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.
In short, for fill not affected by a release of Vanadium, the PADEP has provided the following statewide Representative Background Concentrations (RBCs) for Vanadium in soils:
Pennsylvania: 129 mg/kg
New Jersey: 136 mg/kg
New York: 118 mg/kg
These presumed background concentrations may now be used instead of a costly and time consuming site-specific vanadium Background Demonstration for fill originating in Pennsylvania, New York, or New Jersey.
While the Management of Fill Policy may still provide some site-specific hurdles to clear when moving soil fill to a receiving site in Pennsylvania, the overly broad restriction from naturally occurring Vanadium in soils has been removed. Which is a welcome change for the better.
Brickhouse Environmental has many years of experience helping clients navigate Pennsylvania’s Management of Fill Policy and related soil management issues. Contact David Farrington, P.G., Alfred Yates, P.E., or any of our Geologists or Engineers for additional information.