Newsletters & Articles

A great day for Fall Cleanup!

March 1, 2023

For the second time this year, Brickhouse Environmental spent the day cleaning up a two mile stretch of the Route 322 bypass in West Chester, Pennsylvania. This is part of our ongoing commitment to PennDOT’s Adopt-a-Highway program.

It was a glorious fall day with temperatures in the 60’s. The Brickhouse crew removed over a dozen large bags of litter, a few tires, a car bumper and, ironically, two trash bins! Since first taking on this commitment four years ago, the landscape along this stretch of highway has improved greatly. Like so many other busy highways in the country, the accumulation of litter and lost items never stops, but our efforts are keeping it in check. Since our involvement, the volume of litter collected has decreased from over 35 bags of trash over six months to a little over a dozen.

If you find yourself on the bypass, keep an eye out for the Brickhouse Environmental sign. If you’re lucky, you might even see us on the side of the road doing our part!

We Love it When a Plan Comes Together…an Environmental Monitoring Plan

February 28, 2023

It seems that when most things in life turn out great, they start with a great plan. Sure, there are some spontaneous moments in life that we prize as some of our most memorable — but, when it comes to implementing complex environmental monitoring programs, nothing should be unplanned. And the design and execution of the plan are key.

The Goals: Two primary goals of any environmental monitoring plan should be to:

generate high quality, reliable data that is useful for evaluating trends and/or meeting compliance objectives; and

assure that the data is legally defensible.

Many Variables Can Impact the Data: That being said, a great monitoring plan must recognize the multiple variables that can potentially impact data quality during the sample collection, sample handling, and laboratory analytical processes. Therefore, the Project Manager should design the plan to limit these variables. And obviously, the proper execution by the field team is also critical. The following provides just a few of the variables we consider when developing a monitoring plan:

Quality Assurance/Quality Control Samples: These vary considerably based on the regulatory program and sample type. QA/QC samples are often considered a waste of money by some, but they can be priceless when unexpected or inconsistent data shows up on the laboratory report.
Analytical Method Selection: Methods matter! Analytical methods are designed for specific applications. Analytical laboratories can’t know what method is best suited for your samples and sampling programs unless you tell them. The wrong analytical method can result is data being rejected by a regulatory agency or provide reporting limits that exceed your regulatory limits.

Analytical Laboratory Selection: Not all laboratories are created equal, and many are specialized toward a specific type of analytical work. We have decades of experience working with analytical laboratories in our service area and throughout the country to recommend the best choice for your monitoring program.

Training and Process Matter: To ensure that great monitoring plans are implemented as planned, you need experienced field scientists with the right training and the right equipment. Brickhouse Environmental has been successfully using this formula for decades on small to very large environmental compliance monitoring projects. The types of clients/industries that rely on our environmental monitoring services include landfills (active and closed), wastewater treatment facilities, brownfield redevelopers, mining and manufacturing.

Considering the Big Picture: Environmental monitoring data cannot be viewed in a vacuum. It’s not enough to provide the highest quality environmental monitoring data; it is the interpretation of the data (while considering the big picture) that is also critically important. This is especially true when a client is faced with a Notice of Violation (NOV) or unusual data that may or may not indicate a more significant problem. All factors that may potentially affect monitoring results must be considered from the office to the field and from the laboratory. Again, here are just a few examples of how we consider the big picture when evaluating environmental monitoring data:

Always on the Lookout: Our project managers and field crews are degreed scientists that understand the natural and manmade systems that we monitor. All project managers and field scientists are asked to observe and consider all conditions that may affect monitoring results as they collect environmental compliance data from the field and evaluate laboratory analytical data. This is especially important at dynamic project sites such as landfills, active brownfield redevelopment projects or mine reclamation sites. A consistent trained scientific eye in the field can provide important information from the changing project site that can help explain unexpected environmental monitoring data.
Everything is Connected: It’s not just a sample from a well or a stream, it’s a sample from an aquifer system or a stream network that can be affected not only by the project site but the lands that surround it. When evaluating environmental compliance information, it’s very important to consider all factors that can affect manmade systems, the surrounding natural systems and understand the interactions between them.

Keeping You Out of Trouble: When unusual monitoring data and outliers can’t be explained by site conditions, we question it. While Brickhouse Environmental and our chosen environmental testing laboratories do all we can to ensure accurate field and laboratory monitoring data, mistakes and other outside factors can negatively affect data quality and accuracy. The monitoring plans we prepare and implement include robust quality assurance/quality control measures that allow us to assess the validity and accuracy of field and laboratory derived monitoring information. Through detailed data review and assessment, we have discovered and corrected laboratory reporting errors that had the potential to result in costly recollection, costly regulatory interactions and non-compliance violations. We have also succeeded in having NOVs rescinded by questioning data collected by regulators.

If you are responsible for a project site that requires environmental compliance monitoring, I hope your chosen environmental professional or analytical laboratory is giving your monitoring program and monitoring results the attention they deserve. If you’re unsure, it’s worth your time to reach out to us to discuss your monitoring program and associated challenges.

“Brickhouse Environmental has been providing field services for our facility since the 1980’s. Their extensive knowledge of federal, state and local regulations, coupled with their ability to adapt to new regulations and requirements give us peace of mind that our compliance sampling and reporting is being conducted with professionalism and integrity.”

Steve Burn

Southeastern Chester County Refuse Authority

Pennsylvania Regulatory Update: PADEP Renews the NPDES General Permit (PAG-03)

February 1, 2023

After a long wait, the Pennsylvania Department of Environmental Protection (PADEP) has finally renewed the NPDES General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03). In order for existing sites to maintain their coverage under the renewed PAG-03 General Permit, you must submit a Notice of Intent (NOI) to the PADEP on or before March 23, 2023. While this renewed permit is similar to the prior PAG-03 permit, there are significant changes that could affect your Facility’s operations. These changes should be discussed with your environmental laboratory and consultants.

As with the prior permit, discharges to High Quality (HQ) or Exceptional Value (EV) waters are excluded from coverage under the General Permit. Accordingly, facilities whose receiving streams have been redesignated as HQ or EV waters are no longer eligible for a General Permit, and must apply for an Individual Permit no later than March 23, 2023.

What’s Required with the NOI Submission?

An updated Preparedness, Prevention and Contingency (PPC) Plan needs to be included with the NOI.

Laboratory analytical results may be required for facilities that discharge to receiving waters with an already specified impairment. For example:

For receiving waters already impaired by excess siltation, sediment and/or flow variability, the discharging facility should report Total Suspended Solids (TSS) with their NOI.

For receiving waters already impaired by nutrients, the discharging facility should report Total Phosphorus and Total Nitrogen should be reported.

For receiving waters with existing TMDLs for specific pollutants, the discharging facility may need to submit lab data for that specific pollutant.

For outfalls associated with stormwater basins that do not typically discharge, samples may be taken at the basin outflow.

If no samples were taken within the last two years, any samples taken over the previous permit term (since September 23, 2016) may be reported on the NOI.

Facilities should act quickly in order to obtain the required outfall sample results prior to the March 23^rd submission deadline.

What New Monitoring & Reporting Requirements Are There?

The renewed PAG-03 requires increased levels of response for continual exceedances of the “Benchmark Values”. The first requirement is unchanged: two or more consecutive monitoring period exceedances of Benchmark Values triggers the requirement to develop and submit a Corrective Action Plan (CAP), implement additional controls, or apply for an individual permit if notified in writing by DEP. However, after four consecutive exceedances of the Benchmark Values, the renewed PAG-03 now requires permittees to submit the Stormwater BMP Checklist (3800-PM-BCW0083l) to certify that all applicable BMP controls have been considered for implementation. In addition,

new benchmark values of 9.0 S.U. for pH, 120 mg/L COD and 3.0 mg/ for Nitrate and Nitrite-Nitrogen have been added to each appendix that contains monitoring for those parameters; and
the new PAG-03 now requires monitoring for Total Nitrogen and Total Phosphorus in all covered industrial sectors.

New Laboratory Analytical Requirements

Permittees and their labs are now required to use an analytical method capable of meeting the Target Quantitation Limits (TQLs) for the parameters identified in the new PAG-03 General Permit. Failure to achieve the TQLs will be considered non-compliance by the PADEP, even though the TQL’s are an order of magnitude or less than the benchmark values. Based on our discussions with environmental laboratories, most of these TQL’s can typically be achieved, but some Method Detection Limits, for example, total aluminum and ammonia-nitrogen, are slightly below the laboratory’s method detection limit. Note that the environmental laboratory may need to use different analytical methods to achieve the TQL’s. This issue will need to be resolved with the PADEP in the coming months.

Brickhouse Environmental’s experienced staff of Professional Engineers, Geologists and Scientists are already working on several of our clients’ permit renewals, but we are happy and ready to assist you with your stormwater design, permitting and compliance implementation as well.

For more information, please contact Al Yates, P.E.

Pennsylvania’s new MCLs for PFOA and PFOS Will have Significant Impacts on Drinking Water Suppliers, Environmental Due Diligence, and Act 2 Cleanups

January 24, 2023

The Pennsylvania Department of Environmental Protection (PADEP) has announced its publication of the PFAS MCL Rule in the January 14, 2023 Pennsylvania Bulletin. The rule became effective as of that date.

The new rule sets the Maximum Contaminant Level (MCL) of 14 parts per trillion (ppt) for PFOA and an MCL of 18 ppt for PFOS in drinking water.

PADEP’s new PFAS MCL Rule webpage confirms that the rule applies to all public water systems in the Commonwealth, and that the monitoring requirements have been established for community water systems, nontransient noncommunity water systems, and bottled, vended, retail, and bulk systems (BVRBs). Initial monitoring will be required for 4 consecutive calendar quarters at each entry point (EP) to the distribution systems over the next year or two, depending on the type of system.

The new standards apply not only to public water systems, but also to environmental site cleanups, as these concentrations are also now adopted as new Statewide Health Standards for PFOA and PFOS in groundwater under Pennsylvania’s Act 2 regulations. This creates significant new considerations in Phase I Environmental Site Assessments in Pennsylvania, and may lead to more site owners seeking Act 2 cleanup liability protection in the future.

Brickhouse Environmental has been very active in the monitoring and evaluation of PFAS in groundwater, including source identification and migration studies. If you have questions on PFAS or how the new PFAS MCL Rule may affect your property, please contact David Farrington or one of our other Professional Geologists.

Brickhouse Welcomes Two New Employees

January 23, 2023

Brickhouse Environmental welcomes two new full-time team members, Mr. Ryan Stauffer and Mr. Christopher Hartsky.

Ryan Stauffer

Ryan comes to Brickhouse with over 10 years of experience in environmental consulting. His experience includes conducting environmental site assessments, sampling soil, groundwater, and soil vapor, and completing site characterization and remediation of petroleum contaminated sites throughout the Mid-Atlantic region. Ryan is a graduate of Millersville University with a Bachelor’s degree in Environmental Geography and a M.B.A from the University of Delaware. When not busy writing technical reports, Ryan enjoys rooting for the Eagles, Phillies, and Flyers with his wife and two sons.

Chris Hartsky

Chris is a graduate from Washington College with a degree in Environmental Science and West Chester University with a certificate in Geographic Information Systems (GIS). He comes to Brickhouse Environmental with 4 years of environmental sampling experience, including specialties in air emissions testing and database management. When Chris is not out leading one of Brickhouse’s field teams, you can find him on the golf course or at a local brewery enjoying a craft IPA.

Does my Business Need a Spill Plan?

January 23, 2023

“I didn’t even know what a Spill Plan is, let alone that I needed one!” This is something we have heard often, and it is understandable. Successful small businesses invest a lot of time and money establishing infrastructure, procedures and employee training to safely manage their process liquids and waste streams. However, they are sometimes unaware of specific regulatory requirements for a Spill Plan, and the benefits that they can provide.

Benefits of a Spill Plan – Some of the benefits of a plan include:

Spill prevention helps to protect workers
Timely and appropriate spill response can prevent discharges to the environment
Both of the above help reduce liability and costs
Regulatory compliance can avoid fines and/or shutdowns

Types of Spill Plans – Some of the more typical spill plans and their regulatory triggers are:

Spill Prevention, Control and Countermeasure (SPCC) Plan: The EPA requires Facilities with a total aggregate capacity of above-ground oil storage containers greater than 1,320 gallons of oil (containers 55-gallons or greater) or 42,000 gallons of oil stored in buried tanks, which could discharge to navigable water or shorelines, to maintain a SPCC Plan.

Note: “Navigable waters” can include perennial or intermittent streams and/or wetlands.

Facility Response Plan (FRP): The EPA requires Facilities that could reasonably be expected to cause “substantial harm” to the environment by discharging oil into or on navigable waters to prepare and submit Facility Response Plans (FRPs).

State-Specific Spill Plans: Individual states also have their own spill and emergency response plan, which are typically required by various stormwater, water quality, oil & gas, and waste management permits and regulations. For example, Pennsylvania has the Preparedness, Prevention and Contingency (PPC) Plan and New jersey has the Stormwater Pollution Prevention Plan (SPPP). These plans can typically be combined with a SPCC Plan.

Additional State-Specific Plans Related to Storage Tanks: For example Pennsylvania’s Spill Prevention Response (SPR) Plan, pertains to aboveground storage facilities with greater than 21,000-gallons of regulated substances.

RCRA Contingency Plan Quick Reference Guide: Recently, the EPA started requiring Small and Large Quantity Generators of Hazardous Waste to maintain a Quick Reference Guide in their RCRA Contingency Plan to better respond to hazardous waste releases and accidents.

Although mandated by different regulations, these spill plans share some common elements. They are created to prevent and respond to releases of oil, or other regulated substances, which could impact human health or the environment. The regulated substances are inventoried and required to be safely stored, such as in a fire box or secondary containment structure. They contain detailed worker training, response, countermeasures and public notification requirements in the event of a release. Finally, spill plans identify the manpower, procedures and equipment dedicated to preventing a spill from occurring or reaching the environment.

Who needs a Spill Plan:

Facilities that generate, manage or store significant amounts of oils or chemicals;
Facilities with greater than 1,320 gallons of aboveground oil storage or 42,000 gallons of below ground storage;
Facilities that require stormwater, water quality, oil & gas, or waste management permits;
Facilities required to implement a spill plan by state or federal regulators (this is often initiated after a spill or leak response); and
Small and Large Quantity Generators of Hazardous Waste.

Brickhouse Environmental’s experienced staff of Professional Engineers, Geologists and Scientists are able to quickly identify the need for a spill plan, and implement the required industrial compliance and reporting solutions. For more information, please contact Al Yates, P.E.