• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar

Call Us Today: 610-692-5770

Serving PA, NJ, DE, NY & Beyond

  • Facebook
  • Instagram
  • LinkedIn
  • Twitter
Brickhouse Environmental

Brickhouse Environmental

Sound Science. Trusted Advice.

  • Home
  • About Us
    • History
    • Principal Bios
    • Senior Management Staff
    • Careers
    • Giving Back
    • The Golden Brick
  • Services
    • Site Remediation
    • Environmental Due Diligence
    • Solid Waste Management
    • PFAS
    • Water Resource Management
    • Expert Testimony/Litigation Support
    • Heating Oil Clean-ups
    • Risk Assessment
    • Industrial Compliance
  • Projects
    • Gallery
  • News
    • Technical Articles
  • Resources
  • Contact Us
    • Request Brickhouse Vault Access

The New Year Kicks Off with a New PA Management of Fill Policy

January 6, 2020

  • the suing attorney has a protective cover on his coffee, but forgot to lower his safety glasses…
  • soil excavation at remediation site
  • A digger removes Soil to Dispose of in the appropriate way
  • Soil In Hand
  • A digger is moving dirt on a construction project

The Pennsylvania Department of Environmental Protection (PADEP) has finalized significant changes to the Management of Fill Policy (Document No. 258-2182-773), which took effect on January 1, 2020. The Management of Fill Policy was developed in 2004 to facilitate the unrestricted movement of uncontaminated material, such as soil, asphalt, brick, block, concrete and stone. The new policy will decrease many of the allowable contaminant limits, in some cases by large amounts. It will also synchronize the current and future clean fill standards with the Pennsylvania Land Recycling and Environmental Remediation Standards Act (Act 2).

Use this link to find out more about the PA Land Recycling Program.

This change has major regulatory and cost implications for brownfields redevelopment, real estate transactions, industrial and commercial operations, utilities and transportation projects. Basically, any project requiring excavation or ground disturbance could be impacted, especially in urbanized areas with “historical fill”. Some of the more significant elements to the new policy include:

  • Fill material is now a defined term that is limited to rock, stone, gravel, used asphalt, brick, block or concrete from construction and demolition activities that is separate from other waste. The term specifically excludes reclaimed asphalt pavement, naturally occurring asbestos, mine spoils or acid-producing rock.
  • The new Policy states that fill material containing polychlorinated biphenyls (“PCBs”) at concentrations in excess of 2 mg/kg may only be used if prior written approval is obtained from the United States Environmental Protection Agency.
  • The new Policy eliminates the previous numeric standards, which were developed in 2004. It replaces them with the lower of the current Act 2 residential direct contact numeric values for soils and the residential generic soil-to-groundwater numeric values. Consequently, the clean fill standards will automatically be updated when the Act 2 regulations are next amended.
  • Management of Historic Fill under the new policy now requires mandatory sampling for a broad list of target parameters.
  • Once it’s determined that fill material meets the definition of “clean fill”, a Certification of Clean Fill form must be filed electronically with PADEP (for informational purposes but not approval) before the fill material is transported to the receiving site.
  • Currently, there are no stated exceptions to the Clean Fill filing requirement, so it may apply to all projects as small as homeowners regrading their lawn or similar projects.  Moreover, if sampling of the fill material is necessary, Form FP-001 must be accompanied by copies of the sampling plan, all laboratory reports, data and documentation of any background determination.

Of particular concern with this new policy, is the lowering of standards for various regulated substances that are ubiquitous urban contaminants. For example, the clean fill standard for benzo(a)pyrene is decreasing from 2.5 mg/kg to 0.58 mg/kg, which is below the background level typically found in many developed areas in Pennsylvania. In addition, the clean fill standard for vanadium is decreasing from 1,500 mg/kg to 15 mg/kg, which is substantially less than typical naturally occurring background levels of vanadium in soils.

Based on our experiences, this change will result in soil from many additional sites exceeding the new clean fill standards. Excavated soil not meeting the new clean fill standard is typically either landfilled, at great expense, or managed as Regulated Fill under PADEP General Permit No. WMGR096.

Brickhouse Environmental is highly experienced with identifying the most environmentally safe and cost-effective strategies for managing excavation and fill materials from development and remediation sites.

Have Questions? Reach out to Brickhouse Environmental’s expert, Al Yates, AYates@brickhouse-environmental.com or call 610-692-5770

Documents:   Management of Fill Policy 258-2182-773

Filed Under: Site Remediation, Technical Articles

Primary Sidebar

Stay Informed

Thanks for signing up!

To stay informed and up to date on important regulations, technical guidance, and news, please join our email list

 

Our Services

Site Remediation
Environmental Due Diligence
Solid Waste Management
Industrial Compliance
Water Resource Management
Expert Testimony & Litigation Support
Heating Oil Clean-ups
Risk Assessment

Contact Us

515 South Franklin Street
West Chester, PA 19382
610-692-5770 (Phone)
610-692-8650 (Fax)
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.
 
  • Facebook
  • Instagram
  • LinkedIn
  • Twitter
Serving PA, NJ, DE, NY & Beyond

Copyright © 2023 · Brickhouse Environmental