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Newsletters & Articles

Keeping the Roads Clean this Thanksgiving

In an ongoing effort to keep our highways and roads clean, the team at Brickhouse Environmental once again gathered last month to collect garbage from the shoulders of a 2-mile stretch along Route 322 West Chester Bypass. This rounds out the third year that Brickhouse Environmental has been a sponsor of the PennDOT Adopt-a-Highway program.  We collected 15 bags of trash, a significant decrease since our last roadside cleanup and a good sign that we’re keeping litter under control.

Next time you’re on the bypass, look for the Brickhouse Environmental sign, and remember to keep our roads and highways clean!

Amendments to PA’s Act 2 Statewide Health Standards – May Have Site-Specific Impacts on Environmental Assessments and Cleanups

On November 22nd, the Pennsylvania Department of Environmental Protection (PADEP) published updates to the Chapter 250 regulations for environmental investigations and remediation under Pennsylvania’s Act 2 voluntary cleanup program. The rulemaking includes changes to many Statewide Health Standards based on new scientific information, and adds groundwater and soil standards for PFOA, PFOS and PFBS – three common PFAS chemicals.

According to the DEP, the changes for soil standards include decreases for approximately 83% of the values and increases for 17% of the values. For groundwater, the changes reflect a decrease for approximately 92% of the values and an increase in approximately 8% of the values. Lowering the values may indicate a more stringent cleanup is required at a site and increasing the values may indicate a less stringent cleanup is required at a site. 

Changes to the Regulations and standards can be found here: http://www.pacodeandbulletin.gov/Display/pabull?file=/secure/pabulletin/data/vol51/51-47/1920.html

Some significant changes include:

  • The Statewide Health Standard for benzo(a)pyrene in soils.  The change in the standard from 0.58 ppm to 4.2 ppm will have significant impacts on sites containing historic fill or minor petroleum residuals, alleviating or reducing the need for soil remediation.
  • Standards for three PFAS chemicals in groundwater and soils.  Cleanup standards for PFOA, PFOS and PFBS have formally been added to the lists of Statewide Health Standards.
  • Lead and Vanadium. New standards for lead and/or vanadium in soil are not included in these changes, as they are planned to be addressed under separate rulemaking, hopefully within the next year.  For now, they remain unchanged.
  • Professional Seal – Reports submitted to satisfy Act 2 requirements must be sealed by a licensed Professional Geologist or Engineer for work that provides geologic or engineering analysis and/or opinions.

Note that many of the changes in the Act 2 direct contact soil standards will also carry over to Pennsylvania’s Clean Fill standards.

Please contact one of our Geologists – Dave Farrington, Paul White, Doug Schott, or Steve Huxta – with any questions about site assessments or cleanups under the Act 2 Program.

Brickhouse Environmental Sponsors Downingtown Mountain Bike Team

In the summer of 2021, Brickhouse Environmental became a proud Platinum sponsor of the Downingtown Interscholastic Mountain Bike Team. We became aware of this fantastic organization of student athletes and coaches when the son of a Brickhouse staff member joined the team for the 2021 season. The team first took shape in 2016 with the formation of the Pennsylvania Interscholastic Cycling League and has been growing by leaps and bounds ever since.

Student athletes learn mountain biking skills, compete on a state level and give back to the community. As with all youth sports, the benefits to the student athletes can be very significant sparking positive changes that last a lifetime. Our youth need great organizations like this to brighten all our futures. We encourage you to check them out and support them if possible. 

How Can a Human Health Risk Assessment Benefit You?

The benefits of performing a Human Health Risk Assessment (HHRA) are often underestimated or overlooked entirely when landowners or even potential landowners are making decisions regarding an appropriate path forward for their Site. Whether it’s during a Phase II Environmental Site Investigation (ESA) or through a Pennsylvania Department of Environmental Protection Agency (PADEP) Land Recycling Program (Act 2) Cleanup, HHRA’s can be a time- and cost-effective tool for ensuring that current and/or future receptors are protected from contaminated media.

When can an HHRA benefit your project?

  1. Has a soil boring investigation indicated that contamination exists within your property?  Rather than implement burdensome institutional and engineering controls or perform a costly soil excavation, the performance of an HHRA may eliminate the need for these measures all together.  Site-specific considerations employed in an HHRA (i.e., time spent on Site or child versus adult receptors) are oftentimes far less restrictive than the assumptions built into PADEP screening criteria.  Application of realistic exposure assumptions may show that Site soil contamination does not result in adverse health effects to receptors, eliminating the need for remediation measures.   
  2. Are you seeking an Act 2 Relief of Liability for a Site that also has potentially complete surface water and sediment exposure pathways? Although surface water and sediment may exist on your Site, the PADEP does not allow for relief of liability for these media without the performance of an HHRA to ensure the safety of receptors now and in the future.  Assumptions built into a surface water and sediment HHRA evaluation are far less conservative than those for soil and groundwater, particularly when a Site exists within an urban area where the likelihood of recreational use is minimal to none.  As surface water and sediment are also not amenable to remediation or off-Site disposal, an HHRA evaluation is critical in successfully bringing a project to close within the Act 2 program.
  3. Has the implementation of a soil cap been a primary means for addressing Site soil contamination? Performing an HHRA is typically overlooked as a cost-effective means for “remediating” a Site.  Often a soil cap is recommended as a simple remedy for soil contamination, particularly when paved parking lots are already part of future Site development.  The future ongoing cost and burden placed on property owners, however, far exceed those necessary to perform an HHRA upfront.  The need for a Post-Remedial Care Plan that includes an Environmental Covenant, reporting requirements to the PADEP, and ongoing inspection costs to ensure the integrity of the cap can all be avoided with the evaluation of HHRA that eliminates the need for a cap in the first place.

Whether it’s for adequate data needs for incorporation into an HHRA or the need for an HHRA at all, Brickhouse Environmental’ s in-house Risk Assessment capabilities can assist early in the decision-making process to save both time and money throughout the lifespan of your project.  

PFAS Trends – New Emphasis By US EPA May Have Broad Implications

On October 18th, the U.S. Environmental Protection Agency (EPA) announced the agency’s comprehensive Strategic Roadmap to confront PFAS contamination nationwide.  Below are some thoughts on what the future may hold:

  1. PFAS monitoring and reporting are going to expand into many more areas of the regulated community (some have already started):
    • NPDES discharge permits
    • Sewer discharge permits to POTWs
    • Testing of biosolids (sewage sludge from POTWs) before land application at farms
    • TRI (Toxic Release Reporting) / community right-to-know reporting
    • Leachate and groundwater monitoring at landfills
  2. There is a push to designate certain PFAS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).  If this occurs, there will be a significant trickle-down effect:
    • It would jump start the identification and remedial investigation of sites impacted by PFAS. 
    • It would likely allow the re-opening of closed/inactive cleanup sites.
    • It would also allow EPA and others to recover cleanup costs from potentially responsible parties.
    • It could lead to Natural Resource Damages suits from Federal/State agencies.
    • Remedial Investigations and cleanups would become more expensive due to significant additional specialized sampling, analytical and disposal costs.
  3. Pennsylvania and other states currently use the current USEPA Health Advisory Limit (HAL) of 70ppt for PFOA and PFOS as the cleanup standard for these compounds in groundwater.  The EPA has announced plans for a more aggressive standard by 2023, and Pennsylvania regulators may set their own lower standards for certain PFAS compounds before that.  (Several states already have.)   This should be taken into account when conducting environmental due diligence for a property.  When testing groundwater at a property for PFAS, the assessment of potential liability should not only focus on whether PFAS concentrations are above current standards, but consider the likelihood of lower future standards – and should more importantly focus on whether those compounds were discharged from onsite operations or migrated from offsite sources.