commissioning Improvements
January 18, 2022
Between 18 and 36 percent of reported utility misoperations were attributed to issues that could have been detected through a properly implemented PSC.
FERC & NERC Issue Joint Report on Freeze Reliability Failures
December 15, 2021
The in-depth report outlines twenty-eight recommendations to address freeze reliability failures, including operating practices and recommendations for NERC standards modifications surrounding generator winterization and gas-electric coordination.
NERC Accelerates Additional Cold Weather Standards Changes
November 22, 2021
At its November 2021 meeting, NERC’s Board of Trustees took aggressive action to advance critical cold weather Reliability Standards. Most notably, the group approved the 2022-2024 Reliability Standards Development Plan, which prioritizes standards projects for the coming years including a resolution to include new cold weather operations, preparedness and coordination standards as high priority development projects.
OSHA’s National Emphasis Program on Heat-Related Illness and Injuries
November 3, 2021
On September 20, 2021 in an OSHA National News Release, OSHA published a memorandum establishing an enforcement initiative that is designed to prevent and protect employees from heat-related illnesses and death. This initiative, which develops a National Emphasis Program (NEP) on heat inspections, is an expansion of an already existing Regional Emphasis Program (REP) in OSHA’s Region VI, which covers Arkansas, Louisiana, New Mexico, Oklahoma and Texas.
New Potential Compliance Standards Identified at FERC Technical Conference on Reliability
October 18, 2021
With a focus on the reliability impact of extreme weather and the shortcomings of current system planning approaches, both NERC and FERC conference participants opened the door to potential forthcoming compliance standard enhancements or changes.
NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order
October 5, 2021
On September 22, 2021, the New Jersey Department of Environmental Protection (NJDEP) Commissioner announced the issuance of Administrative Order (AO) No. 2021-25 to implement New Jersey’s Environmental Justice (EJ) Law. This order is effective immediately, and applicants seeking to site new major source facilities, renew major source permits or expand existing facilities with major source permits (e.g., Title V air permits) in overburdened communities are affected. There are more than 4.5 million people that live within 331 municipalities that are overburdened communities in the state of New Jersey.
OSHA Returns to In-Person Inspections As COVID-19 Restrictions Lift
August 4, 2021
The Occupational Safety and Health Administration (OSHA) is authorized by the Occupational Safety and Health Act of 1970 (OSH Act) to assure employers provide safe and healthful work conditions free of recognized hazards and by setting and enforcing standards and providing training, outreach, education and technical assistance. OSHA has recently announced the return to in-person inspections as COVID-19 restrictions begin to lift.
NERC Proposes Revisions to CIP-008
March 27, 2021
NERC’s CIP-008 standard aims to mitigate reliability risks resulting from a Cyber Security Incident by specifying incident response requirements. Newly proposed revisions would augment mandatory reporting to include incidents that compromise, or attempt to compromise, a utility’s Electronic Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMS).
EPA continues to aggressively address PFAS wastewater with two new strategies
January 4, 2021
EPA takes steps toward PFAS wastewater and storm water permitting, and analytical methods for testing.
Ecological Risk of PFAS from AFFF-Impacted Sites
June 30, 2020
The facts on evaluating exposure to wildlife
Targeting Perfection in the Construction and Operation of Pipelines
October 18, 2019
To have an impact on the delivery or operation of a pipeline, it’s vital to eliminate the intra- and inter-company barriers, including those in the areas of communications, culture and technology.
PHMSA Publishes New Rules to Increase the Safety of Hazardous Liquid Pipelines and Gas Transmission Pipelines
September 25, 2019
The Pipeline and Hazardous Materials Safety Administration this week published important new rules aimed at improving pipeline safety.
NERC Calls for New Approach to Reliability Planning Due to Gas Supply Disruption Risks
December 14, 2017
A recently published NERC report concludes that as reliance on natural gas to meet electric generation requirements increases, additional planning and operational measures must be considered to mitigate power system reliability risks.
SEC Rules in Favor of Climate-Related Disclosures
March 8, 2024
In a long-awaited climate ruling, the Securities and Exchange Commission (SEC) ruled 3-2 in favor of the climate-related disclosures on March 6, 2024.
EPA Proposes Rules for IRA-mandated Waste Emissions Charge for Methane
February 6, 2024
EPA proposed rules to implement the Waste Emissions Charge (WEC) program for facilities that exceed a waste emissions threshold
What You Need to Know about the EU Corporate Sustainability Reporting Directive (CSRD)
January 19, 2024
January 1, 2024, marks the start of the first reporting timeframe for companies in scope of the European Union’s Corporate Sustainability Reporting Directive (CSRD).
New Jersey Implements Landmark Environmental Justice Regulations
August 2, 2023
A new landmark Environmental Justice (EJ) law is now effective in New Jersey following a lengthy rulemaking process surrounding the New Jersey Department of Environmental Protection’s (NJDEP) Administration Order (AO) No. 2021-25. It is the first rule of its kind and the strongest EJ regulation in the nation.
EPA Proposes Regulation of Green House Gas Emissions
July 10, 2023
This article highlights the EPA’s proposed rules to regulate greenhouse gas emissions from power plants and the potential impact on new and existing fossil fuel-fired facilities.
Organizing for Project Success
June 22, 2023
Many organizations are establishing Project Management Organizations (PMOs) to improve project management within their organizations. While there can be many reasons for establishing a PMO, most are established to improve project management with respect to schedule, cost, quality and risk. This article provides an overview of factors to consider when deciding on which type of PMO is most suitable for your organization and how best to implement a successful and high-performing PMO.
New Executive Order 14096 Broadens Environmental Justice Initiatives
May 9, 2023
Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, seeks to deepen the Biden administration’s “whole-of-government” approach to environmental justice (EJ) by fully integrating the consideration of unserved and overburdened communities and populations into all aspects of federal agency planning and delivery of services.
Proactive Enforcement is Key in the EPA FY2022-2026 Strategy
October 19, 2022
A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.
Preparing for EPA Inspections in Environmental Justice Communities
October 4, 2022
The EPA Office of Enforcement and Compliance Assurance Have Expanded Goals to Strengthen Enforcement and Protections Within EJ Communities
TRC Companies Inc. welcomes the Founder and Key Principals of ESG Advisory Firm Enzo Advisors, LLC
September 27, 2022
TRC Companies announces the expansion of its Climate Solutions offering and ESG capabilities with the addition of the Founder and CEO, and key members of Enzo Advisors, LLC
Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan
June 14, 2022
The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.
TRC Companies Pledges to Achieve Net Zero GHG Emissions by 2040
April 26, 2022
TRC Companies, a digitally powered and environmentally focused global professional services firm, announced its commitment to achieve Net Zero greenhouse gas (GHG) emissions across its full value chain by 2040, aligning with the most ambitious aim of the Paris Agreement to limit global temperature rises to 1.5 °C.
Why Are ESG Frameworks Important?
April 13, 2022
ESG standards significantly impact long-term growth, leading many companies to integrate ESG reporting into their corporate social responsibility (CSR) strategies. ESG frameworks are broad and diverse, and establishing a reporting system that covers your industry’s most relevant metrics can be challenging.
How Does ESG Address Environmental Concerns?
October 22, 2021
When investors consider where to put their money, they may examine environmental, social and governance (ESG) criteria, learn about a company’s core values and decide if they align with their own. Young people, in particular, search out this information to make decisions that align with their morals.
What Is Environmental, Social and Corporate Governance?
October 10, 2021
Several key considerations help determine whether an investor decides to support a particular company. While many factors can tip the scales, investors are increasingly seeking out businesses that uphold higher standards. Therefore, companies should openly communicate their standards to make it easier for investors to understand their values.
NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order
October 5, 2021
On September 22, 2021, the New Jersey Department of Environmental Protection (NJDEP) Commissioner announced the issuance of Administrative Order (AO) No. 2021-25 to implement New Jersey’s Environmental Justice (EJ) Law. This order is effective immediately, and applicants seeking to site new major source facilities, renew major source permits or expand existing facilities with major source permits (e.g., Title V air permits) in overburdened communities are affected. There are more than 4.5 million people that live within 331 municipalities that are overburdened communities in the state of New Jersey.
Cryptocurrency: The Environmental Threats and Opportunities
August 9, 2021
Cryptocurrency (also known as crypto) is taking the fintech industry by storm, despite the economic experts who still dismiss it as a viable form of currency. Although often criticized for this volatility, whistleblowers are also further shining a light on the severe toll that these digital currencies are taking on the environment.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
TRC Announces Collaboration with Greenstone Reinforcing Integrated ESG, Sustainability and Climate Risk Solutions
June 26, 2020
The dominant trend in improving the efficiency and profitability of the logistics and supply chain industry will continue to be achieved through automation. Environmental, social and governance (ESG) issues can be important considerations for investments in this sector due to potential reputational risks for the acquiring entity. Key issues include negative publicity surrounding the perception of job elimination, as well as the procurement of specialty materials required to produce batteries and other components of autonomous robots. The recycling or responsible disposal at the end of the life of the product is also a key focus especially in Europe. TRC was asked to provide ESG risk screening for a foreign auto manufacturer’s investment in a U.S.-based autonomous robotics company. A two-step approach was taken to access the risks associated with this target. The first step evaluated the inherent risks of the target company’s sector based on its geographical spread and operations using public information like the Sustainability Accounting Standards Board (SASB) and the CDC Investment Works Toolkit. The second step involved deeper analysis of ESG risk assessments & insights based on a review of specific controls that the company uses to manage its risks. This included a questionnaire, reviewing company documents and programs, and interviewing company representatives.
COVID-19 and Implications for ESG Investing
June 3, 2020
This global pandemic has exposed business vulnerabilities and recalibrated material Environmental Social and Governance factors for investors.
Regulators Update Design Storm Rainfall Depths in Response to Climate Science Projections and Recent Storm Data
August 3, 2023
Regulators are responding to anticipated increases in extreme rainfall events by updating design storm rainfall depth regulations.
New Executive Order 14096 Broadens Environmental Justice Initiatives
May 9, 2023
Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, seeks to deepen the Biden administration’s “whole-of-government” approach to environmental justice (EJ) by fully integrating the consideration of unserved and overburdened communities and populations into all aspects of federal agency planning and delivery of services.
TRC Companies Inc. welcomes the Founder and Key Principals of ESG Advisory Firm Enzo Advisors, LLC
September 27, 2022
TRC Companies announces the expansion of its Climate Solutions offering and ESG capabilities with the addition of the Founder and CEO, and key members of Enzo Advisors, LLC
Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan
June 14, 2022
The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.
Why Are ESG Frameworks Important?
April 13, 2022
ESG standards significantly impact long-term growth, leading many companies to integrate ESG reporting into their corporate social responsibility (CSR) strategies. ESG frameworks are broad and diverse, and establishing a reporting system that covers your industry’s most relevant metrics can be challenging.
10 Takeaways from the COP26 Climate Meeting
November 17, 2021
There are compelling reasons to be optimistic about the outcomes of the COP26 meeting. Notably, agreement among all nations that more needs to be done, by both private and governmental bodies, to contain and mitigate climate change.
New Jersey Implements Landmark Environmental Justice Regulations
August 2, 2023
A new landmark Environmental Justice (EJ) law is now effective in New Jersey following a lengthy rulemaking process surrounding the New Jersey Department of Environmental Protection’s (NJDEP) Administration Order (AO) No. 2021-25. It is the first rule of its kind and the strongest EJ regulation in the nation.
New Phase I ESA Standard Will Affect Environmental Due Diligence
January 25, 2022
After years of review, revisions and discussions, the new ASTM E1527 Phase I Environmental Site Assessment (Phase I ESA) standard has been published. The new standard includes updates to definitions, clarifications on processes and requirements, and guidance for emerging contaminants.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
A billion-dollar BrewDog: TRC advises private-equity client on major craft beer investment deal
April 19, 2021
When one of America’s leading private-equity companies decided recently to buy a stake in one of the world’s fastest-growing craft-beer brewers, the deal team sought advice from TRC.
TRC Announces Collaboration with Greenstone Reinforcing Integrated ESG, Sustainability and Climate Risk Solutions
June 26, 2020
Recently TRC’s Rick Sisk, Vice President – Transaction Advisory Services, was part of Intralinks virtual roundtable series Oil & Gas Part II, “Has Oil & Gas Run Out of Steam?” Like many industries, oil and gas has been significantly impacted by the COVID-19 pandemic. In the first part of our industry roundtable on the topic held this past spring, a distinguished panel of experts outlined how the dramatic plunge in oil demand hit the industry hard. There was little optimism for quick recovery at the time. So where are we now? To learn more, Intralinks reconvened a panel of experts — Jamie Garrett, Principal at JoyCap Advisory LLC (formerly VP M&A, Direct Energy); Ian Graham, Senior Finance Director, Corporate Development Tax & Treasury at Trican Well Service, and Rick Sisk, Vice President, Transaction Advisory Services (oil & gas) at TRC Companies — to see the how oil and gas market has fared over the past few quarters. We also considered what 2021 might look like for an industry in flux.
COVID-19 and Implications for ESG Investing
June 3, 2020
This global pandemic has exposed business vulnerabilities and recalibrated material Environmental Social and Governance factors for investors.
TRC Brings Environmental Services to Manchester with Second UK Office
March 5, 2020
In continuing to expand our presence in a key British market, TRC is opening our second UK office in Manchester, England
Keith Woodburne
Keith Woodburne is a principal geologist with 24 years of experience in environmental consulting. Keith has served as a Program and Project Manager and Senior Technical Lead for a broad range of site characterization and remediation projects in the western United States, including in Washington, Oregon, Montana, California, Arizona, and Texas. He has extensive experience in project management, site characterization design and implementation, and regulatory liaison and stakeholder management. He has managed complex projects regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and under a variety of State regulatory agencies and programs. During his career, Keith has managed projects for major industries including oil & gas, cement, tire, and fertilizer manufacturing, for residential and commercial developers, former dry-cleaning facilities, the Port of Seattle, and for a number of industrial class I railroads. He currently provides support in the Pacific Northwest to the TRC’s per- and polyfluoroalkyl substances (PFAS) CORE Team in the Engineering, Construction, and Remediation (ECR) practice. Contact Keith at KWoodburne@trccompanies.com.