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What Are PFAS and Why Are They an Issue?

Per- and polyfluoroalkyl substances (PFAS) are a class of approximately 5,000 anthropogenic fluorinated chemicals whose presence in the environment is becoming of significant interest both in the United States and abroad.  PFAS have been used since the 1940s in numerous industrial and residential products such as Aqueous Film Forming Foam (AFFF) for firefighting, metal plating, food packaging, specialty surfactants, non-stick cookware, water-resistant fabrics, and others.

Understanding release mechanisms and pathways, assessment strategies, fate and transport, and remediation of PFAS continues to prove to be challenging.  PFAS is found somewhat ubiquitous in nature, from military installations, sewage treatment facilities, drinking water wells, and even in air.  Some PFAS, such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), are thought to be recalcitrant and bioaccumulate, thus posing potential significant impacts to humans and the environment.  Ongoing toxicological work indicates PFAS exposure may have suggestive carcinogenic potential while other studies potentially link PFAS to elevated cholesterol levels, immune system response and function, low birth weight, and others (ITRC, 2018). 

Chemical Structure of PFOA (Utah Department of Environmental Quality)

PFAS owe their recalcitrant nature to their chemical structure, which is commonly defined as being a “two-part” chemical.  The first part, referred to as the “tail”, is comprised of covalently bonded carbon and fluorine.  This carbon-fluorine bond is known to be one of the strongest in nature, due to the large differences in electronegativity between carbon and fluorine.  The “head” consists of a functional group such as a carboxylic or sulfonic acid, typically found in nature as a negatively charged anion.  Together, the head and the tail give PFAS its remarkable hydrophobic and hydrophilic properties.

How Can EEC Help?

EEC has extensive experience in dealing with emerging contaminants, such as PFAS, and the challenges they bring. Over the years, EEC has successfully helped its clients deal with emerging contaminants, such as hexavalent chromium, 1,4-dioxane, and perchlorate, and has developed comprehensive cost-effective site investigation and remedial solutions. With the evolving nature of emerging contaminant issues, EEC remains at the forefront by keeping up to date with current regulatory issues, such as the development of health advisory/notification levels and testing for PFAS in drinking water, issuance of investigative orders for corrective action and site investigation, development of testing protocols in drinking water and groundwater, and evaluating treatment technologies to remove PFAS from water.

EEC is committed to assisting its clients with potential upcoming issues with PFAS. Whether it’s groundwater, surface water, or drinking water sampling; or developing the best treatment approach for cleanup, EEC’s team of highly experienced scientists, geologists, and engineers have the capability to address the emerging issues revolving around PFAS.

EEC’s Services for PFAS:

  • Feasibility studies for PFAS removal in water, wastewater, and leachate
  • Owners agent / Owners Advisor for water purveyors
  • Subsurface investigation and sampling of soil, sediments and groundwater
  • Historical research and source identification
  • Plume evaluation and modeling
  • Remedial design and treatment of soil, sediments, and groundwater
  • Industrial wastewater treatment
  • Aerially deposited PFAS studies
  • Installation of remediation systems


soil pollution services

Why We Work on Managing and Reducing Soil Pollution

At EEC Environmental, we offer numerous services designed to manage and reduce soil pollution. Reducing soil pollution is important to the environment and the health of every living thing on the planet.

Why Managing and Reducing Soil Pollution is Important

The Food and Agriculture Organization (FAO) of the United Nations spells out five reasons why soil pollution is important and needs to be addressed.

It Touches Everything

Soil pollution affects all aspects of our lives. Our health and the health of our planet are dependent on the quality of our soil.

It Threatens Our Future

Experts say soil pollution has degraded one-third of our topsoil. Since it takes a thousand years to generate 1 cm of topsoil, pollution today will affect countless generations to come.

It Affects Soil Filtration

Soil acts as a natural filter for chemicals and other toxins, and soil pollution diminishes soil’s filtering potential. In other words, soil pollution stops our soil from protecting us from contaminants.

It Increases Food Insecurity

Because soil pollution reduces crop yields and the nutritional quality of those crops, it contributes to the rising problem of food insecurity. To guarantee a wide availability of safe and nutritious food, it’s essential to maintain healthy soils.

It Puts Our Health at Risk

Human and animal antibiotics released into the environment seep into the soil and help to create antimicrobial-resistant bacteria. The spread of these bacteria decreases the effectiveness of antibiotics which are used to combat both common and deadly diseases. Almost a quarter million people die each year as the result of these bacteria that are resistant to traditional antibiotics.

How to Reduce Soil Pollution

Here are some of the ways that industries and municipalities can manage and reduce soil pollution from their facilities.

Soil, Groundwater, and Soil Vapor Remediation

EEC’s experts can help redress pollution found in nearby soil. Our engineers, geologists, and hydrogeologists are experienced with several remedial techniques, including soil vapor extraction (SVE), in situ chemical oxidation (ISCO), and dual phase extraction (DPE).

Brownfield Redevelopment

Managing existing soil pollution is important when redeveloping brownfields into viable properties. EEC can handle all aspects of the environmental redevelopment, from initial due diligence to remedial action plans.

Stormwater Services

Stormwater runoff is a major cause of soil pollution. EEC offers a variety of stormwater management services, including design, inspection, and compliance for MS4s, SWPPPs, and BMPs.

Let EEC Environmental Help Manage Soil Pollution

EEC Environmental has worked towards managing and reducing soil pollution for more than 25 years. Our team of scientific and engineering experts has established our reputation as one of the top environmental companies in the United States. We work from our Annapolis, Maryland, and Los Angeles/Orange County locations to serve the environmental needs of private and public clients across the country.

Contact EEC Environmental today to learn how we can help you manage and reduce your soil pollution footprint.

Industrial Wastewater – CERCLA Allocation Project

Understanding CERCLA Cost Allocations

Part of the EPA’s mandate under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) is to remediate sites listed under the National Priorities List (NPL) that contain hazardous waste (also called Superfund sites).

For any site that requires remediation, the primary responsible parties (PRPs) will go through a cost apportion process to establish the settlement amount. The cost allocation process may depend on the types of contamination, the number of PRP’s involved, the site category, and various other factors.

The act applies to past and present owners, operators, generators, and transporters of hazardous waste. Therefore, understanding CERCLA’s cost allocation process and knowing what pitfalls exist can help entities determine their liability and share of responsibility for the remediation of a specific site.

CERCLA Cost Allocation Processes

Since the act passed in 1980, some entities expressed their frustration with the CERCLA cost allocations process due to the high transaction fees. To streamline the process, the Office of Site Remediation Enforcement (OSRE) reached out to entities involved with the apportioning of Superfund site costs. Although the findings in the document aren’t legally binding, it does provide entities with best practices when navigating the cost allocation process.

The costs that the EPA can enforce on a Superfund site include:

  • Direct costs: Any expense traceable to a specific cleanup activity.
  • Annual contracting costs: Costs of contractors providing training or services to a variety of sites.
  • Indirect costs: Expenses calculated by the EPA for the administration and operations of the agency.

4 Best Practices for CERCLA Cost Allocation

The higher costs incurred by PRPs during the allocation process are usually derived from the retroactive, strict, joint, and several liability schemes involved. If settlement efforts fail, the litigation costs and transaction fees can increase exponentially. To avoid this, the OSRE found that appointing an allocator at the beginning of the process could help reduce the costs while also enabling a fair and equitable outcome for the parties involved.

It’s common for PRPs to establish an allocation committee that develops the allocation methodology. The committee will appoint an independent allocator who will follow a process to help them reduce the costs and allocate liabilities between the parties fairly.

1. Establishing Procedural Rules

Rules regarding ex parte communications, appeals, and resolving disputes will ensure the parties conduct a fair allocation process. The primary goal of the procedural rules is to achieve an expeditious settlement with the EPA without resorting to excessive litigation between the parties.

2. Data Collection and Information Gathering

After the parties agree to the procedures, the allocator can start gathering data and information relating to the Superfund site. Using the EPA’s 104(e) rule, allocators can use information requests relating to site and disposal records, conduct interviews, and issue questionnaires to involved parties.

3. Applying Allocation Factors to PRPs

Using the procedural rules, allocators assign proportionate costs to each PRP. Factors that influence the cost may include the amount of waste involved, the toxicity of the materials, the degree of involvement of a party, and the level of cooperation of each PRP. Allocations may also differ between classes of parties such as generators and transporters or owners and operators.

4. Finalizing the Allocation Report

The allocator will finalize their findings in a report and issue it to the allocation committee. The committee and parties can then review and recommend changes, before finalizing the findings and issuing the final report. Objections may arise from the ability to pay determinations, parent and successor issues, or the toxicity and volume of materials involved. Once all the parties agree with the allocator’s findings, they can engage with the EPA to negotiate the final settlement amount.

EEC Environmental’s Compliance and CERCLA Cost Allocation Services

EEC Environmental’s services can help parties to navigate the CERCLA cost allocation process. For both public and private entities, EEC Environmental’s engineers, litigators, and technical resources can assist in every step of the process.

To find an acceptable outcome and for a better understanding of the CERCLA cost allocation process, contact one of EEC Environmental’s regional offices today.

environmental pollution

What Can the COVID-19 Virus Tell Us About Environmental Pollution?

The spread of the novel coronavirus disease, COVID-19, around the world wreaks havoc on economies and populations. However, with a reduction of human activity around the globe, one area that’s benefitting from the new normal is the environment.

With most of the world’s populations facing extended lockdowns and governments enforcing social-distancing guidelines, the natural environment is thriving. Social media posts about wildlife roaming around city centers show that our effect on the environment remains concerning.

Profound and Lasting Effects of the COVID-19 Pandemic

Researchers around the world agree that the COVID-19 pandemic will have lasting effects on human industry. While many people view the virus as an invisible enemy, responses from national governments are equal to wartime controls and mandates on populations. While there have been positive environmental impacts from the coronavirus response, researchers warn that the benefits shouldn’t be overestimated.

The Costs of the COVID-19 Response

As the world grapples with the COVID-19 pandemic, there have been visible positive impacts on the environment. Although media outlets report improvements in air quality and reductions in greenhouse gas emissions, the effects are only temporary according to researchers. At the same time, studies indicate that secondary pollutants like ground-level ozone have increased in some regions.

Nitrogen dioxide have decreased in the US, China, and Western Europe by as much as 60% during the pandemic. According to atmospheric scientists, these levels are unprecedented since they started monitoring air quality using satellites in the 1990s. While most of the environment is healing during the pandemic, researchers did find one concerning increase in pollution.

Surface Ozone Pollution at Ground-Level

One pollutant that has increased according to studies was surface-level ozone. This happens when there’s a drop in nitrogen dioxide pollution in major industrial centers around the world. Surface-level ozone is a secondary pollutant that forms when sunlight and high temperatures catalyze and create chemical reactions in the lower atmosphere.

Although researchers found an increase in these pollutants around the world, the decrease in nitrogen dioxide over major population centers remains promising. Considering this unintended experiment’s data can help researchers to develop strategies and methods that can improve atmospheric conditions in the future.

EEC Environmental and Pollution Control in the Future

Once the pandemic subsides and the world returns to normal, there will still be environments that require remediation and pollution control. EEC Environmental has a team of experts that can help public and private entities to understand the scope of these problems and develop innovative solutions to remediate environments.

The industrial revolution led to large-scale changes in our environment. What the COVID-19 pandemic shows is that taking any effort to reduce environmental pollution and remaining committed to the environment’s wellbeing remains a noble pursuit.

To find out how EEC Environmental can help your organization remediate a site or if you need to design a pollution prevention program, reach out to one of our experts today.

Assessment of Stormwater Runoff, MS4

2018 Industrial Storm Water General Permit Amendment

The California statewide National Pollutant Discharge Elimination System (NPDES) Industrial Storm Water General Permit regulates the discharge of water associated with industrial activity.  On November 6, 2018 the State Water Board amended the General Permit to new requirements. These additional requirements become effective on July 1, 2020.

The amendments include:

  • Sufficiently Sensitive Test Methods – requiring a site pollutant source assessment for applicable Total Maximum Daily Loads (TMDL)
  • TMDL Implementation – including requirements for facility operators to collect industrial storm water samples for pollutant analysis and assessed for compliance
  • Additional State options incentivizing on-site or regional storm water capture and use

EEC Environmental specializes in the analysis, evaluation, communication and remediation of storm water runoff. 

In light of these amendments, EEC is available for related services including:

  • Conducting a site pollutant source assessment for applicable TMDLs.
  • Reviewing previous sample results to determine if the current BMPs implemented are adequate for meeting the TMDLs
  • Recommending additional BMPs both general and advanced that can help to meet the TMDL
  • Assist in responding to any enforcement actions taken by the Regional Water Quality Control Board.

The complete Amendment Fact Sheet is available as a download here. 

Contact EEC Environmental for storm water site support.

Environmental Technical Assistance Opportunity

Three Maryland food processing facilities to receive free assistance

The Maryland Department of the Environment has contracted with EEC Environmental to provide environmental opportunity assessments and technical assistance to three food or beverage manufacturing/processing facilities in Maryland.  EEC Environmental, a nationally recognized environmental consulting firm, will work directly with three selected facilities to identify opportunities and solutions for improving energy and water use efficiency, reducing chemical usage, hazardous and non-hazardous waste reduction, wastewater reduction and process optimization.  The purpose of these visits is not to advise on environmental compliance issues, but rather to identify voluntary actions that will reduce environmental impacts and reduce costs for the facility.

The participating organizations will be asked to provide facility access and information

to the EEC Environmental consultants and in exchange will receive the following services free of charge: 

  • A facility-wide audit to identify opportunities that increase the efficiency of resource use, reduce waste and related environmental impacts and save money.
  • A written report identifying opportunities related to energy efficiency, water conservation, waste reduction, recycling, composting, procurement, transportation, and cleaning.
  • Assistance in prioritizing these opportunities based on return-on-investment, payback period, environmental impact, feasibility, and owner/management priorities, and an outline of next steps for implementation.

Interested companies should contact the following individuals as soon as possible, but no later than June 1, 2020 in order to take advantage of this valuable program.


Tina Bickerstaff, EEC Environmental

Laura Armstrong, Maryland Department of the Environment

EEC Presented at the 22nd Annual CUPA Conference February 3-6, 2020

EEC presented at the 22nd Annual California Unified Program Annual Training Conference (CUPA) February 3-6, 2020 in Burlingame, California. EEC’s Emily Vavricka presented on the emerging contaminant PFAS, focusing on PFAS sampling procedures, analytical methods, and current regulatory updates.

The California CUPA Forum is a non-profit 501(c)(6) statewide association that works with the Office of the State Fire Marshal, the California Office of Emergency Services, the Department of Toxic Substances Control, the State Water Resources Control Board and Cal EPA to update and continuously improve the Unified Program for the agencies, businesses and the communities that are served. For the past 21 years, the California CUPA Forum Board has invited both government entities and industries to attend and receive the same training at the annual training conference.

EEC is a nationally recognized leader in the field of soil, soil vapor, and groundwater assessment, remediation, due diligence, and compliance through “Out of the Box” unique technical solutions blended with industry proven strategies.

For more information on the 22nd Annual California CUPA Training Conference, please click here.

EEC exhibited at the 28th Annual Environmental Law Conference at Yosemite, CA to Feature PFAS

EEC Environmental (EEC) exhibited at the 28th Annual Environmental Law Conference at Yosemite at the Tenaya Lodge at Yosemite, October 17-20, 2019.

The Environmental Law Conference at Yosemite® is nationally recognized as the largest and most prestigious gathering in California of leaders in environmental, land use, and natural resources law.

EEC featured our expertise in tackling Per- and polyfluoroalkyl substances (PFAS) which pose a serious human health risk leading to stringent action levels in California and throughout the US. 

EEC provides a broad spectrum of litigation support ranging from scientific investigations to expert testimony in state and federal courts. EEC’s ability to provide a reliable scientific basis for overcoming or minimizing contentious issues includes experience in matters related to contamination of soil, soil vapor, and groundwater; geologic and hydrogeological issues; industrial wastewater; historical document research and PRP Identification; CERCLA cost allocation; and insurance cost recovery.

Click the following link at https://calawyers.org/section/environmental-law/yosemite/ for more information.

Tina Bickerstaff joins EEC to head up east coast operations

EEC Environmental is pleased to welcome Ms. Tina Bickerstaff, CPG, PG to its Mid-Atlantic Team of environmental professionals. Tina joins EEC with more than 29 years of professional experience as its East Coast Regional Branch Manager. She is a Certified Professional Geologist (CPG) with national and state registrations and has held responsibility for the coordination, management and completion of all aspects of site investigations, remediation, environmental compliance programs, and regulatory negotiations. Tina is a Subject Matter Expert for due diligence Environmental Site Assessments (ESAs), RCRA Corrective Action, and has extensive experience in coastal plain, karst, and bedrock geology.

As a Sr. Managing Geologist at EEC, Tina will draw upon her extensive experience in leading multi-disciplinary project teams at complex, dynamic industrial and commercial properties to provide high quality solutions to EEC’s valued clients.

Latest News: California Sets the Lowest Notification Levels for PFAS in the Country

The California State Water Resources Control Board, Division of Drinking Water (DDW), has accepted the Office of Environmental Health Hazard Assessment’s (OEHHA) recent recommendation on new lower Notification Levels (NLs) for PFOA and for PFOS. On August 23, 2019, the DDW announced it established notification levels for PFOS and PFOA at 6.5 parts per trillion for PFOS and 5.1 parts per trillion for PFOA. These new levels are set at the lowest levels at which they can be reliably detected in drinking water using currently available analytical detection methods.

More information can be found here.

Joseph Jenkins of EEC Presented for WEF on the Implementation of FOG Control Programs May 30

EEC presented in a webcast hosted by the Water Environment Federation (WEF).  EEC’s Joseph Jenkins shared his expertise about the proper implementation of plumbing code requirements to prevent blockage of fats, oils, and grease (FOG) that can be accumulated in sewer lines. The abstract for the presentation can be found here.

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Industrial General Permitting

Most new construction, development and upgrade projects require some sort of industrial general permitting assessment.  Sometimes abbreviated as IGP, this permit puts regulations in place for how stormwater is discharged from industrial sites.

Facilities Subject to Regulations

Not all facilities are subject to regulations regarding stormwater discharge, or need an industrial general permit. However, some of the types of facilities that are usually subject to these regulations include:

  • Hazardous waste management
  • Landfills
  • Manufacturing
  • Mining
  • Recycling
  • Sewage or wastewater treatment
  • Transportation

This is by no means an exhaustive list. The IGP may differ as you move across state lines as some states prioritize natural resource management more than others. The facility’s Standard Industrial Code (SIC) determines if coverage is required.  If your facility has no outside exposure of the potential pollutants, then your facility can obtain non-exposure certification (NEC).

What Happens if Your Business or Project is Out of Compliance?

It is the responsibility of local government agencies to identify and report any facilities that are out of compliance. However, older establishments are more likely to be out of compliance than new organizations.  This is because many government agencies now check business license applications to see if you will need an industrial general permit, and will usually inform you at that time. If you are found out of compliance, you may be significantly fined or have the project put on “hold”.

How to Verify if Your Facility is in Compliance

The process of verifying your organization’s compliance status varies from state to state, or even across city and county lines. As a result, it is important to have professional consultants on your team, like the environment compliance experts at EEC Environmental.  We are experienced in all environmental compliance and permitting applications, and assist our clients in navigating complex industrial permitting laws.

Should we find that you are out of compliance, we will also assist you with getting your permit in place, whether it requires a new application or a renewal.  For more information on how we can assist you, contact our corporate office at (714) 667-2300 or send us a detailed message via the contact form on our website.  Industrial general permits can be daunting, let EEC Environmental help you navigate.

soil and groundwater

What Is Bioremediation?

What Does Bioremediation Technology Entail?

Bioremediation is the method of cleaning up groundwater, soil, and subsurface contaminations using biological organisms. Bioremediation specialists treat pollutants, such as oil, pesticides, solvents and various petroleum products, through mimicking and stimulating nature’s biodegradation processes.

In nature, microbes such as yeast, bacteria and fungi feed on contaminants and release water, CO2, ethene and other harmless gases as byproducts. Bioremediation specialists employ this organic occurrence to reduce or eliminate pollutants from different mediums in the following ways:    

  • Bioaugmentation is the method of supplementing the appropriate variety of microbes indigenous to the groundwater and soil. For the microbes to thrive and eat pollutants most effectively, certain conditions are required, such as a suitable temperature, oxygen and the addition of nutrients and amendments, e.g., vegetable oil or molasses. The treatment may be performed in situ, meaning in place, or, if conditions are not ideal, ex situ, meaning above ground. Ex situtreatment is achieved through the pumping polluted groundwater or excavation impacted soil. Once removed from the subsurface treatment would occur. Read here to learn more on the topic.
  • If there is little or no biological activity at a site, exogenous microbes can be introduced and enhanced to degrade the contamination.
  • Some microbes require oxygen in the environment to function, while others bioremediate in an anaerobic, or oxygen-free, environment.

Are There Any Side Effects?

Bioremediation uses microbes that naturally occur in groundwater and soil, harmlessly stimulating chemicals, nutrients and amendments, causing no damage to onsite personnel or the surrounding community. Samples from the treatment site are frequently tested by bioremediation specialists to maintain balance and monitor progress. After treatment, the microbes die off and leave minimal byproducts such as water and gases. In comparison with several other methods, onsite bioremediation offers a cheaper and less disruptive way to clean up a site.       

What Is the Treatment Length?

The duration for remediation is site specific. It can range from a few months to a few years, depending on the size of the contaminated site, the favorability of the host and surrounding environments, contaminant concentration, in situ or ex situ methods, and cleanup after ex situ treatment.

Why Choose EEC?

Selecting an appropriate remedial approach and action plan is crucial to clean up a site and meet regulatory closure requirements. EEC Environmental employs a combination of the latest remedial technologies and other time-tested methods. If you are looking for a bioremediation solution for soil and groundwater, contact an EEC expert today.

Soil and Groundwater Remediation System Design

As available land for construction and redevelopment in large urban environments becomes more and more scarce, the once terrifying idea of redeveloping an environmentally impacted site has now become a tremendous opportunity to make a significant return on investment. As savvy investors realize these opportunities, soil and groundwater remediation is something many developers and investors face on a daily basis. The good news is that we have entered an era when there is an ever-expanding list of options to clean these sites at greatly reduced cost and time frames than in early years of environmental industry.

Sources of Soil and Groundwater Contamination

Causes of soil and groundwater pollution are varied, and include release from landfills, industrial operations, sewage, mining, nearby sanitation systems, fuel stations, dry cleaners, and liquid waste from wastewater treatments. Groundwater may be contaminated with volatile and semi-volatile chemicals, pathogens, radioactive material, metals and organic compounds.

Soil and Groundwater Remediation Options

  • Physical treatments can include excavation of impacted soil, soil stabilization, air sparging, soil vapor extraction, dual phase extraction, and pump and treat with carbon adsorption.
  • Biological treatments comprise biosparging, bioventing, bioslurping, in situ anaerobic bio-augmentation and phytoremediation.
  • Chemical treatments, chemical precipitation, in situ chemical oxidation, ion exchange, surfactant enhanced recovery, membrane separation and oxygen and ozone gas injections.

The treatment method should be chosen based on the contaminants specific to the site and other site-specific factors. For example, pollutants such as tetrachlorethene (better known as the dry cleaning solvent PCE or PERC), trichloroethene, benzene, ethylbenzene, poly-nuclear aromatics and vinyl chloride can be remediated through enhanced or natural aerobic and/or anaerobic degradation, carbon adsorption, insitu chemical oxidation, or in situ or exsitu thermal treatment. Other like metals and pesticides are more effectively addressed by soil removal or stabilization.    

Combination of New and Old Techniques

Offering clients comprehensive site investigation, remedial feasibility expertise, and remedial design and implementation, EEC Environmental has remained on the front line of the newest remedial technologies while also utilizing time-tested techniques.

If you are faced with a situation where an environmental site assessment and/or soil and groundwater remediation for a contaminated site is necessary, or simply if you need to discuss your situation with an environmental professional, or have questions regarding any of our other services, contact us online or by telephone and an EEC team member will be happy to connect with you.

TSCA and the Pollution Prevention Act Compliance

Understanding an Environmental Site Assessment

ESA and the Pollution Prevention Act ComplianceAn ESA, short for Environmental Site Assessment, is an evaluation of a property for the purposes of identifying any existing or potential environmental issues. ESAs are ordered during the due diligence period of the sale of a property by lenders and purchasers to avoid contamination liabilities. ESAs are completed for commercial, industrial, and multi-family residential properties as well as undeveloped land. The Phase I ESA is also completed to support the “innocent landowner defense” pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The evaluation begins with a Phase I ESA and is followed by a Phase II ESA if necessary.

What Is a Phase I ESA?

The objective of the Phase I ESA is to assess the environmental condition of the property and identify recognized environmental conditions (RECs), as defined by the American Society for Testing and Materials (ASTM), in connection with the property.  The Phase I ESA comprises the following steps:

  • Site inspection for petroleum products, hazardous chemical storage areas, chemical spills, underground storage tanks, clarifiers, sumps, and pits, among other things
  • Review of federal, state and local governmental files
  • Review of historical sources including aerial photographs, topographic maps, city directories, fire insurance maps, recorded land title records, building department records, and environmental reports
  • Interviews with tenants, current and past owners, key site managers, neighbors and government officials
  • Review of public records of neighboring properties that are hazardous or contaminated as per federal and state regulations to evaluate contamination risk
  • Review of the physical setting of the property, including general geology, topography, and hydrogeology
  • A review of recorded land title records, regulatory agency records, and State Institutional Controls/Engineering Controls databases for environmental liens or activity and use limitations (AULs)
  • Review potential vapor encroachment conditions (VECs) at the property
  • Out-of-scope, optional considerations may include mold, lead, radon, asbestos, wetlands, flood zone, and seismic hazards

What Is a Phase II Environmental Site Assessment?

If RECs are identified during a Phase I ESA, a Phase II ESA may be requested. Phase II ESAs involve sampling of groundwater, soil, soil vapor, and indoor air to check for chemicals such as petroleum hydrocarbons, volatile organic compounds, metals, and other contaminants. The following tasks may be conducted during the second phase to verify the existence and concentrations of hazardous substances:

  • Surficial soil and water sampling
  • Subsurface soil, soil vapor, and groundwater sampling
  • Geophysical testing to identify buried drums and tanks
  • Sampling of indoor air to evaluate health risks to occupants
  • Installation of groundwater monitoring wells to evaluate groundwater beneath the site and neighboring properties

What Standards Should Be Followed for an Environmental Site Assessment?

Phase I ESAs must meet the most updated standards established by ASTM and the All Appropriate Inquiries Rule (AAI) under CERCLA. Phase II ESAs must comply with applicable USEPA, State, and local regulatory agency requirements. The assessments must be performed by environmental experts with professional registrations who are trained in the fields of geology, hydrogeology, environmental science, engineering, biology, and chemistry, among others.

EEC Environmental has over 20 years of experience providing consulting services to a variety of clients. If you are in search of an environmental site assessment company, need remediation help with a contaminated site or simply have questions regarding any of the assessment steps or services, contact us and one of our experts will assist you.

Stormwater Management Plans

Stormwater Management Planning Steps

Stormwater Management Plans

Stormwater management plans are required for most new commercial and residential developments, provide long-term plans for rainwater harnessing, modernization of antique water management systems and reinvigoration of communities through updated waterways and green spaces. Effective management of stormwater prevents flooding and contamination of water

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Wastewater Treatment Basics

Wastewater Treatment Basics

Wastewater TreatmentWastewater is generated after human and commercial consumption of water. The domestic use produces wastewater, also called sewage, from showers, sinks, various household cleaning appliances and flush toilets. Industrial and agriculture wastewater comes from water usage for various processes and washing and cleaning of products. Wastewater is directed to a wastewater treatment plant for removing pollutants before it can be released into

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Implementing LID and Green Infrastructure BMPs

Implementing LID and Green Infrastructure Best Management Practices

Implementing LID and Green InfrastructureStormwater runoff is a major cause of water pollution in urban areas. Whatever doesn’t get soaked into the ground and filtered back into the natural water cycle floods and carries trash, bacteria, heavy metals, and other pollutants from the urban landscape into nearby water bodies.

Higher flows as a result of heavy rains can also cause erosion and flooding in urban streams that damage habitat, property, and infrastructure. One can manage stormwater runoff by engineering Blue, Grey, and Green Infrastructure.

Stormwater Infrastructure

Green Infrastructure, or Low Impact Development (LID), uses or mimics the natural processes that result in infiltration, evaporation or use of stormwater. These processes aim to create functional and appealing site drainage that treat stormwater as a resource rather than a waste product. On a broad scale, these practices can be managed so that they maintain or restore a watershed’s hydrologic and ecological functions.

Gray Stormwater Infrastructure includes the conventional piped drainage and water treatment systems that are designed to move urban stormwater away from the built environment. This separate from Blue Infrastructure, which uses small footprint high-efficiency devices installed and retrofitted within existing collection systems.

Implementing Best Management Practices

EEC Environmental (EEC) assists industrial facilities with the identification and implementation of best management practices (BMPs) to assist in consistently meeting California’s established numeric action levels (NALs).

Industrial facilities are required to implement source control BMPs. These BMPs are intended to keep pollutants out of the stormwater and could be structural or non-structural. However, when source control BMPs are not sufficient to consistently meet the NALs, a facility may need to implement advanced BMPs, which are controls intended to remove the pollutants from the stormwater. Examples of source control BMPs and advanced BMPs include:

  • Good Housekeeping (i.e., sweeping, preventing material tracking)
  • Preventative Maintenance
  • Spill and Leak Prevention and Response
  • Material Handling and Waste Management
  • Erosion and Sediment Controls
  • Employee Training
  • Quality Assurance Record Keeping

Advanced BMPs include:

  • Exposure Minimization (i.e., shelters, preventing contact with materials)
  • Containment and Discharge Reduction (i.e., infiltration, reuse, diversion, LID BMPs)
  • Treatment Control BMPs (i.e., mechanical, chemical, biologic, or other treatment technology)

For more information about stormwater infrastructure and best management practices contact EEC by clicking the following link here.

Wastewater Treatment Compliance

Wastewater Treatment Compliance and Meeting Regulatory Requirements

Wastewater Treatment ComplianceThe treatment of wastewater is essential to ensuring public health and clean water. The process involves converting the wastewater into an effluent, or an outflowing of water to a receiving body of water, which can be directly reused or returned to the water cycle with minimal impact on the environment. However, before treated wastewater can be discharged to the water cycle, it must comply with local, state, and federal regulations. So, how can wastewater treatment facilities and entities that produce wastewater remain compliant with these regulations?

Federal State and Local Regulations

The Clean Water Act (CWA) prohibits the discharging of pollutants from a point source into a water of the United States unless they have a National Pollutant Discharge Elimination System (NPDES) permit. The permit provides control for technology-based and water quality-based limits.

The national pretreatment program, a component of the NPDES program, is a cooperative effort of the federal, state, and local levels of environmental regulatory agencies that have been established to protect water quality. Local municipalities can then perform permitting, administrative, and enforcement tasks for discharges into the municipalities’ publicly owned treatment works (POTWs).

Wastewater Treatment Compliance

EEC Environmental (EEC) conducts local limits evaluations, develops industrial pretreatment ordinances and enforcement response plans, and assists in industrial user permitting. EEC also designs and builds wastewater pretreatment systems and performs pretreatment system evaluations for flows up to 2.5 millions of gallons per day (MGD).

Our team has unique expertise in developing technically based local limits and ensuring that industrial users have reasonable discharge permits. EEC has also created and conducts an operator training program for industrial wastewater dischargers and assists industries in achieving compliance with their wastewater discharge requirements.

EEC has developed a strong national reputation for helping public agencies, private industries, and commercial businesses come into complete compliance with their environmental regulations. We have experience negotiating favorable permit conditions for our clients resulting in reasonable regulations and millions of dollars in savings.

Industrial laundry washing machines in dry cleaner's workshop, PERC

Reducing PERC Contamination in Laundry and Dry Cleaning

Industrial laundry washing machines in dry cleaner's workshop, PERC ContaminationPerchloroethylene or Tetrachloroethene (PCE, PERC) has been used as an effective dry cleaning solvent in dry cleaning facilities for a number of years. Today, it is the most commonly used solvent. However, PERC can pose health hazards if exposure is not adequately controlled. So, how can one reduce PERC contamination and workplace exposure in dry cleaning and industrial laundry facilities?

Sources of PERC Contamination and Exposure

Employees in dry cleaners can be exposed to PERC while performing routine maintenance on machines and conducting various tasks such as removing clothes (especially thick items) before the drying cycle is finished or transferring solvent-laden garments into the dryer.  Working around uncontrolled “fugitive emissions” from dry cleaning machines can also expose workers to high levels of PERC.

Reducing PERC Contamination and Exposure

The United States Department of Labor’s Occupational Safety and Health Administration (OSHA) has implemented mandatory standards such as Hazard Communication (29 CFR 1910.1200); General requirements for personal protective equipment (29 CFR 1910.132); and Respiratory Protection (29 CFR 1910.134) in order to reduce PERC exposure with employees. Laundry and dry cleaning facilities also must comply with the United States Environmental Protection Agency (EPA) regulations to control the release of PERC into the environment.

Machine operation and maintenance, building design and ventilation, work practices, as well as PERC storage and disposal are ways in which these facilities comply with these regulations. Air monitoring for PERC release, recordkeeping, and PERC use reporting are also critical when reducing contamination.

Environmental Solutions for Dry Cleaners, PERC Contamination

EEC Environmental (EEC) has significant experience with the evaluation of industrial laundry facilities that have been impacted by petroleum, chlorinated solvents, and other contaminants. EEC performs a wide range of activities for the laundry industry, including Phase I Environmental Site Assessments‎ (ESAs), compliance services, Phase II subsurface investigations, insurance cost-recovery, remedial services, regulatory negotiations, and litigation support. EEC provides a broad base of general compliance services to the industrial laundry industry, including regulatory compliance, permitting, emergency business plans, emergency response, safety, Underground Storage Tanks (USTs) compliance, and state-specific compliance such as compliance with California’s SB989.

EEC prides itself on working with landowners, managers, and individual dry cleaner owners to evaluate potential contamination and provide remedies, when necessary, in a manner that allows business to continue uninterrupted so that both the landowner and dry cleaner owner do not lose essential revenue. When dealing with an operating dry cleaner, decisions cannot always be driven by environmental factors alone.

EEC’s overall project goal in supporting the dry cleaning industry is about smart, common sense decisions that meet regulatory requirements that are manageable for the client.

Contact EEC for more information.

Regulatory Closure, Compliance & Negotiation for Litigation, EPA

EPA Compliance Requirements for Real Estate Construction and Property Development

Environmental and land use regulations can, frequently, become overwhelming. Understanding and complying with these regulations take away from time-sensitive projects, and unwanted fines ranging into the tens of millions of dollars for larger commercial or retail property can be more than daunting. So what are some of the United States Environmental Protection Agency (EPA) compliance requirements for real estate construction and property development?

Clean Water Act (CWA) Permit Coverage
Regulatory Closure, Compliance & Negotiation for Litigation, EPA, Construction

If your real estate construction activity disturbs one or more acres of land, you may have to obtain Clean Water Act (CWA) permit coverage for discharge of stormwater runoff from your construction site. The EPA National Pollutant Discharge Elimination System (NPDES) program or the state NPDES permitting authority issues general permits for stormwater. However, to obtain permit coverage, you will need to submit a Notice of Intent (NOI) or permit application to develop and implement a Storm Water Pollution Prevention Plan (SWPPP) and provide a Notice of Termination (NOT), if required by your permitting authority.

Resource Conservation and Recovery Act (RCRA)

If your site or project generates or handles hazardous wastes, such as lead-based paint (LBP); fluorescent lamps that contain mercury; and construction/demolition (C&D) wastes, such as wood, roof material, insulation, plaster, or sheet rock, then you may have to check their allowed concentrations are in the regulations that implement the Resource Conservation and Recovery Act (RCRA).

Assistance Meeting EPA Compliance

Industrial Wastewater – CERCLA Allocation ProjectThere are a number of other laws and regulations under the construction sector (NAICS 23) of the EPA. However, there’s help to meet the requirements. EEC Environmental (EEC) has assisted real estate and property developers throughout the United States on all aspects of environmental-related issues. Our professionals understand the nuances of this business sector, including the need for rapid response, quick turnaround, and discretion that must be maintained throughout the process. EEC’s services are utilized at the earliest stages of the real estate transaction and development process, often even before the due diligence phase, when we do a “Phase 0” to quickly determine if there will likely be significant environmental issues.

We have extensive experience in large portfolio and specialized due diligence necessary for property transactions, evaluation of costs associated with environmental liabilities, evaluation of fast-track remediation alternatives, evaluation of risk-based remedial strategies, and installation of preventive mitigation equipment such as those to prevent vapor intrusion. Further, EEC assists our clients in determining if the utility infrastructure (electrical, sewer, stormwater) and permitting abilities are sufficient for the intended property use, developing and implementing SWPPPs, and conducting facility audits.

Our construction personnel has diverse backgrounds, which include mechanical, electrical, plumbing, and structural concrete experience. All construction staff works under the direct supervision of a construction manager with more than 20 years of experience and are 40-hour Hazardous Waste Operations, and Emergency Response (HAZWOPER) trained to work at contaminated sites.

Contact EEC for more information.

What Is GIS And How Is It Used?


Hundreds of thousands of organizations are using GIS to solve problems. But what is GIS, and how is it being used?

GIS, or Geographic Information Systems, is a technological field that incorporates geographical features with tabular data for one to map, analyze, and assess real-world problems. According to Esri, the company that builds and manages ArcGIS, “a geographic information system (GIS) is a computer-based tool for mapping and analyzing things that exist and events that happen on earth.” However, GIS is more than just a generated computer system and, in many ways, GIS can change the way we view the world.

Geographic information systems operate on various levels.  On the most basic level, geographic information systems technology is used as computer cartography or straightforward mapping. The real power of GIS is through using spatial and statistical methods to analyze attribute and geographic information giving one a deeper understanding of the layers of collective data.

GIS works as a tool to help frame an organizational problem. The tool can help organizations make various analysis with acquired data, and to share results that can be tailored to different audiences through maps, reports, charts, and tables and delivered in printed or digital format. Geographic information systems allow organizations of all sizes and in almost every industry to better visualize, question, study, interpret and understand the relationships, patterns, and trends in their data.

GIS Integration

Geographic Information System (GIS) and Data ManagementEEC Environmental’s (EEC) technology professionals assist in all phases of new application development and adoption of GIS design and asset management software implementation. We match the appropriate technology to our clients’ business needs and deploy these solutions to ensure that they remain sustainably effective.

EEC retains business partnerships with companies like Esri, Cityworks (CMMS), and Amazon Web Services which gives us access to the latest in GIS and information technology software, infrastructure, and best practices. EEC’s engineers utilize computer-aided design (CAD) software for drafting and updating As-Built plans, and database technologies to support and manage a variety of projects across all divisions of the company.

The technology services team at EEC can provide the tools to meet their mission whether they have a small-scale project or need enterprise implementation. Our team of expert consultants will help our clients establish their organization’s vision for their GIS and craft a pragmatic, budget-conscious, step-by-step approach to getting the most out of all software investments.

Contact EEC for more information.

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