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September 4th is National Protect Your Groundwater Day!!

September 4, 2018

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September 4th is National Protect Your

Groundwater Day!!

Protect your Groundwater Day is an annual observance established by the National Groundwater Association (NGWA) to highlight the responsible development, management, and use of groundwater. It is also a platform to encourage yearly water well testing and well maintenance.

According to the NGWA, 44% of the U.S. population relies on groundwater for its drinking water supply. It is also used for irrigation, livestock, manufacturing, mining, thermoelectric power, and other purposes, making it one of the most widely used and valuable natural resources on earth.

NGWA also notes that only 1% of the water on earth is usable, 99% of which is groundwater. Groundwater is the world’s most extracted raw material, with withdrawal rates in the estimated range of 259 trillion gallons per year.

And, as everyone knows, drinking 6 to 8 glasses of water per day is good for your health. So, don’t take that crisp, clear, and clean glass of water for granted!

Brickhouse Environmental encourages everyone to do their part in conserving and protecting this precious resource.

Emerging Contaminants Update – NYSDEC Requiring Site Owners to Investigate PFAS and 1,4-Dioxane in Groundwater

In our Spring news alert, we advised of the extensive impacts to drinking water supply systems throughout much of the country from PFOA and PFOS, which had been specifically identified as “emerging contaminants” by the U.S. Environmental Protection Agency (EPA). Public water supplies were shut down in numerous communities near military air bases and airports, due to the runoff and infiltration of these compounds from fire-fighting foams, which are probably the biggest contributor to these contaminants. Several of these sites are in our local area. (https://www.brickhouse-environmental.com/emerging-contaminants/)

The EPA has also labeled 1,4-dioxane as an emerging contaminant and, as toxicological studies continue, some states are lowering their groundwater standards to 0.3 ppb. This compound was a stabilizer added to the solvent 1,1,1-trichloroethane (TCA) in the 1950s, so it is commonly found in groundwater at solvent cleanup sites.

The newly discovered health risks from these emerging contaminants, combined with advances in laboratory detection technologies down to the parts per trillion, are causing federal and state agencies to re-open investigations into previously closed Superfund and other remediation sites. Also, beginning this Summer, the New York State Department of Environmental Conservation (NYSDEC) began issuing letters notifying remediation site owners of new requirements to sample their properties for PFAS and 1,4-dioxane.

Analytical methods for these compounds are costly, as the labs must detect down into the parts per trillion level. Sampling techniques require great care and specific expertise. As a result, the need to assess and/or remediate these compounds can represent a significant additional financial burden to site owners. As different states continue to develop their emerging contaminant programs, it is important for property owners with affected sites to obtain technical and legal advice early in the process, to help manage these issues and their associated liabilities.

The Proper Abandonment of Unused Wells

Regardless of well type (monitoring, drinking water, agricultural, etc.) or location, it is always good practice to properly abandon wells that are not being used and are not planned for future use. The goal of well abandonment is to prevent potentially contaminated surface runoff from directly entering our aquifers. Regulatory implications vary from state to state and, in some instances, from county to county. In Pennsylvania for instance, Chester County and Bucks County tightly permit and regulate the installation, use, and abandonment of all types of wells. In Montgomery County, only potable supply wells are similarly regulated. Other counties in Pennsylvania (typically more rural counties) have no specific permitting or regulatory requirements for wells. The Pennsylvania Department of Environmental Protection (PADEP) has also begun to more strongly encourage all well owners to properly abandon unused wells, particularly at closed remediation sites.

In New Jersey, the New Jersey Department of Environmental Protection (NJDEP) has taken this a step further. At environmental cleanup sites, before the regulators will issue a Remedial Action Outcome (RAO: a State issued approval indicating that remedial work has been completed), the persons responsible for cleanup are required to properly abandon (seal) all existing groundwater monitoring wells. These well abandonments, by regulation, must be performed by a New Jersey licensed driller who will document the well sealing. This abandonment documentation is a required submittal to obtain the RAO. If monitoring wells are damaged, covered, or cannot be located to be properly abandoned, a series of administrative filings and submittals will be required to obtain your RAO. This administrative work can extend the timeframe to closure and add unforeseen project costs.

Groundwater: A Global Resource

Today, billions of people still lack access to a safe, reliable water source. Yet, water is one of the most important resources we all need to survive. On the most basic level, we need it for drinking and sanitation. While hard to imagine not having enough water to safely fulfill our basic needs, in more arid climates and less developed societies in the world, water can be scarce and oftentimes unsanitary. It is worth noting that, in any condition, consumption of untreated surface water results in significant risk of water borne diseases such as cholera, typhoid, and dysentery. To add to the risk, unsafe drinking water sources are often great distances from people’s homes, resulting in hours of daily water retrieval. It is hard to imagine, but the ability to safely fulfill this basic need is a real and often insurmountable challenge.

There is hope. For many of these people, groundwater serves as a promising resource that can dramatically improve quality of life and provide opportunity for advancement far beyond basic needs. The main challenge is access. A local organization working to solve this problem, with a focus on long-term sustainability, is Lifetime Wells International (LWI).

The mission at Lifetime Wells International is to improve qualities of life in the developing world and reduce the number of people without access to clean water through working with local communities to install, maintain, and monitor water resource infrastructure. Their efforts are currently focused in Ghana and Tanzania. The primary method involves drilling a water supply well and installing a handpump in the heart of the community. While LWI helps communities transition from a potentially dangerous and unreliable surface water source to well-produced safe and reliable water from beneath the ground, LWI is spearheading the start of true change in the community’s access to a safe, reliable water source.

To maximize the lifetime of a well, Lifetime Wells International works with each community to develop and implement a water resource management system. LWI actively recruits and trains local pump mechanics capable of monitoring, servicing, and repairing the water resource infrastructure. By ensuring communities understand and are equipped to manage their new water systems and guaranteeing access to pump mechanics skilled in necessary maintenance and repair, LWI works to create reliable, safe, and sustainable water resources and possibilities for greater advancements in people’s quality of life. Since 2015, Brickhouse Environmental has been an active supporter of LWI’s mission and encourages you to take a closer look at their ongoing work at www.lifetimewellsinternational.org.

Historic Fill

August 7, 2018

Uncovering historic fill findings can be an unwanted surprise for a real estate development project. The need for unexpected testing and possible landfill disposal can crush a project budget. However, with proper due diligence and planning, you can avoid unexpected delays and costs.

What is Historic Fill?
Historic Fill is non-indigenous material that was previously placed on a property in order to raise the topographic elevation of the site. The fill material was typically imported from offsite, and had nothing to do with the operations conducted onsite. The material generally contains mixtures of soil and residuals, including coal or wood ash, foundry sands, construction or demolition debris, and/or dredge spoils. The source of the material is usually undocumented, and problems arise because it is often contaminated by residual metals and/or hydrocarbon compounds at concentrations exceeding regulatory cleanup standards.

Since historic fill is not federally regulated, various state agencies have developed their own specific definitions for “historic fill” in their states, and they have differing requirements for its management and remediation. Pennsylvania and New Jersey have some of the more robust regulations and policies on historic fill, but their approaches are very different. It is important to know the differences (see below).

How to Limit Surprises
Proper environmental due diligence (a Phase I ESA) should identify whether there is the potential for contaminated historic fill to be present on a property. If the potential is identified, Phase II sampling and analysis can confirm whether fill is contaminated, and whether it falls under that state’s definition of historic fill.

Historic fill is often found in urban locations, but can be found in suburban and rural locations, as well. The approach for assessing the fill should be site-specific, based on the project goals and design, geotechnical considerations, and State-specific regulations.

For instance, often times a site will have soil/fill material that is not physically suitable for constructing a building, based on a geotechnical study. The unsuitable soil/fill is shipped offsite. If this fill is classified as contaminated historic fill, it would need to be sent to a permitted landfill, at a cost of tens of thousands to hundreds of thousands of dollars. This could obviously cause major project delays and cost overruns. However, if this issue was identified during due diligence, the problem could have been avoided, or renegotiated upfront.

Different States Have Different Requirements
In most states, including Pennsylvania and New Jersey, there is no regulatory requirement to physically remove contaminated historic fill from the property. It can remain onsite. However, between these two states, not only is historic fill defined differently, but there can be significant differences in how the fill can be managed onsite, potential residual liabilities, and ongoing reporting and care obligations. Here are some highlights:

New Jersey

The biggest difference between Pennsylvania and New Jersey is that, as currently defined by statute, historic fill meets the definition of a discharge within New Jersey’s Spill Compensation and Control Act (N.J.S.A. 58:10-23.11), and therefore requires remediation.

Based on this requirement for remediation, the NJDEP has enacted regulations (N.J.A.C. 7:26E-5.4 and the NJDEP Historic Fill Material Technical Guidance Document) detailing requirements for the investigation and remediation of historic fill. Consistent with New Jersey Technical Regulations, a series of reporting and administrative filings will also be required to document the presence, delineation, remediation, and certifications for remediation of historic fill. In addition, the reporting and filings are required to be approved and signed by a Licensed Site Remediation Professional (LSRP) registered in the State of New Jersey.

There is flexibility in selecting the remedial strategy, and it can be tailored to property uses (i.e. residential vs. industrial use). The fill can be left onsite, if desired, by “remediating” through the use of engineering controls (e.g. capping at residential establishments), or institutional controls (e.g. deed notice), and a Soil Remediation Permit to ensure the continued protectiveness of the engineering control. But even this simplest of remedial strategies still requires a full delineation of the historic fill, the previously referenced administrative filings, and long-term reporting and care obligations until the controls and Remedial Action Permit are removed.

It should also be noted that New Jersey’s “Brownfield and Contaminated Site Remediation Act” requires the NJDEP to map regions of the state where large areas of historic fill exist and make this information available to the public. These maps are currently available, which is useful in conducting due diligence prior to purchase of a property, but can have other implications if you already own the property.

Pennsylvania

The management and handling of all fill material in Pennsylvania is regulated by the PADEP’s Management of Fill Policy (August 7, 2010). In this policy, defined classes of fill material include clean fill, regulated fill, and historic fill. The biggest differences between Pennsylvania and New Jersey are that, in Pennsylvania:

– there is no obligation to remediate historic fill, and

– the State has not mapped regions of the State where historic fill is known to exist.

If fill is known to have existed prior to 1988, even if it is identified as contaminated, it is defined as historic fill and there is no obligation to clean it up or delineate it. However, if you dig it up, and send it offsite, it must be sampled, analyzed, and characterized as a waste, unless sampling demonstrates that the material meets clean fill standards.

Also, in PA, if materials were buried or used to fill an area prior to 1980, it may not be classified as a waste at all, since it pre-dated Pennsylvania’s Solid Waste Management Act (Act 97).

Final Thoughts
The discovery of contaminated historic fill can introduce unwanted delays and significant cost increases to a development project. The extent of these impacts can be affected greatly by the particular State in which the project is being conducted, especially in Pennsylvania and New Jersey. Therefore, it is important to have a strong understanding of fill management policies and regulations, before digging into your real estate development project.

Project delays and cost increases can be avoided, or at least managed, by including historic fill evaluations as part of your environmental and geotechnical due diligence studies. By considering the potential presence of historic fill upfront, and incorporating its presence into your preliminary site design, you can avoid costly surprises during the project, and stay on-time and in-budget.

If you have questions regarding the management of historic fill, or other related issues, you may contact David Farrington, P.G. at dfarrington@brickhouse-environmental.com, or Alfred Yates, P.E. at ayates@brickhouse-environmental.com for further detail. Or feel free to call us at 610-692-5770.

Trail Blazer Run 2018

June 25, 2018

The Brickhouse Team had a great time sponsoring the Trail Blazer Run & Family Fun Hike again this year! We are happy to support East Bradford Township’s Public Trail Program and extend our warm thanks to everyone who participated and volunteered in the event. Cheers to all you Trail Blazers!

Save the Date!

June 11, 2018

Brickhouse Environmental is a proud sponsor of this year’s 7th Annual Trail Blazer Run & Family Fun Hike. Proceeds benefit East Bradford Township’s Public Trail Program.

Please join us to experience exclusive access to Paradise Farm Camps’ extensive trail network, which traverses 600 acres of scenic natural resources. The running and walking courses take participants on challenging – yet enjoyable – paths meandering through the woodlands and meadows of the historic camp, which originally opened in 1913.

For the last 20 years, East Bradford Township has been a leader in open space preservation and trails development. Today, the Township owns over 700 acres of land and maintains roughly 25 miles of trails, including the popular Brandywine Trail, located adjacent to PA Rt. 322 between Downingtown and West Chester. Seven years ago, East Bradford Township began the Trail Blazer Run to build community support for public trails and raise funding for trail improvement projects.

In the past seven years, the event participation has more than doubled, from approximately 140 participants to over 300. During that same period, gross revenue grew 175%, with sponsorship contributions accounting for roughly half of that revenue stream.

Beyond dollars and cents, the Trail Blazer Run has grown to be a significant event for the Chester County community. Friends and family of all ages enjoy the energy and atmosphere of this unique event. Each year, Victory Brewing sponsors a party after the races, during which all participants receive a well deserved cold beer (root beer for minors) and the comradery of the other participants.

5 Mile Trail Run:

Individual registration:
$25 (until June 15)
(or $30 on race day)

Team/Family registration:
$75 (max. 4 participants)

1.5 Mile Family Fun Hike:

Individual registration:
$20 (until June 15)
(or $25 on race day)

Fixed team/Family registration:
$50 (max. 4 participants)

Race day registrations are cash or check only; no credit cards.

Emerging Contaminants

May 3, 2018

Emerging Contaminants present special challenges when conducting Phase I and Phase II Environmental Ste Assessments (ESAs). Most people probably still not have heard of Perfluorooctanoic acid (PFOA) or Perfluorooctane sulfonate (PFOS), but for many people living near U.S. military bases, these chemicals have become very well known. Over the past few years, PFOS and PFOA have been generating headlines across the country, with drinking water contamination from firefighting foams reported on and around at least 37 military bases in 19 states. In the Philadelphia region, the highest profile contaminated military sites include the former Willow Grove Naval Air Base and current Horsham Air Guard Station, and the former Naval Air Development Center in Warminster, Bucks County, as well as New Jersey’s Joint Base McGuire-Dix-Lakehurst, and the Delaware Air National Guard Base in New Castle, Delaware.

PFOS and PFOA, the two most notable of the Perfluorinated compound (PFC) family, have been found in the blood of humans, wildlife, and fish. Adverse health risks associated with exposure to PFCs include developmental issues and select types of cancer (i.e. kidney cancer). These chemicals were widely used in firefighting foams from 1970 to 2015, to extinguish fires from aviation fuels at military sites and airports. On May 25, 2016, the United States Environmental Protection Agency (EPA) issued a public health advisory, and established health advisory levels of 70 parts per trillion (ppt) for PFOA and PFOS in drinking water. This interim standard is very low, and is especially impactful, considering that the compounds were previously unregulated in drinking water supplies. More recently, the States of Delaware and New Jersey have issued even stricter regulatory standards of 7 (PFOA and PFOS) and 14 (PFOA) ppt, respectively.

After the EPA classified these compounds as “emerging contaminants,” the Department of Defense required testing of water quality at nearly 400 facilities where the firefighting foam was used. The results have been staggering for some of these communities, as public water supplies have been shut down, due to significant exceedances of the EPA health advisory standards. More studies are yet to come, as Congress’ recently approved Omnibus spending bill allocated $44 million to the Air Force and $44 million to the Navy, to conduct additional studies and remediation, specifically on sites with suspected and/or confirmed PFOA and PFOS contamination.

As more studies are conducted, PFCs are being found in water supplies near other types of non-government facilities, including certain types of manufacturing plants, fire safety training centers, airports, and other undetermined sources. Locally, PFOA and PFOS have impacted drinking water supplies in two additional Bucks County neighborhoods, at the Ridge Run PFC Site in East Rockhill, and the Easton Road PFC Site in Doylestown. These Sites are actively being investigated by the Pennsylvania Department of Environmental Protection.

How Do PFCs Travel in the Environment?

The chemical characteristics of these compounds make them highly soluble in groundwater and persistent in the environment, as they do not hydrolyze, photolyze, or biodegrade. As a result, PFCs can migrate long distances through groundwater, and have been documented in contaminant plumes extending over one mile from the source area. Environmental release mechanisms have been documented to include direct discharge to the ground from extinguishing fires or in fire safety training areas, discharge of waste water to soils or drainage lines, land application of contaminated sludges, and dispersion from industrial air or vapor emissions. Once discharged to the surface soils, the soluble compounds migrate down to the groundwater with infiltrating precipitation, and disperse from there.

How Do They Impact Environmental Due Diligence?

PFOA and PFOS present special challenges for the Environmental Professional when conducting Phase I and Phase II Environmental Ste Assessments (ESAs). It is essential to stay up-to-date with both Federal and State regulations and advisories, which are continuously being updated for these compounds, as more is understood. Interim standards and advisory levels vary from state to state, and are often not included in a state’s published list of cleanup standards.

Consider a typical Phase I ESA for a commercial or industrial property transaction. As part of All Appropriate Inquiry, as defined by the EPA, the Environmental Professional typically follows specific protocols outlined in ASTM’s Standard Practice for Phase I Environmental Site Assessments, to evaluate whether potential environmental liabilities are present. Standard practice includes inquiry of reasonably available public records sources, to gather readily available information for the subject property and surrounding area.

This records search and review is typically accomplished through the acquisition and review of a Regulatory Database Report, which is available through specialized database providers; But due to the lack of published health standards and the short period of time since the publication of the EPA health advisory, there can be a lag time before even the known PFC sites make it onto these databases.

As a result, it is essential that the Environmental Professional keeps up-to-date with both the regulatory and technical landscape, as both are continuously evolving. They will need to rely on their specialized knowledge and experience to know when to dig deeper, and what questions to ask, to determine whether a property may have a greater potential for PFOA or PFOS liabilities. In a Phase I ESA, this carries through the interview process, the site reconnaissance, and the historical research of the property and neighboring properties. For a manufacturing site, the Environmental Professional needs to consider whether PFCs were ever part of the onsite manufacturing process. For commercial sites, we need to consider all potential offsite sources, current or historic, and evaluate the potential for the PFCs to have migrated onto the property from those offsite sources; And, of course, if fire-fighting foams were used onsite or on nearby properties.

The next set of challenges comes when there is a recommendation to collect groundwater or soil samples for PFOA and PFOS analyses. Specialized sampling equipment and techniques are required to prevent “false positive” detections, due to cross-contamination from sampling equipment, bottleware, lab equipment, or any number of other sources. Thus, in addition to a top-notch laboratory, an experienced Hydrogeologist and a solid QA/QC team are crucial for assuring accurate analytical results.

If you would like to know more about PFCs and other emerging contaminants, please contact one of our experienced Hydrogeologists at Brickhouse Environmental. We will be glad to assist you in any way that we can.