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Brickhouse Environmental

Brickhouse Environmental

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Newsletters & Articles

Act 2 Updates: Does Your Act 2 Site Still Require Post-Remedial Activity and Use Limitations?

May 19, 2022

The November 20, 2021 changes to Act 2 Statewide Health Standards (SHS) have created some beneficial opportunities for some previously remediated properties that still have post-remedial inspections, reporting, and Activity and Use Limitations (AULs).

For example, in the last 6 months: 

  • We helped one client remove the existing requirement for an asphalt cap, allowing unrestricted non-residential use of the property and a much less costly redevelopment project; and
  • Another client gained approval for unrestricted residential use of their property where groundwater use would have previously been prohibited, significantly improving their property value for re-sale.

Specifically for these properties, the changes in the 1,2,4-Trimethylbenzene standards in groundwater and the benzo(a)pyrene standards in soil allowed us to remove burdensome property use limitations and engineering controls.

Example No. 1

A gas station with petroleum releases to the soil was previously closed out under Act 2 using a Site Specific Standard due to benzo(a)pyrene concentrations above the Statewide Health Standard.

Therefore, the soils required a protective cap and annual inspections and reporting.

However, after the standard was raised from 0.58 to 4.2 mg/kg, the soil no longer exceeded the Statewide Health Standards, so we were able to remove the requirement for a protective cap and related post-remedial care obligations.

The removal of the cap and reporting requirements increased the redevelopment opportunities for the site and also improved the property value.

Example No. 2

A heating oil spill impacted soil and groundwater of a neighboring residential property.  Under a PADEP-approved Cleanup Plan, soils were excavated and replaced, and groundwater monitoring wells were installed.  Five years later, the homeowners still couldn’t sell their property because 1,2,4-Trimethylbenzene concentrations still exceeded residential Statewide Health Standards in the groundwater.  

In November, the Statewide Health Standard increased from 15 parts per billion (ppb) to 130 ppb, thus allowing the cleanup and monitoring to be ceased, and an Act 2 release of cleanup liability was issued by the PADEP, with no restrictions.  The change in standard immediately increased the property’s value and ability to be sold. 

The Bottom Line

In certain situations where sites previously received Act 2 cleanup approvals through the use of engineering controls and/or Activity and Use Limitations on the property, there may now be opportunities to remove these burdensome obligations and ultimately improve the future use and value of the property. 

If your property was previously remediated but still has ongoing maintenance, monitoring and/or reporting obligations, Brickhouse Environmental would be glad to review your reports and advise whether these benefits may be available for your property.

Filed Under: Brickhouse, Environmental Due Diligence, Read More, Technical Articles

PADEP Announces Public Comment Period on New PFAS Drinking Water Standards

March 31, 2022

The Pennsylvania Department of Environmental Protection (PADEP) has announced a 60-day public comment period on a new proposed rule to set maximum contaminant levels (MCLs) for PFOA and PFOS in drinking water. 

[Read more…] about PADEP Announces Public Comment Period on New PFAS Drinking Water Standards

Filed Under: Read More, Regulations, Technical Articles, Water Tagged With: padep, PFAS, regulations

Finally, Relief from Overly Restrictive Vanadium Standards in Soil

March 31, 2022

As we have detailed in previous newsletters during the past two years, many Pennsylvania site development projects requiring the import or export of soil from one property to another have been derailed by the presence of Vanadium in the soil.  This problem was caused by changes in the PADEP’s Management of Fill Policy in January 2020, which included the reduction of the clean fill standard for Vanadium from 1,500 mg/kg to 15 mg/kg in soil.  This concentration is substantially less than naturally occurring background levels typically found in soils in this region.  Due to the massive number of site remediation and development projects that were stalled as a result of this change, the PADEP recognized the problem, worked with many stakeholders, and has now published a new interim-final Technical Guidance Document (TGD) to address  background Vanadium concentrations in soil.

[Read more…] about Finally, Relief from Overly Restrictive Vanadium Standards in Soil

Filed Under: Read More, Risk Assessment, Site Remediation, Technical Articles Tagged With: risk assessment, vanadium

3 Easy Steps to Avoid Heating Oil Headaches

March 31, 2022

Many of us rely on heating oil as the fuel source to heat our homes. The heating oil is stored in either an above ground (in the home or outside) or underground (buried) storage tank that is connected to the boiler. Properly maintaining these systems can help avoid releases of heating oil, which can result in major headaches and unexpected expenses, especially with many new homeowner’s insurance policies excluding coverage for cleanup.  

[Read more…] about 3 Easy Steps to Avoid Heating Oil Headaches

Filed Under: Heating oil clean up, Read More, Technical Articles

Under the Slab: Vapor Mitigation Strategies for Brownfield Development

February 22, 2022

Ownership and redevelopment of brownfield properties can provide a business opportunity and greatly benefit a community. While there is significant potential for an all-around positive outcome, the owner or developer takes on the challenge of remediating or managing the contamination through working with environmental professionals and regulators. One of the most common challenges in managing contamination on these properties is dealing with vapor intrusion. 

Vapor intrusion can occur when soil or groundwater underneath or adjacent to a building is impacted by “volatile” contaminants, meaning they readily exist as a vapor (i.e., gas). Think of the vapors that emanate from an open can of gasoline or other household chemicals such as paints and stains. When petroleum products or other volatile chemicals are spilled, they can seep into soil and groundwater and become an ongoing source of potentially harmful vapor. When these vapors move through soil and building foundations it can diminish indoor air quality. This is called vapor intrusion and can result in building occupants being exposed to these contaminants while breathing. 

Vapor intrusion issues can be identified during due diligence, site development, or during characterization and remediation of known petroleum or other chemical spills. The nature and extent of the soil and groundwater contamination, as well as existing building conditions all have a significant impact on the best way to manage and resolve the vapor intrusion issue. It doesn’t matter if the building was constructed 200 years ago, 2 weeks ago or planned for construction in 2 months, there is a cost-effective solution. The solutions differ most significantly when considering mitigation of existing or new construction. Continue reading to learn more or call us at (610) 692-5770. 

[Read more…] about Under the Slab: Vapor Mitigation Strategies for Brownfield Development

Filed Under: Environmental Due Diligence, Read More, Site Remediation, Technical Articles Tagged With: Environmental Due Diligence, Site Remediation, vapor intrusion

New Phase I ESA Standard Redefines “Recognized Environmental Condition”

January 26, 2022

Through November of 2021, over 300,000 Phase I Environmental Site Assessment (ESA) Reports have been prepared in the United States in connection with the sale, purchase, financing, and development of commercial real estate.  The primary purpose of conducting a Phase I ESA is to identify whether there are Recognized Environmental Conditions (RECs) in connection with a property being investigated. 

With the release of its updated Standard Practice, ASTM E1527-21, the American Society of Testing and Materials (ASTM) offered several significant changes.  One of the most overlooked yet potentially significant changes involves the definition of a REC.  

[Read more…] about New Phase I ESA Standard Redefines “Recognized Environmental Condition”

Filed Under: Environmental Due Diligence, Read More, Regulations, Risk Assessment, Site Remediation, Technical Articles

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brickhouse@brickhouse-environmental.com

Testimonials

Michael, I am so pleased with the response time, and thoughtfulness of your effort and Brickhouse in general. I wasted a LOT of time with other environmental companies. I guess it’s never too late. I plan on working for another 20+ years. Both you and Doug have been fantastic.

Jack B.
 

Dave, Very solid and professional work Dave. Thank you for everything.

– Dan W.
 

Paul, Thanks for your excellent work and planning for this. Glad it is done!

– Phillip R.
 

Your field staff were awesome. Steve is especially sharp and communicates well with the client and attorneys.
The whole crew inspired confidence, and made a strong impression that Brickhouse is a quality outfit.

– Sam C. and Mark R.
 

Excellent job to all at Brickhouse! Yet another successful project, nice work! Thank you.

– Scott E.
 

The loan went through! Thanks for all that you have done for us, you did an amazing job!!!

– Pete S.
 

We officially sold the home. We thank you and appreciate what you have done to ease the transition. Your expertise is duly noted and it was nice working with you.

– Joseph P.
 

It was a pleasure working with you guys… I will definitely call again when we run into any environmental issues on our projects.

– Steven O.
 

You did an absolutely incredible job. I am so impressed by the level of detail in the report. Thank you so very much.

– David T.
 

Thanks Paul and company, great job.

– Richard B.
 

Your work has been excellent and I will be very happy to continue our relationship going forward.

– Gordon M.
 

Thanks for the status updates, I got out there as they were working on the newly uncovered well. Nice guys out there, personable and professional.

– Gary P.
 

Thank you very much for your assistance in my tank removal project. Your managers and field crew were a pleasure to work with.

– Chris M.
 

Thanks Michael, you did a fantastic job on this report, and made my life a lot easier.

– Brian B.
 

Thanks so much for your continued great work on this project. We are impressed with your work.

– Michael H.
 

Dave Farrington and Brickhouse have worked with Action Manufacturing Company as consultants on our Environmental projects with excellent results.

– Randy A.
 

I want to thank you and Brickhouse for your help throughout this process. I will recommend you to everyone that requires environmental services. Your company is truly professional. Thanks again.

– Tommy M.
 

Thanks Dave. Outstanding effort by you and your team in getting this done.

– Richard F.
 

I just heard from my colleagues in Philadelphia about the case.  They had nothing but praise for the effort your firm contributed.  Thanks for stepping up to this project at the last minute.

– John C.
 
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