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PFAS Soil and Groundwater Investigation

Use of Fire Suppression Foam Leads to PFAS Soil and Groundwater Investigation

PFAS Fire Foam Site InvestigationVermont: In 2008, an unfortunate tractor trailer truck fire occurred at a truck terminal operated by our client, an international freight contractor. Approximately 500 gallons of fire suppression foam was used to extinguish the fire, along with thousands of gallons of water. During the fire, the saddle tanks on the truck ruptured releasing diesel fuel, motor oil and antifreeze to the ground surface. Cleanup activity followed, with an environmental contractor removing impacted asphalt and soils.

Fast-forward 10 years,  with new information about per- and polyfluoroalkyl substances (PFAS), the Vermont Department of Environmental Conservation (DEC) requested that our client complete an investigation of groundwater to determine if it had been adversely impacted by residual perfluorinated compounds (PFCs), specifically perfluoroocanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA).

To evaluate the soil and groundwater conditions at the site, Liberty scientists installed three groundwater monitoring wells. Soil sampling was performed concurrently with the well installation. Site investigation activities conformed to strict protocols to prevent cross-contamination of the samples from PFAS-containing materials that are commonly used during environmental investigations as well as in our everyday lives. A favorable outcome was achieved, as the results were below action levels and no further evaluation was required for this site.

What are PFOS and PFOA? Why should you be aware?

Much more information about per- and polyfluoroalkyl substances (PFAS) will be available in the future as both the state and federal governments further study the health impacts, establish standards and publish regulatory guidance. Currently many states have launched efforts in data collection, with Pennsylvania announcing a plan to conduct an initial sampling of over 3,000 public water systems last month.

Excerpted from the Pennsylvania Department of Environmental Protection Bureau of Safe Drinking Water PFAS Sampling Plan

Per- and polyfluoroalkyl substances (PFAS) are a large group of man-made chemicals that have been widely used in commercial and industrial processes since the 1940s. This class of chemicals includes more than 3,000 substances that have been used in a variety of industrial and consumer products including firefighting foam, textiles (stain and water repellant clothing, carpet, upholstery), paper and packaging (microwave popcorn bags), non-stick cookware, personal care products (dental floss, cosmetics, toothpaste, shampoo), adhesives, latex paint, metal plating, wire manufacturing, industrial surfactants and many other uses. PFAS chemicals have been found in the blood serum of 97 percent of the general U.S. population. PFAS chemicals have been detected in water in at least 38 states. PFAS are very stable compounds that remain in the environment for a very long time and bioaccumulate. The half-life of some of the common PFAS is estimated to range from 2 to 10 years. Two of the most widely-known PFAS are perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). Animal studies of PFAS exposure report: developmental effects, liver toxicity, kidney toxicity, immune effects, and increased risk of cancer. Only a few of the PFAS have been studied for their human health impacts. Human epidemiology data report associations between PFAS exposure and high cholesterol, increased liver enzymes, decreased vaccination response, thyroid disorders, pregnancy-induced hypertension and preeclampsia, and increased risk of cancer (testicular and kidney). PFAS chemicals are currently unregulated at both the federal and state level. In 2009, EPA issued a provisional Health Advisory Level (HAL) for PFOA and PFOS of 400 ng/L and 200 ng/L, respectively. EPA issued a Final HAL in May of 2016. According to EPA, the final combined lifetime HAL for PFOA and PFOS of 70 ng/L is protective of all consumers, including the most sensitive populations, with a margin of protection from a lifetime of exposure to PFOA and PFOS from drinking water. While PFAS chemicals have received much attention in both the scientific and regulatory communities, there remains a lack of knowledge regarding these chemicals, how they impact the human body and what lasting, long-term health effects may be realized as a result of exposure.

Read the entire document here: http://files.dep.state.pa.us/Water/DrinkingWater/Perfluorinated%20Chemicals/BSDW%20PFAS%20Sampling%20Plan_Phase%201_April%202019.pdf

PFAS Site Investigation Services and Remedial Planning

Liberty Environmental has an experienced team of scientists and geologists to provide site investigation and remedial planning around these emerging contaminants. To learn more, contact Andrew Fetterman, PG at 800.305.6019.

The post PFAS Soil and Groundwater Investigation appeared first on Liberty Environmental, Inc.

SRBC Grandfathered Water Use Registration Guide

SRBC Grandfathered Water Uses Registration

Susquehanna River
(Photo source: dep.pa.gov)

Susquehanna River Basin Commission (SRBC) Grandfathered Water Use Registration Guide

From the desk of Katie Cirone, PE

The Susquehanna River Basin Commission (SRBC) recently completed a study where it was revealed that up to one billion gallons of water used in the basin per day is not under SRBC oversight. To rectify this issue, grandfathered water uses must register with SRBC by December 31, 2019 in order to preserve their grandfathered status and avoid obtaining an approval in the future. SRBC is an interstate agency that covers parts of New York, Pennsylvania, and Maryland, and operates independently of the environmental agencies in these states.

What is a grandfathered water use?

SRBC regulations state that certain water uses that are in excess of the regulatory thresholds do not require approval if those activities predated applicable regulations, provided there is no environmental harm. The type of water use, regulatory threshold, and effective date of regulations are summarized below:

Type of Water Use Regulatory Threshold

(gallons per day)

Effective Date of Regulation
Consumptive Use 20,000 January 23, 1971
Groundwater Withdrawal (onsite wells) 100,000 July 13, 2978
Surface Water Withdrawal 100,000 November 11, 1995

How do I know if my facility is considered a grandfathered water use?

If a consumptive use or withdrawal was initiated prior to the effective date of regulation and exceeds the regulatory threshold volume listed above, then your facility is considered a grandfathered water use and must register with the SRBC. If your facility has an existing approval issued by the SRBC, you must still register any grandfathered sources.

The regulatory threshold volume is determined by summing the actual daily withdrawal or consumptive use over the peak consecutive 30-day period from the past five years, then dividing by 30. If that number meets or exceeds the regulatory threshold, then your source must be registered with SRBC.

What is a consumptive water use?

Consumptive use is defined by the SRBC as the loss of water due to transpiration by vegetation, incorporation into products, evaporation, injection of water or wastewater into the subsurface, or any other process by which the water is not returned to the waters of the basin undiminished in quantity. This applies to all incoming water sources, including surface water or groundwater withdrawals, stormwater capture, or public water supply. If your facility is taking in more water than it is discharging, then it is considered a consumptive use.

The simplest calculation for consumptive use is the difference between metered inflow to the facility and metered outflow from the facility. Common consumptive uses include cooling towers for power generation, commercial, or institutional use; steam vented during a manufacturing process; and incorporation of water into final products.

How do I register my facility?

Registration of a grandfathered water use is completed online and requires submission of the following information and a $1,000 registration fee.

  • Basic information about the facility and its water sources
  • The method of tracking or metering quantities of water
  • Historical withdrawal and/or consumptive water use quantity data

What happens after I register my facility?

After you register your facility as a grandfathered water use, SRBC will ensure that your facility will maintain the existing exemption from project review and approval moving forward. Your facility will be subject to annual reporting of the water use once registration is completed.  At this time, there is no ongoing annual fee for registered sources.

What if I don’t register my facility?

If you neglect to register a grandfathered water source on or before December 31, 2019, the facility loses its exemption from SRBC review and approval. A formal application will have to be submitted to SRBC for review, and the source will be subject to all SRBC rules and regulations.

To speak with an experienced environmental permitting consultant, please call us at (800) 305.6019.

The post SRBC Grandfathered Water Use Registration Guide appeared first on Liberty Environmental, Inc.

Cirone Joins Liberty Environmental

Pennsylvania Environmental Compliance Expert

Katherine “Katie” Cirone, PE
Environmental Compliance Specialist

Lancaster, PA: Environmental Engineer, Katherine (Katie) Cirone, P.E., has joined Liberty Environmental, Inc. as a Compliance Specialist. With a strong background in environmental consulting for manufacturers, Katie provides industrial clients with environmental compliance assistance including industrial wastewater and stormwater NPDES and air quality permitting; annual waste, EPCRA, and air quality reporting; management of regulated wastes; regulatory agency coordination; emergency response planning; spill plan development; and compliance audits.

Cirone is a graduate of Wilkes University with a B.S. in Environmental Engineering. She resides in the City of Lancaster and loves the ability to walk to work.

The post Cirone Joins Liberty Environmental appeared first on Liberty Environmental, Inc.

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