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  • 27 Jun 2025 10:34 AM | Anonymous member (Administrator)

    By Bill Allgeier, Laboratory Manager, ALS USA Environmental

    When it comes to monitoring Volatile Organic Compounds (VOCs) at brownfield sites, especially those in remote or power-limited locations, passive air sampling offers an accessible, reliable option. Unlike active sampling—which requires power sources and calibrated pumps—passive techniques rely on diffusion to collect samples over time. 

    These low-maintenance approaches are growing in popularity across site remediation, health and safety, and fenceline monitoring projects. This article covers the different passive VOC sampling tools available, their strengths, and how to choose the right one for your site.

    Cost Effective, Field-Friendly

    Passive air sampling collects airborne contaminants without pumps or powered devices. Instead, compounds are captured as they naturally diffuse through the air and into the sampling media. It’s a cost-effective and field-friendly method, ideal for long-duration monitoring or projects where access is limited. Common applications include indoor air testing, ambient outdoor air, personal exposure monitoring, and soil vapor investigations.

    Passive VOC Sampling Tools

    There are four key passive sampling options for VOCs. Each tool fits different field conditions, project goals, and regulatory contexts.

    • Silonite Canisters are ideal for “whole air” sampling. The canisters are filled over 24 hours using a flow regulator – they require no pump and allow for analysis of 60+ VOCs. Additional methods like reduced sulfur compounds and fixed gases can be analyzed from the same canister, removing the need to deploy multiple sampling techniques. They're highly versatile and suitable for indoor, outdoor, and soil vapor applications.
    • Passive TD Tubes are used for long-term sampling (up to 14 days, depending on the compound), especially for low-level VOC monitoring. They're small, rugged, and comply with EPA Method 325. Great for fenceline, LDAR, and indoor use. However, typically they have a limited number of analytes that can be reported. 
    • VOC Badges are the go-to option for personal exposure monitoring. Workers wear the badge for up to 8 hours to assess individual VOC exposure levels. These are compliant with occupational health standards.
    • Radiello Samplers are flexible samplers with a 7-day deployment window, ideal for industrial or mining sites. They measure up to 31 VOCs and can also support non-VOC testing (e.g., formaldehyde, NO2).

    Need to ship your samples fast? Canisters and TD tubes don’t require refrigeration and ship easily with commercial couriers.

    Choosing the Right Tool for the Job

    Selecting the best method depends on your project objectives, site conditions, and regulatory requirements. Consider:

    • •Sampling duration – Canisters (any duration up to 7 days), TD tubes (up to 14 days, depending on the compound), badges (8 hours), and Radiello (7 days).
    • Target VOCs – Do you need a wide panel (e.g., over 60 compounds)? Go with canisters. Need a focused list? Badges or TD tubes may suffice.
    • Sampling environment – For personal exposure, use VOC badges. For soil vapor, ambient air or industrial zones, canisters or TD tubes work better.
    • Accreditation needs – For example, ALS provides NELAP & AIHA accreditation for methods using canisters and TD tubes, ensuring data meets defensibility standards.

    Why Passive Sampling Works Well for Brownfield Sites

    Passive sampling is often the best fit for brownfield redevelopment projects because it’s simple, scalable, and doesn’t require power or bulky equipment. It can support key project stages, including baseline air quality assessments, post-remediation verification, and long-term monitoring. And since these methods are non-intrusive, they’re ideal in community-sensitive areas.

    Whether you’re assessing indoor air, monitoring an industrial fenceline, or verifying cleanup at a brownfield site, passive VOC sampling is a proven and practical approach that ensures your sampling campaign is efficient, accurate, and compliant.

    The Author:


    Bill Allgeier is Laboratory Manager of the ALS USA Environmental full-service laboratory in Rochester, NY.  Bill has been with the ALS environmental team for 26 years as an Analyst, Operations Manager and Lab Manager, and oversees a 24,000 sq ft. facility where the team processes over 290,000 air, soil, water, drinking water and waste sample tests annually.  

    Email: bill.allgeier@alsgobal.com

  • 24 Jun 2025 10:59 AM | Anonymous member (Administrator)

    by Christopher D. Valligny, LSRP, Montrose Environmental

    Embreeville Park in West Bradford Township, Pennsylvania, is a testament to what’s possible when environmental remediation, historical stewardship, and community planning converge. Once home to a psychiatric hospital complex dating back to the 19th century—and later, a brownfield marked by contamination and deteriorating infrastructure—the 200-acre property has been reimagined into preserved open space through a collaborative effort grounded in sustainable redevelopment.

    In 2019, facing a proposal for more than 1,100 residential units, residents rallied to chart a new course for the site. With community backing, the Township acquired the property for $22.5 million, halting the proposed high-density development and committing to the site's long-term ecological and historical value.

    Tackling Environmental Liability with Strategic Funding and Compliance

    Redeveloping a property of this scale—and complexity—demanded not just public support but also a robust financial and technical roadmap. Montrose’s brownfield experts helped secure a $1.5 million grant through the Land and Water Conservation Fund and assembled a layered funding portfolio with state and local partners. That financing enabled critical assessment, remediation, and early redevelopment work.

    Milestones included:

    1. Phase I & II ESAs to characterize environmental conditions and target contamination.
    2. Act 2 Program compliance, resulting in a Release of Liability and setting the legal foundation for future recreational reuse.
    3. Hazardous and universal waste removal, paired with geotechnical efforts that allowed on-site demolition debris to be safely reused for land stabilization.

    Historic Preservation and Community Cohesion

    The park’s transformation wasn’t limited to environmental cleanup. Guided by archaeologists, the project protected Native American cultural resources—preserving local heritage while restoring the land’s public utility. As of 2024, 185 acres have been designated for passive recreation and conservation. Planned improvements include walking trails, ball fields, and interpretive signage to showcase both natural and cultural history.

    Lessons for the Northeast Brownfield Community

    Embreeville Park offers replicable insights for BCONE members and other Northeast stakeholders:

    1. Community-Driven Outcomes: The pivot away from dense redevelopment exemplifies how public input can shift brownfield narratives toward long-term, non-commercial value.
    2. Creative Reuse: On-site material recovery for stabilization cut costs and reduced waste—an essential approach for municipalities with limited redevelopment budgets.
    3. Integrated Partnerships: Success hinged on tight collaboration between municipal leaders, environmental consultants, legal experts, and funding agencies.

    The Author:


    Christopher D. Valligny, LSRP, Senior Scientist II, Montrose Environmental

    Chris is a Senior Scientist with over 15 years of experience in environmental consulting, ecological research, and policy implementation. Licensed as a NJDEP Licensed Site Remediation Professional and UST Closure/Subsurface Evaluator, he also holds OSHA 40-Hour HAZWOPER certification. Chris manages complex brownfield investigation and remediation projects—including Phase I/II Environmental Site Assessments—throughout New Jersey, Pennsylvania, and Delaware. His interdisciplinary approach supports a diverse client base of insurers, municipalities, developers, nonprofits, and legal teams.

  • 23 Jun 2025 11:14 AM | Anonymous member (Administrator)

    by Abraham Cullom, PhD, Pace® Director of Water Safety & Management

    Brownfield redevelopment is often an attractive option for data center site selection. Data centers benefit from existing infrastructure, shortening construction time, and allowing the data center to reach full operability faster. Modern data centers can also transform under-utilized or abandoned industrial and commercial sites and boost local economies by creating jobs and stimulating demand for local services.

    However attractive they may be, brownfield development projects always carry risks. Before investing, developers often perform an Environmental Site Assessment (ESA) to identify and mitigate these potential risks, ensuring the site is safe for future use and protecting data center owners from unforeseen liabilities. 

    Contaminants listed as “Hazardous Substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) are a frequent target of investigation as CERCLA gives the EPA the authority to hold property owners liable for cleanup costs even if they were not responsible for the original contamination. However, CERCLA Hazardous Substances are not the only contaminants that can impact building safety and future liabilities. In this article, we highlight three areas that may not be automatically included in a data center site assessment but perhaps should be.  

    Asbestos

    “Friable” asbestos, meaning asbestos in a form or in materials that can easily be crumbled by hand, is a CERCLA hazardous substance. Therefore, environmental site assessments should include this substance, particularly if the building was constructed prior to the 1980s. 

    Nevertheless, stockpiles of asbestos-containing building materials were used for many years after the U.S. EPA prohibited most forms of asbestos in construction. Furthermore, even if the site has a history of asbestos abatement projects, decades-old records may not be entirely reliable. Some areas of the country have naturally occurring asbestos that could also present a problem, especially during construction or soil excavation. 

    Although Phase I ESAs do not typically include testing, to protect the investment, the site assessment team may want to consider working with a laboratory to analyze the presence of asbestos in accumulated dust during this phase. A simple “scrape and scoop” sample of settled dust can be analyzed using Polarized Light Microscopy (PLM) or Transmission Electron Microscopy (TEM). However, keep in mind that this method is not designed for precise quantification of asbestos fibers and is not suitable for regulatory compliance or legal purposes. More advanced sampling and analytical techniques can be used to validate and further quantify asbestos fibers in settled dust in late-phase ESAs.

    Waterborne Pathogens and Microbially Influenced Corrosion (MIC) 
    Brownfield sites that have existing, operational HVAC systems can offer redevelopment advantages. However, if the building has been unoccupied for any length of time, checking water systems for signs of microbial activity may be warranted. Microbes thrive in the warm, stagnant water that pools inside unused pipes, equipment, HVAC systems, and more. For the data center operator, this can create a couple of major issues.

    The first challenge is the potential for dangerous pathogens, such as Legionella, to colonize the biofilm that often forms inside older or unused water systems. When the water is turned on, the increased pressure can dislodge these bacteria and release them into the water system. The primary way Legionellosis, the disease caused by the bacterium Legionella, is contracted is through breathing aerosolized droplets containing the bacteria. This exact scenario can be created through cooling systems used by data centers. In fact, CDC research found cooling towers to be the second largest source of Legionellosis outbreaks. (An outbreak is defined as two or more people getting sick.)

    The second challenge is microbially influenced corrosion, or MIC. MIC is also associated with the presence of biofilms. As colonies form and grow inside water systems, they can affect the electrochemical environment of a material's surface and accelerate corrosion. MIC is a significant concern in industrial settings, and the damage caused by MIC can amount to billions of dollars annually in increased maintenance and replacement costs as well as damage to systems and property. 

    In addition, MIC has been shown to reduce cooling system thermal efficiency. As corrosion worsens, the uneven surface inside the pipes and equipment creates even more pockets for biofilms to form. The resulting biofilm can foul heat exchangers, impeding heat transfer and reducing the efficiency of the cooling system. 

    There are several types of tests available to detect and identify dangerous pathogens in water systems. Due to the dangers presented by Legionella in particular, regular testing of cooling systems for the presence of Legionella is recommended. In addition, a Biological Activity Reaction Test (BART) can be used to detect and monitor specific types of microbial activity in water systems. For instance, BART can be tailored to look for broad groups of bacteria, such as those involved in sulfur cycling (sulfate-reducing bacteria, sulfide-oxidizing bacteria), iron-related bacteria (iron-oxidizing and iron-reducing bacteria), slime-forming bacteria, and heterotrophic bacteria. 

    Lead-Lined and Galvanized Steel Pipes

    Despite ongoing efforts to replace lead and galvanized steel pipes, the U.S. EPA estimates more than 9 million lead-based water service lines are still in use across the country. Lead-lined water service lines are more susceptible to corrosion from factors such as dissolved oxygen, low pH, and low mineral content in water. Not only can this corrosion release lead into the water systems, but it also creates pockets for biofilms to form, further accelerating the corrosion and the release of even more lead into the water system. Clearly, this is an issue if the lead service lines feed the building’s potable water systems. In addition, as discussed in the preceding section, the resultant biofilms can also negatively impact thermal efficiency. 

    Galvanized steel service lines were also commonly installed in the U.S. during the first half of the 20th century. These pipes have a zinc coating designed to prevent rusting. While galvanized pipes themselves do not contain lead, lead particles can accumulate within the corrosive buildup in these pipes if they are or have ever been connected to downstream lead pipes. When water flows through galvanized pipes, it can release the built-up lead particles, leading to water contamination.

    Under the U.S. EPA’s Lead and Copper Rule, efforts are being made to identify and replace lead and galvanized steel service lines. However, a significant portion of service lines have yet to be characterized thanks to incomplete record keeping when these lines were installed. Testing for lead in the water system can help determine if lead or galvanized steel service lines are in use and may need to be replaced.

    Exploring the Risks for Greater Rewards

    Brownfield sites hold immense potential for data center development, offering existing infrastructure, cost-efficiency, and opportunities for economic revitalization. However, these opportunities come with an inherent need for thorough due diligence. While CERCLA hazardous substances are a primary concern, developers should broaden their scope during ESAs to consider additional risks that may not be immediately apparent.


    Potential issues such as residual asbestos, waterborne pathogens, and legacy piping materials like lead-lined or galvanized steel can pose significant operational, financial, and health challenges if overlooked. Assessments that leverage advanced sampling techniques and testing methods can significantly reduce liabilities and ensure the long-term safety and efficiency of the facility.

    The Author:


    Abraham Cullom, Ph.D., Director of Water Safety and Management, Pace® Building Sciences 

    Dr. Cullom is the Director of Water Safety and Management at Pace®. He holds a B.S. from the University of Pittsburgh and a Ph.D. from Virginia Tech in Civil and Environmental Engineering, where he published multiple peer-reviewed papers demonstrating the impact of in-building plumbing environments on important opportunistic pathogens, antibiotic resistance, and microbial ecology. A cross-disciplinary expert, Dr. Cullom translates insights from engineering, microbiology, and chemistry into practical solutions to mitigate disease risks in water systems and help end Legionnaire’s disease. 

  • 11 Jun 2025 11:46 AM | Anonymous member (Administrator)

    By Matthew J. Gozdor, Quantitative Hydrogeologist/Senior Technical Specialist at GZA GeoEnvironmental, Inc.

    With artificial intelligence (AI), scientists and engineers are faced with a familiar question: The tools are impressive on their own, but how do we use them to provide effective, reproducible results? Our recent work for a client to develop a groundwater model that was as accurate as traditional modeling but with fewer data points and lower cost helps illustrate the way forward.

    For this project, we focused on machine learning (ML), which is a subset of AI. ML uses algorithms and statistical models to analyze data for patterns, draw inferences from those patterns, and learn from the patterns without being issued explicit instructions. In this instance, we needed to demonstrate to regulators that impacted groundwater was discharging to a nearby stream and not flowing underneath the stream.  

    Traditional modeling to meet our objective required obtaining a significant amount of information through complex field work and gathering historical information, LIDAR data, geological data, etc. The information needs for our ML model were significantly less and limited to weather information from a nearby weather station, river elevation data, and groundwater levels. Our AI-assisted model used Python, a common programming language popular in the ML community, and an open source “package” named Pastas developed for groundwater scientists and engineers to analyze hydrogeological time series. Pastas uses a transfer function noise model to show how the groundwater system will respond to a  stressor (e.g., precipitation) while also incorporating random noise on the output to better reflect the complexity of a hydrogeological system. 

    To test the model, we used it to predict future groundwater elevations which were compared to actual measured values over time. Using the Normalized Root Mean Square Error (NRMSE), which compares the predicted values against the observed values while normalizing them by the standard deviation of the observed data, we found that our ML model’s values came within 2% of real-world observations.

    Our approach has the potential to be used in a wide range of groundwater scenarios, from estimating snowmelt effects to controlling groundwater in tunneling operations. Core to going forward, however, will be ensuring that the model reflects the real-world data, and that the data reflects the risks: In other words, trust, but verify. 

    Scientists and clients are understandably concerned about how to use these tools and where they fit into our work. By developing ML models that can be checked against real-world results, and carefully choosing what data a model is built on, clients and contractors alike can make better-informed decisions, while saving time and money.

    The Author:


    Matthew J. Gozdor is a Quantitative Hydrogeologist and a Senior Technical Specialist at GZA GeoEnvironmental, Inc. With 25 years of experience, his focus is on groundwater flow modeling, fate & transport modeling, aquifer testing design and evaluation, and hydrologic evaluations.

    www.gza.com, matthew.gozdor@gza.com

  • 07 May 2025 2:23 PM | Anonymous member (Administrator)

    by Tony Finding,CHMM, Brownfield Science & Technology, Inc. (BSTI)

    When your in-situ environmental remediation system goes live, it might feel like the hard part is over. The installation is complete, the contractors have cleared out, and regulators are off your back. But a quiet site doesn't mean it's time to take your eye off the ball—especially when it comes to operations and maintenance (O&M) costs.

    Based on over three decades of designing, building, and operating remediation systems, here are ten professional strategies to ensure your O&M dollars are working hard—every year of your project.

    1. Know Your Endgame Before You Start

    Don't just focus on cleaning up contamination—consider whether you need to clean it up at all. Regulatory endpoints based on risk assessments can allow for scaled-back remediation if human or environmental risks are minimal. Even with an active system, a fresh look at your endpoints might reveal you're closer to closure than you think.

    2. Design with O&M in Mind

    System designers often over-engineer for peak contamination. But as mass removal rates decline, you're left operating an oversized system at full cost. Request cost projections for both early and steady-state phases, and push for lifecycle budgeting that highlights long-term expenses. Design choices—like centralized monitoring points—can significantly reduce site time and improve data quality.

    3. Use the Right Tool for the Right Job

    Remediation often starts with aggressive “hammer” solutions. But as contaminant levels drop, those systems can become excessive and inefficient. Adaptive site management lets you switch to more targeted “Q-tip” solutions later on, potentially saving thousands without compromising outcomes.

    4. Choose Skilled Operators, Not Just Warm Bodies

    An experienced system operator does more than read meters—they monitor trends, anticipate problems, and fine-tune performance. If your system experiences frequent downtime or surprise repair costs, you might have a “meter reader” instead of a true O&M professional.

    5. Beware of the “Lowest Cost” Trap

    Competitive bidding can drive down hourly rates, but if each new contractor delivers diminishing returns, the long-term cost may be higher. Operators who lack incentive to close out a site might prolong a project indefinitely. Invest in quality service, not just low rates.

    6. Follow the Money: Understand Your Spending

    Dissect your budget. Are your dollars going to energy-hungry systems with minimal output? Are you collecting redundant data? Is fouling causing frequent failures? Understanding cost drivers helps you prioritize solutions and streamline your program.

    7. Match Technology to the Phase

    Early on, robust renewable technologies (like thermal oxidizers or soil vapor extraction) are efficient. But as contaminant levels drop, consumables like activated carbon might be cheaper. The key is knowing when to switch. A good operator can help optimize timing based on treatment cost per mass removed.

    8. Embrace Telemetry and Remote Monitoring

    Simple telemetry systems offer huge savings. They alert you to faults in real time and reduce the need for routine site visits. They also allow techs to show up prepared, cutting down on costly return trips. Smart monitoring prevents unnoticed downtime—days, even weeks—that delay progress and inflate costs.

    9. Don’t Get Distracted by “Bells and Whistles”

    Not every automation is worth the price tag. While some features are essential (like remote valve control for high-risk sites), others add cost without value—and sometimes even create new maintenance burdens. Evaluate your system needs critically to avoid over-engineering.

    10. Schedule Annual Optimization Reviews

    No system performs exactly as designed. Conditions change—water tables shift, surface cover alters, infrastructure evolves. An annual review with your operator ensures you adapt to these changes. It’s a powerful opportunity to reassess system performance and capture savings year over year.

    The Author:


    Tony Finding, CHMM, serves as Vice President and Director of Remediation Technologies at Brownfield Science & Technology, Inc. (BSTI). With over 25 years of experience in environmental consulting, Tony is a Certified Hazardous Materials Manager and a leading expert in environmental remediation system design, implementation, and optimization. He has directed the successful completion of more than 300 remedial projects across the Mid-Atlantic region, bringing deep expertise in technologies such as in-situ chemical oxidation, bioremediation, and advanced groundwater treatment. Tony is also a recognized leader in the assessment and remediation of PFAS and other emerging contaminants, and has contributed to national technical guidance through the Interstate Technology and Regulatory Council (ITRC).

    Contact:

    Tony Finding, V.P., Director of Remediation Technologies

    Email: tfinding@bstiweb.com

    Phone: (610) 593-5500

    Website: www.bstiweb.com

  • 24 Apr 2025 8:30 AM | Anonymous member (Administrator)

    by Lindsay Boone, M. Sc., Pace Analytical Services

    The reclamation and redevelopment of brownfield sites represent a critical opportunity to breathe new life into underutilized spaces. However, a thorough site assessment is essential to understanding a site’s past usage and the potential it presents for future liabilities. Furthermore, the designation of PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) has made PFAS a critical component of any site redevelopment assessment. 

    In this article, we discuss the primary test methods used to analyze PFAS in environmental matrices with the goal of arming readers with the insights they need to chart a clear path forward.

    Test Methods for Brownfields Analysis

    For the purposes of brownfield redevelopment, an environmental analysis can cover a variety of matrices, such as groundwater, surface water, stormwater runoff, soil and more. In 2024, the U.S. EPA finalized EPA 1633, providing the industry with a standardized, validated method for analyzing targeted PFAS compounds in non-potable aqueous and solid matrices.  

    We are seeing the EPA as well as state agencies utilize 1633 in programs in National Pollutant Discharge Elimination System (NPDES) permitting. The Department of Defense (DOD) has also relied heavily on EPA 1633 for PFAS remediation projects when analyzing non potable matrices.  Yet, while EPA 1633 may be used for brownfield site assessments, these projects do not always involve direct EPA or DOD oversight. This allows project managers in some cases to leverage other test methods for analyzing PFAS in environmental matrices.

    An alternative method, ASTM D8421, was developed by the American Society for Testing and Materials to provide the industry with a quick, easy, and robust method for PFAS in non-potable aqueous matrices. This method was validated using reagent water and tested with difficult matrices including landfill leachate, metal finisher wastewater, Publicly Owned Treatment Work (POTW) influent and effluent, and other non-potable water. 

    The ASTM D8421-22 documentation describes the method this way: This test method covers the determination of per- and polyfluoroalkyl substances (PFASs) in aqueous matrices using liquid chromatography (LC) and detection with tandem mass spectrometry (MS/MS). These analytes are co-solvated by a 1+1 ratio of sample and methanol then qualitatively and quantitatively determined by this test method. Quantitation is by selected reaction monitoring (SRM) or sometimes referred to as multiple reaction monitoring (MRM).  

    ASTM D8421 provides several advantages over EPA 1633: 

    • Turnaround time (TAT) is typically faster than more procedurally complex methods like EPA 1633.
    • ASTM D8421 is typically a less expensive test to perform than EPA 1633.
    • ASTM D8421 is a low-volume test, requiring only three containers of 5 ml each. This makes sample collection and shipping easier and less expensive.
    • ASTM D8421 has been validated for 44 PFAS. This includes the 40 PFAS quantifiable by EPA 1633 plus PFPrA, a short chain PFAS, and TFSI, a compound of interest in DOD projects.
    • Technically similar to EPA 8327, either method can be cited.
    • ASTM D8535 is technically similar to ASTM D8421. Pace® has validated this method for analyzing PFAS in soil and other solids.

    ASTM D8421 is a “performance-based” method, meaning it can be adapted or optimized for specific projects or analytical goals. Pace® added isotope dilution which is also used for quantification in EPA 1633.

    Is ASTM D8421 a Screening Method?

    The short answer to this question is no. However, “screening method” is a user-defined term without a universal understanding or definition. At its essence, ASTM D8421 is a definitive method. There is some confusion regarding the capabilities and ability of ASTM D8421 to meet specific Data Quality Objectives (DQO). To clarify, it is essential to understand the difference between a “screening method” and a “definitive method.”

    Definitive test methods deliver data suitable for final decision-making (of the appropriate level of sensitivity, precision, and accuracy) and legally defensible. These methods are typically developed in accordance with rigorous scientific standards to ensure they provide consistent, reproducible results that accurately reflect the presence and concentration of PFAS compounds. Definitive test methods require a precision and bias statement.  

    Screening methods produce data that can support an intermediate or preliminary decision but should eventually be supported by definitive data. For example, EPA 1621 is defined by the EPA as a screening method as it only “estimates” the concentration of AOF (adsorbable organic fluorine) in a sample. ASTM D8421 can certainly be used by various stakeholders to meet screening-level DQOs; but at its essence, ASTM D8421 is a definitive method.

    Interesting Developments Are on the Horizon

    Interestingly, the landscape for PFAS test methods can change even faster than the regulations, and there are some interesting developments in the works. As expected, the EPA has proposed adding EPA 1633 to 40 under Methods Update Rule 22, further cementing the use of these methods in EPA regulatory actions. 

    Just as importantly, MUR 22 also proposes incorporating ASTM D8421 by reference. “By reference” simply means that the Congressional Federal Record (CFR) will link out to documents authored by the standards body that developed the method instead of including all details in the CFR. This relieves at least some of the documentation burden for the agency. Once ASTM D8421 has been incorporated as a “Part 136” test method, the EPA can incorporate it into other Clean Water Act (CWA) regulatory programs if it so chooses. 

    The Author:


    Lindsay Boone, M.Sc.  is a PFAS Technical Specialist at Pace® Analytical Services and frequent speaker on PFAS-related issues including treatability and remediation studies.

  • 06 Mar 2025 2:05 PM | Anonymous member (Administrator)

    These standards may apply to sites undergoing remediation as well as sites that have been closed

    By Kristen English and Mindy Sayres, PG, LSRP, GZA GeoEnvironmental, Inc.

    If you’re wondering what the New Jersey Department of Environmental Protection’s (NJDEP’s)  updated Ground Water Quality Standards (GWQS) mean for you as an environmental consultant, site owner, or prospective site owner, here are some key points to consider.

    Background

    NJDEP amendments to the GWQS changed the criteria for 73 compounds, including 50 that were made more stringent. Of those, the GWQS of seven compounds have been decreased by an Order of Magnitude (OOM) or more.  Effective February 3, 2025, these standards apply to Class II-A groundwater, which is essentially all groundwater in New Jersey.  It has been estimated that thousands of sites, both active and closed, will be impacted. 

    What are the Order of Magnitude compounds?

    The seven compounds for which standards have been decreased by an OOM or more—at least 10x more stringent—are: 1,1-Biphenyl; Cobalt; Free Cyanide; 1,3-Dichlorobenzene; Heptachlor Epoxide; Methoxychor; and Vinyl Chloride.  

    How do these new standards change what is required at my site where remediation is underway?

    • If a remedial action workplan (RAW) or remedial action report (RAR) is submitted by August 3, 2025, the former GWQS remain in effect, except for those seven compounds with OOM changes. It is imperative that an evaluation be completed for those seven compounds to determine if groundwater concentrations remain in compliance and protective of human health and the environment. If they do not meet the new standards, additional investigation and/or remediation may be required. 
    • At sites where the RAW/RAR have not been submitted by August 3, 2025, the new GWQS will apply.

    An RAO was issued for my site – will the case be reopened?

    There has been much discussion in the environmental community in the short time since the GWQS were published as well as in the comments/responses of the newly published GWQS about potential “reopener” triggers for cases that have been closed, i.e., have a Response Action Outcome (RAO) or No Further Action (NFA). Indeed, the science of each site varies, and environmental consultants will work closely to advise their clients appropriately as these scenarios are further explained by the NJDEP.

    Thus far, in response to multiple comments included in the February 3, 2025 New Jersey Register publication of the new GWQS regarding the potential for cases with a final remediation document to be reopened, the NJDEP response has included the following information:

    • For sites with a Restricted-Use RAO or Limited Restricted-Use RAO with an approved Groundwater Remedial Action Permit, an OOM evaluation for the seven compounds noted above must be conducted and included with the next Biennial Certification submittal. Depending on the results of that evaluation, additional actions may be required. 
    • If a site has been closed with an unrestricted RAO or an unrestricted NFA, the OOM evaluation would be required if/when the site “re-enters” the NJDEP’s Contaminated Site Remediation and Redevelopment (formerly named the Site Remediation Program), which could be prompted by a property transaction or other triggers.

    What are the most common constituents for which standards have been made more stringent?

    In addition to Vinyl Chloride (one of the seven compounds for which the standard has decreased by an OOM), three of the 50 compounds for which standards have become more stringent and which are very commonly found on contaminated sites in New Jersey include:  Benzene; Tetrachloroethene; and Trichloroethene.  These compounds are often present in groundwater at sites in New Jersey impacted by historical uses such as dry cleaners, gas stations/auto repair shops, and industrial and manufacturing facilities that used solvents in their operations, to name a few.

    What if the site I am considering purchasing is contaminated?

    Environmental due diligence, including a Preliminary Assessment (PA) and, if necessary, a Site Investigation (SI), remains critical for buyers in New Jersey to make informed property transaction decisions. This investigatory process demonstrates that the buyer has conducted “all appropriate inquiry” and entitles the buyer to “innocent purchaser defense” under the Spill Act; this can protect the buyer from responsibility for additional evaluation requirements or costs associated with the new GWQS. Compliance with the new GWQS is the responsibility of  the Person Responsible for Conducting Remediation (PRCR), as determined by New Jersey’s Spill Act and/or Brownfield Act. 

    The Authors:


    Kristen English is a Senior Project Manager at GZA with more than 25 years of experience in the environmental field. Her expertise lies in soil and groundwater remediation at hundreds of sites throughout the Northeast including brownfields and UST closures. Kristen.English@GZA.com

      Mindy Sayres, PG, LSRP is a Senior Vice President of GZA and the District Office Manager of the firm’s Fairfield, NJ office. She has more than 30 years of environmental consulting experience, leading project teams tackling complex geologic, hydrologic and contaminant investigations.  Mindy.Sayres@GZA.com
  • 03 Feb 2025 5:37 PM | Anonymous member (Administrator)

    By Ryan Givens, AICP, Montrose Environmental

    The U.S. Government Accountability Office (GAO) reports over 1.5 million abandoned properties across the U.S. – creating voids and a sense of abandonment in our cities and local communities.  These sites, including industrial buildings, office parks, and waterfronts, have potential to be reimagined as new community-serving destinations through resolute revitalization planning strategies. A clear vision is crucial for revitalization, involving community members, leaders, and experts to identify opportunities and set a trajectory for change

    Key Approaches:

    Adaptive reuse involves converting and modernizing existing structures.

    • Convert old buildings into residential units or commercial spaces.
    • Challenges include upgrades and compliance with safety standards.

    Urban infill entails building new opportunities on vacant urban lots.

    • Develop new projects on vacant urban lots, integrating with the surrounding area.
    • Challenges include limited space, parking, and potential environmental issues.

    Redevelopment means replacing outdated sites with transformative developments.

    • Replace outdated structures with new developments.
    • Examples include transforming vacant shopping centers and industrial plants.

    Public realm enhancements include upgrading streets, parks, and public spaces.

    • Add landscaping along public streets, repair sidewalks and create recreational amenities.
    • Challenges include funding for enhancements.

    Strategy Tips for Successful Revitalization:

    1. Adapt Regulatory Tools: Amend zoning and building codes to accommodate and entice investment.
    2. Identify Infrastructure Upgrades: Assess and upgrade infrastructure to support redevelopment projects and support new tenants.
    3. Resolve Environmental Barriers: Identify and address contamination and hazardous substances to ready sites for redevelopment and reuse.
    4. Secure Funding: Identify funding sources for revitalization projects.
    5. Rebrand and Market: Rebrand areas to attract new investors, residents, and visitors.

    By incorporating these strategies, communities can transform abandoned properties and distressed neighborhoods into thriving, sustainable environments.

    Tools and Resources

    • EPA Brownfields Program: FY 2025 Brownfields Job Training Listening Sessions
    • Case Studies on Urban Revitalization: World Bank Report on Urban Revitalization
    • Current Vacancy Rates in the U.S.: Census.gov - Housing Vacancies and Homeownership

    The Author:


    Ryan Givens, AICP, is a dedicated City Planner and Urban Designer with 24 years of experience in community design, master planning, and revitalization strategies. Passionate about urban places, Ryan specializes in land use planning, urban infill, and redevelopment, focusing on transforming neglected properties into vibrant community assets. His expertise in environmental assessments, infrastructure planning, and funding strategies ensures successful project implementation, making him an invaluable partner in revitalizing neighborhoods and commercial districts.

  • 05 Dec 2024 12:13 PM | Anonymous member (Administrator)

    by Alex Bazeley, AC Power

    A closed landfill in Niagara, New York is now powering a brighter future. The Pine Avenue Landfill is bringing clean, affordable energy to over 2,300 homes since two newly constructed solar projects on the site came online in early November. The 13.5 MW-dc development will also generate over half a million dollars in revenue for the town and its school district, bolstering their municipal budget.

    While its neighbor, the iconic Niagara Falls, has always symbolized natural power, the solar array on the Pine Avenue Landfill shows how dormant land can be revitalized to advance renewable energy for a community long affected by industrial activity. The success is the result of a collaboration involving AC Power, Calibrant Energy, Montante Solar, and the Town of Niagara, combining their expertise to transform previously contaminated land into a renewable energy resource that benefits the community.

    This case study explores the site's history, the development process, the web of permitting and engineering challenges — along with the solutions used to overcome them — and the wide-ranging benefits brought to the Town of Niagara through this project. The milestone not only marks a new chapter for the region, but also stands as a replicable path forward for other municipalities looking to give land a new life and bring the energy transition to its residents. 

    The Opportunity of Brownfields

    Across the United States, there are tens of thousands of brownfield sites — former industrial or commercial properties that may be contaminated and have limited potential for redevelopment. For many years, these sites were seen as liabilities, burdened by their histories and costly remediation. But with growing demand for renewable energy and an increased focus on sustainability, more landowners are recognizing the potential of these properties as prime locations for solar and other renewable energy projects.

    Brownfields, including capped landfills, offer a unique opportunity to generate clean energy while revitalizing previously unused land. By converting brownfields into renewable energy assets, municipalities can achieve multiple goals: reducing environmental hazards, generating local economic benefits, and contributing to statewide and national renewable energy targets. Projects like the Pine Avenue Landfill solar installation demonstrate that brownfields are not just a problem to be managed — they are a resource to be harnessed.

    A New Chapter for the Pine Avenue Landfill

    The Pine Avenue Landfill’s legacy of disposal stretches back more than a century, when in the late 1800s Union Carbide began using the site for the dumping of industrial manufacturing waste. It transitioned into a solid waste management facility in the 1970s, coinciding with Republic Services-Allied Waste’s takeover of the property as owner. The site is part of a 385-acre complex which includes an active solid waste landfill directly to the north of one of the solar projects, seven closed solid waste landfills, and six closed hazardous waste landfills. 

    In 2022, AC Power began discussions with Republic Services to transform closed portions of the landfill. Leveraging their expertise in repurposing contaminated sites, they identified an opportunity to turn this challenging piece of land into a productive asset — generating renewable energy for the community and delivering economic benefits. But the journey from concept to construction required a deep understanding of environmental compliance, creative engineering, and strategic partnerships.

    Initiating the Process

    With portions of the landfill capped and others still active, the site presented unique permitting and environmental challenges, including securing access for the installation and operation of the solar facilities, ongoing landfill gas collection and monitoring at the project sites, and interconnection design and siting of electrical equipment on and off the landfill cap. The various levels of environmental regulation throughout the larger landfill complex underscored the creativity required for this project and the urgency with which a forward-thinking solution was needed.

    AC Power initiated a Phase I Environmental Site Assessment and critical issues analysis/permitting matrix to verify that the closed and capped sections of the landfill could support the development of the solar projects, while remaining compliant with environmental regulations. Accordingly, the developers proposed two 5-MW-ac solar energy generating facilities on two separate sections of capped and closed landfills. 

    Navigating Permits and Incentives

    Once a lease agreement was secured, attention turned to permitting for the development, which necessitated creative thinking and relentless pursuit of the project. Working with outside land use counsel, the developers coordinated with the Town to obtain a use variance that allowed the project to be sited on the existing landfill sections, in addition to bringing the project through the State Environmental Quality Review and site plan review processes.  

    The NYSDEC post-closure use modification application required comprehensive stormwater analysis, geotechnical assessments, and operational planning to demonstrate the viability of solar development at the site. Tetra Tech, as an engineering partner on the project, conducted the vital work to meet these requirements, while the developers worked closely with the Town of Niagara to secure zoning approvals and a use variance for siting the solar projects.

    The developers leveraged both local and federal clean energy incentives to make the project economics pencil. The project was awarded a community solar incentive through NYSERDA’s NY Sun program, while the IRA’s provisions, which include a base Investment Tax Credit of 30% for solar projects sited on brownfields, were pivotal in financing the project. In addition, the site's classification as an energy community in May 2024, based on updated employment codes and regional unemployment data, enabled the project to access an additional 10% ITC. 

    By providing fair-paying jobs during the construction phase of the development under the IRA’s prevailing wage requirements, the project underscores the ways in which these projects can benefit local workforces. These jobs not only supported the solar industry but also contributed to skill development in clean energy construction, fostering a workforce prepared for future renewable energy projects.

    Innovative Engineering for a Challenging Site

    Engineering a solar project on a landfill requires creative solutions to ensure that the integrity of the capped landfill is maintained, and this site was no different. The resulting design involved a ballasted ground-mounted solar system — the industry standard for these types of projects — ensuring that no penetrations were made into the landfill cap and thereby protecting the underlying waste containment systems.

    More pressing, though, was the fact that portions of the site remained active, which meant navigating a web of existing infrastructure. The presence of active gas flares, groundwater monitoring wells, and at-grade gas lines required the developers to work diligently to obtain all required permits and approvals and bring the projects to notice to proceed while minimizing disruption.

    With the development process successfully navigated, AC Power was ready to sell the project, which would commence construction and lock in a long-term owner-operator. They found just that in Calibrant Energy, who would purchase the project in late 2023, and with Montante Solar on board as the EPC, the team was ready to break ground and get the energy flowing.

    Community Benefits

    The resulting project will bring renewable, discounted energy to more than 2,300 homes, enabling this community to directly share in the benefits of a decarbonized economy. In accordance with New York’s community solar guidelines, more than half of the project’s subscribers will be Low- to Moderate-Income, further democratizing the energy transition.

    The projects’ combined 13.5 MW-dc capacity translates to significant CO2 offset — approximately 3,630 metric tons annually, equivalent to removing 789 cars from the road each year or planting over 93,000 trees. Such impacts directly support New York State’s Climate Leadership and Community Protection Act CLCPA, which aims to achieve 70% renewable energy by 2030 and reduce greenhouse gas emissions by 85% by 2050.

    AC Power, along with outside counsel, worked with the town to implement a Payment In Lieu of Taxes agreement, an alternative revenue stream structure that provides municipalities with stable income over the life of the agreement. The PILOT agreement established an annual payment structure that will pay out more than half a million dollars to the Town and the Wheatfield School District over the next 15 years, which can be reinvested into community infrastructure and services. This arrangement ensures a predictable revenue stream for the town and school district, contributing to local services without increasing the tax burden on residents. 

    Additionally, Niagara County recently introduced a local ordinance, the first of its kind, requiring solar developers to have an end-of-life recycling plan for their projects. In compliance, Solarcycle contributed a decommissioning plan to the project to ensure that when the array has exhausted its abilities — in as soon as 25-30 years — the solar panels will be responsibly recycled. What this means is that Calibrant, as the long-term owner-operator of the project, will work with the Town to keep the panels from simply ending up in another landfill. This initiative sets a precedent for future solar projects and emphasizes the importance of sustainable practices throughout the project's lifecycle.

    Lessons for the Future

    The Pine Avenue Landfill project serves as a blueprint for how towns across the country can transform underutilized and problematic sites into renewable energy assets. The following key takeaways highlight the lessons learned from this project:

    1. Creative Engineering Solutions: Developing solar on capped landfills requires unique engineering approaches that protect the integrity of the site. Ballasted ground-mounted systems and tailored layouts that accommodate existing infrastructure are essential in ensuring the project can be built without disrupting the landfill's containment systems.

    2. Community-Centered Development: Projects that bring tangible community benefits — such as consistent revenue through PILOT agreements and clean, affordable energy for residents — are more likely to gain local support. Ensuring that Low- to Moderate-Income households benefit from the energy produced fosters community buy-in and equity in the renewable energy transition.

    3. Sustainable Lifecycle Planning: A commitment to sustainability must extend beyond the operational phase of the project. Planning for the end-of-life recycling of solar panels and other components ensures that the project’s environmental benefits are maximized and that future decommissioning does not result in additional environmental burdens.

    Conclusion: A Legacy of Resilience and Renewal

    With Montante completing construction on the project in late October 2023, the project was ready to come online and start writing a new chapter in the region’s environmental history. The Pine Avenue Landfill solar project is a testament to the power of innovative partnerships and strategic policy support in transforming brownfields into assets. By working with Republic Services and local stakeholders, and by leveraging the opportunities provided by the IRA, the Town of Niagara has turned a site with a complicated past into a source of clean energy, community benefits, and economic opportunity.

    The Author:


    Alex Bazeley is the Marketing Manager at AC Power LLC. Alex is responsible for developing and executing strategies that enhance AC Power's brand presence and recognition in the brownfield solar redevelopment space. AC Power is a mission-driven, woman-owned solar development company specializing in projects sited on contaminated land, including brownfields, landfills, Superfund sites, and more.

  • 30 Oct 2024 2:21 PM | Anonymous member (Administrator)

    by Christopher Dacey, Haley & Aldrich

    Our communities, businesses, economies, and natural environment face growing water-related challenges and impacts.

    These challenges are diverse and often disruptive, and they sometimes have devastating consequences for lives, livelihoods, and economies. Worldwide, over 90 percent of natural disasters are water- and weather-related, including drought, wildfires, pollution, and floods. In 2023, the National Oceanic and Atmospheric Administration confirmed 28 weather and climate disaster events that affected the United States, with losses exceeding $1 billion each. Since 1980, losses related to such events have exceeded $2.6 trillion.

    As demand for water grows, infrastructure ages, and climate change makes water-related challenges more frequent and dynamic, such costs are likely to increase.

    Also, there are many water challenges outside of natural disasters that can be disruptive and costly, such as contaminated water supplies, operational inefficiencies and upsets, evolving regulations and costs, environmental liabilities, and water security, that businesses must contend with regularly.

    No aspect of our communities, economies, or environment is immune to both the need for water and its inherent challenges. This duality often confounds decision making due to conflicting stakeholder objectives and shifting priorities. From industrial, mining, and agriculture operations to technology, utilities, and energy producers, water security and stewardship are critical and growing concerns. The need for sustainable water management and resource protection is further amplified as water resources become stressed under increasing demands.

    What is water risk?

    The UN Global Compact’s CEO Water Mandate defines water risk as the possibility of an entity or asset experiencing a water-related challenge. These challenges take many forms:

    • Water supply accessibility and reliability, driven, for example, by inadequate water storage or treatment systems, groundwater depletion, imperiled surface waters, and competing demands from agriculture, industry, urban areas, and environmental protection.
    • Water supply quality, which can be degraded by salinity, pollutant discharges, aging infrastructure, and poor waste management.
    • Flooding, a growing threat as sea levels rise, flood patterns change, and storms intensify with climate change. Flooding often disproportionately affects vulnerable populations.
    • Infrastructure failure, a potential consequence of extreme weather events.
    • Droughts, which, due to climate change, may become more intense and increasingly impact geographical areas unaccustomed to drought stress.
    • Regulatory discharge limits, which may necessitate water treatment, regulatory tracking, and sampling programs for compliance.
    • Supply chain disruption, which could follow floods or storms and impact transportation networks or vulnerable suppliers at any point in an operation’s supply chain. A common example is food supply disruption due to drought, freezes, and flooding.
    • Energy-water nexus challenges, because energy is required to withdraw, treat, and distribute water to the point of use, and energy is also consumed as water is used in industrial, manufacturing, agricultural, and cooling processes. Likewise, water resources serve a critical role in the generation of electricity and the production of fuels and can significantly affect the reliability and resilience of energy systems.
    • Regulatory uncertainty driven by changing administrations, policies, permitting requirements, regulations, legal challenges, and interpretations.
    • Knowledge management due to, e.g., employee turnover, reorganization, poor data management, and technology transitions.

    Community opposition to infrastructure modernization or other development projects.

    These challenges can evolve slowly — as in the case of a water supply dwindling over years of drought — or occur abruptly, as in the case of flooding caused by a storm. The extent of the risk involved is a function of the likelihood of a specific challenge occurring and the severity of the challenge’s impact, which, in turn, depends on the intensity of the challenge and the vulnerability of the stakeholder or asset. Simultaneous or frequent challenges — such as more frequent and intense storm events — can amplify impacts.

    When it comes to water, standard risk management approaches — including avoidance, mitigation, transference, and acceptance — present unique challenges and opportunities. Past risk assumptions may not be appropriate for many locations and industries due to evolving uncertainties and knowledge.  

    How can you manage water risk and make operations more resilient?

    Given that water risk encompasses such a wide, sometimes competing range of challenges, operations need multidisciplinary expertise and a holistic approach to properly integrate best practices for resource and risk management. They also need to ensure that the risk management strategies they adopt today can adapt to the uncertainties of tomorrow.

    The following steps can help manage water risk:

    Understand your vulnerabilities. We can think about water risk in four major categories: physical, regulatory, reputational, and technological. All four elements are interrelated, but an understanding of each can guide priorities and create a big-picture view of your current risk profile.

    • Physical risk. As the most visible aspect of water risk, physical risk often manifests as the effects of flooding, drought, landslides, inadequate infrastructure, erosion, water stress, ecosystem vulnerability, and water quality. Familiar examples of risk mitigation measures include engineering structures for flood protection or securing more reliable water supplies.
    • Regulatory risk. This aspect encompasses concerns such as evolving regulations, rising water costs, regulatory permitting uncertainty, water laws, and water allocation limits. The administration of water rights, laws, and regulations can vary significantly across jurisdictional boundaries, which can contribute to compliance and operational challenges.
    • Reputational risk. Given water’s centrality to healthy, prosperous communities and the increased public scrutiny of corporate environmental, social, and governance concerns, including environmental justice, projects that impact water supplies can draw intense scrutiny from local communities and other partners. Reputational risk factors include potential community opposition, shareholder concern and litigation, creditworthiness, insurability, and investment community expectations.
    • Technological risk. This risk area encompasses data governance, decision barriers, knowledge gaps, data quality, technology debt, technology transition, and change management. In other words, does a company have the right technology and practices in place for informed operational, compliance, and safety-related decisions as water challenges arise? Effective decision support solutions require careful assessment and implementation to prove useful and provide value.

    Assess your vulnerabilities to find your opportunities. A systematic look at each risk area mentioned above can help operations find where they are most vulnerable, which, in turn, can help prioritize mitigation efforts.

    A risk assessment can also help you identify the vulnerability of assets to water stranding, that is, assets that have or could stop producing a return due to a water-related event, such as flooding, inadequate water supply, poor water quality, or regulatory noncompliance. Without proactive actions, stranded assets can evolve into long-term liabilities.

    A thorough understanding of your risk can also reveal water-related opportunities: the possibility that you can drive value and positive outcomes through better water management.

    What is a water opportunity?

    With proper planning, tactics for managing risk can accomplish multiple goals — increasing the efficiency of your current water use, making progress toward internal sustainability commitments, and helping you better mitigate water risk.

    Water opportunities can include:

    • Efficiency gains. These gains include cutting water use by modernizing systems and practices to eliminate leaks and waste, performing regular water audits, and co-optimizing water and energy efficiency.
    • Recycling, reclamation, and restoration. These opportunities also increase efficiency and can make your site more self-sufficient or protected in the event of a water-related emergency. For example, a restored coastal marsh can mitigate the impacts of storms and flooding.
    • Opportunities to benefit your community. For example, that same restored coastal marsh could provide your community with recreation and wildlife habitat.
    • Risk mitigation cost sharing. Federal and nonfederal funding programs, such as EPA brownfields, stormwater, and infrastructure grants, offer cost-sharing opportunities, some of which can pair risk mitigation with conservation efforts. Stakeholder collaboration can also achieve mutually beneficial outcomes.
    • Nature-based solutions. Green roofs, permeable pavement, bioswales, and other green-design choices can protect water quality and offer side benefits, such as better air quality, wildlife habitat, and aesthetic appeal.
    • Technology sharing and leveraging. Properly aligned technology can provide cost savings while mitigating water risk — such as a water monitoring program that informs compliance and operational decisions or sharing information with stakeholders for transparency or to inspire innovative solutions.
    • A chance to employ the best available science and practices. A growing wealth of resources is available to guide risk mitigation and adaptation investment decisions.
    • Lower insurance costs. Demonstrating proactive water risk reduction measures can lower insurance costs and validate insurability.
    • Safer operations. Effective water risk mitigation protects people, assets, businesses, and the environment.
    • Future cost avoidance. By planning today, you can incorporate water risk reductions and sustainability into ongoing improvement plans to reduce future costs or build a water-resilient supply chain to protect future revenues.
    • Better monitoring of industry and international standards. The Alliance for Water Stewardship, the Global Reporting Initiative, the Sustainability Accounting Standards Board, CEO Water Mandate, and many other bodies offer regulatory and industry guidance related to water risk. Operations increasingly need to account for and disclose their sustainability, water stewardship, and water risk and opportunity initiatives. Tracking those standards and understanding your current state can build a more robust, accurate reporting structure.

    The Author:


    Christopher Dacey is a Technical Expert, Senior Hydrogeologist with Haley & Aldrich.


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