Pennsylvania released the complete and final list of results of samples collected from public water systems after Governor Tom Wolf issued an executive order to address Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) in drinking water. The results do not indicate widespread PFAS contamination.[Read more…] about Pennsylvania Announces Final PFAS Statewide Sampling Results
Pending Revisions to the ASTM Phase I ESA Standard (E1527-13)
Professionals involved with commercial and industrial real estate transactions are almost assuredly familiar with the ASTM “Phase I Environmental Site Assessment” (ESA). Well, the current version of the ASTM Standard is due for revision in 2020.
Environmental due diligence has been an important factor in commercial and industrial property transactions since the 1980s, as proper due diligence was identified as a specific need for federal liability protection under CERCLA. In 1993, ASTM published E1527, the first “standard practice” for environmental professionals conducting Phase I ESAs. Since that time, the “ASTM Phase I Standard” (E1527) has been recognized as the industry standard for conducting the first phase of environmental due diligence.
Every 8 years, the ASTM standards expire and need to be revised. That time period will soon come for ASTM E1527-13, as it sunsets on December 31, 2021. Therefore, the new standard (E1527-21) must be finalized and published sometime in 2021.
The ASTM E50.02 subcommittee is working on updating several aspects to the standard. Key changes to E1527 are anticipated to include:
- Clarifications to the HREC and CREC definitions. The task group is working to refine the definitions for HRECs and CRECs and relationships between the various types of Recognized Environmental Conditions.
- Expansion of Historical Research to adjoining properties. The current version of the standard specifically requires historical research of the subject property, but the updated standard may require a more robust investigation of adjoining properties and the surrounding area.
- Non-Scope Considerations may be modified to reference emerging contaminants, especially PFAS.
Brickhouse Environmental is participating on the ASTM E50.02 subcommittee, and we will continue to track the status of the updated ASTM Phase I Standard. Continue to check our website and ASTM.org for future updates.
Winter is Coming
December and January are the busiest time of year for heating oil deliveries and, not surprisingly, the time of year for the most home heating oil spills. As a public service, the Pennsylvania Department of Environmental Protection (PADEP) has published a handy Fact Sheet (Tips for Residential Tank Owners) with somewhat easy Self-Inspection Checklists for basement and backyard above-ground heating oil tanks, as well as underground tanks. This publication provides information to help individuals deal with a heating oil release and any subsequent cleanup.
In this article, you will learn how to….
- Prevent Fire, Explosion and Exposure
- Stop or Contain the Release
- Report the Release
- Clean Up the Release
- Environmental Cleanup
- Help is Available
Take the time to inspect your tank and associated piping and fittings. Not comfortable with that? Have your heating oil delivery company do it. If you see minor drips, or corrosion of the tank legs, don’t put it off for later. It is important to catch tank issues before they become expensive problems. We know, because we have assisted homeowners with oil tank spills and they’re usually not covered by Homeowner’s Insurance.
View this helpful video from the PADEP
Utilize the Underground Heating Oil Tank Cleanup Reimbursement Program offered by the Pennsylvania Department of Environmental Protection. “The Underground Heating Oil Tank Cleanup Reimbursement Program provides funds to help with environmental cleanup costs due to releases of heating oil from underground tanks. This program is available to owners of underground heating oil tanks with a capacity of 3,000 gallons or less, used for heating onsite. In order to qualify for the program, the heating oil release must have occurred after January 30, 1998.”
So, inspect your tank – and have a happy, warm, and spill-free holiday season.
For more information, please contact us
Links: From the DEP
Underground Heating Oil Tank Cleanup Reimbursement Program
SRBC Grandfathered Water Use Registration Program
Susquehanna River Basin Commission (SRBC)
Program deadline is: December 31, 2019
Have you received a letter from the SRBC regarding your water use?
Do you have a groundwater withdrawal of 100,000 gallons of water per day or more initiated prior to July 13, 1978? *
Do you have a surface water withdrawal of 100,000 gallons per day or more initiated prior to November 11, 1995?*
Does your facility consume 20,000 gallons per day or more from surface water, groundwater, a combination thereof, or any other source (including a public water supply), initiated prior to January 23, 1971?*
Don’t miss the deadline and lose your grandfathered status.
If you answered yes to any of these questions, then you will want to utilize the Grandfathered Water Use Registration Program provided by the Susquehanna River Basin Commission.
NOTE Threshold volumes are expressed as consecutive 30–day averages. The facility’s volume is determined by totaling the actual daily withdrawal or consumptive use over the peak consecutive 30–day period, then dividing by 30.
* if you initiated a withdrawal above these quantities after the listed dates, you should already have a permit.
Have Questions? Reach out to Brickhouse Environmental’s SRBC expert, Stephen Huxta
Grandfathered Water Use Registration Program PDF
Frequently Asked Questions
Factsheet on Grandfathered Water Uses Registration Program
March Newsletter – Act 2 TGM, Vapor Intrusion, & more!
Since our inception in 1977, site investigation and remediation have remained at the core of our business with many of our clients and sites residing in Pennsylvania. Prior to the adoption of the Land Recycling and Environmental Remediation Standards Act (Act 2) in 1995, regulatory closures of cleanup sites were on a case by case basis, wrought with inconsistencies and sometimes frustration on all sides. It was the goal of Act 2 to bring a consistent site remediation process to the Commonwealth that would facilitate the reuse of unused or underused commercial/industrial properties. While that goal has been largely realized, experiences over the many years since 1995 have led to many changes and incremental improvements to the process.
The most recent and highly anticipated improvement to the Act 2 process is the publication of a revised Act 2 technical guidance manual (TGM) on January 19, 2019. While the regulations that established Act 2 (25 Pa. Code Chapter 250) provide the framework for the Land Recycling Program, the TGM provides a user’s manual for the Act 2 process. The prior version of the TGM was published in 2002 and was in need of a significant revision to reflect what was learned over the decades working with Act 2 and the changes in the science of site investigation and remediation.
The current rendition of the TGM includes 500+ pages and represents a significant rework and expansion of the prior version to provide clarity and detail where it was needed most. The most notable of the changes/additions include:
A significantly expanded section detailing the assessment and remediation of separate phase liquids (SPL) at both Act 2 sites (voluntary cleanups) and cleanups conducted at regulated storage tank facilities under the Corrective Action Process. Of particular importance, scientifically grounded endpoints to free product remediation were added.
The prior TGM did not originally include detailed guidance for the assessment of vapor intrusion. This void was later filled by a supplemental vapor intrusion TGM section that was most recently modified in January 2017. This version of the vapor intrusion TGM has been integrated into the current 2019 TGM.
Similar to vapor intrusion, the prior TGM did not provide detailed guidance for proper groundwater monitoring well construction and abandonment. A standalone “Groundwater Monitoring Guidance Manual” was established in 2001 prior to the TGM, however it quickly became outdated. The updated TGM includes a new detailed section dedicated to this topic.
The new TGM includes clarified and expanded sections pertaining to the establishment of environmental covenants consistent with the Uniform Environmental Covenants Act and the topic of post-remedial care.
As a company, we use the TGM on a daily basis under a wide range of circumstances. Our client might be a commercial developer looking to build houses on an abandoned contaminated commercial property, or a homeowner looking to restore their property value following a heating oil spill, or a regulated tank owner working through the Corrective Action Process following a release. Regardless of the reason for the cleanup, if it’s being cleaned up in Pennsylvania, your consultant and your regulator will likely be applying the Act 2 TGM to your site. Given the significant improvements to the TGM, we see these improvements translating to improved outcomes for our clients involved in remedial projects in Pennsylvania. Please contact us if you have any questions regarding the application of the Act 2 process to your remedial project.
For many brownfield redevelopers and commercial property owners, evaluating and managing the threat of vapor intrusion has become an unwelcome, but not uncommon, challenge. As urban renewal projects continue to “repurpose” old manufacturing buildings, replace old dry cleaners at retail shopping centers, and plow over gas stations, the potential for contaminated soil vapors to intrude into buildings continues to grow. To understand whether vapor intrusion is truly a concern at your property, it is helpful to understand the baseline causes and processes of soil vapor intrusion, and to maintain trusted experts to help separate true potential health threats and viable solutions from the smoke and mirrors.
Vapor intrusion occurs when vapors migrate from subsurface contamination into an overlying or adjacent building. In order for vapor intrusion to occur, first there must be a source of the vapors. The source is most commonly soil or groundwater impacted by volatile organic compounds (VOCs). Once in the vapor phase, these chemicals begin to migrate through the subsurface, and potentially into overlying buildings. The risk, or problem, comes when the occupants of that building breathe these vapors that can result in negative health effects. This may all sound familiar to radon — because it is! The realization of vapor intrusion as a concept stemmed from the concern over radon intrusion that took hold in the 1980s.
In the case that contaminated soil or groundwater is identified as a potential source for vapor intrusion, state and federal agencies have published extensive guidance on steps to evaluate risk to surrounding buildings. Depending on the relative location of the impacted soil or groundwater, the evaluation may include only a review of existing data versus screening values, or it may require sampling of 1) the air between the soil particles within the source area, 2) the air beneath the slab of the building, or 3) air within the building. This data can then be evaluated to determine if mitigation measures are warranted.
Brickhouse Environmental’s scientists and engineers understand the many variables that can impact soil vapor intrusion to buildings – including site-specific soil and rock conditions, preferential utility pathways, and building construction. If vapor intrusion is found to be a material threat at your property, there are options for mitigation. In new construction, vapor barriers can be installed beneath the building to prevent the migration of vapors to indoor air. For existing structures, sub-slab ventilation systems can be designed and installed to remove contaminated soil vapors from beneath the building and ventilate it to above the roofline. This continues to be the most common and successful approach. If a vapor intrusion concern is identified at your property, contact our experts to help verify the source and design the most cost-effective and least disruptive solutions for your site.
Pennsylvania’s Storage Tank and Spill Prevention Program regulations were significantly modified on December 22, 2018. The changes are focused on increasing the emphasis on proper equipment operation and maintenance with the goal of decreasing the number and severity of underground storage tank releases in the Commonwealth. The Pennsylvania Department of Environmental Protection – Division of Storage Tanks has created the following website to help regulated tank system owners comply with the new regulations: New Regulations
Brickhouse Environmental has an opening in our West Chester, Pennsylvania office for an Environmental Scientist/Geologist Project Manager who is looking for an opportunity for responsibility and growth in a vibrant, well-established, and growing company. The selected candidate will be responsible for scoping, performing, managing, and completing multiple concurrent project assignments in a team-oriented environment. The selected candidate will also be expected to play a significant role in the continued growth of our company, through project management and business development, and eventually staff development, and mentoring efforts.
For more information or to apply online, please visit our website: http://bhe.integral.support/careers/
If you have any questions about your site or project, or need a Professional Geologist, Engineer, or Licensed Site Remediation Professional, please contact us at 610-692-5770.