2 — December 2025 — M id A tlantic Real Estate Journal
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M id A tlantic Real Estate Journal
M id A tlantic R eal E state J ournal Publisher, Conference Producer ..............Linda Christman VP, Conference Producer .............................Lea Christman Editor/Graphic Artist ......................................Karen Vachon Contributing Columnist .......................Scott Bisbort, LSRP Langan Engineering & Environmental Services Mid Atlantic R eal E state J ournal ~ Published Monthly Periodicals postage paid at Hingham, Massachusetts and additional mailing offices Postmaster send address change to: Mid Atlantic Real Estate Journal 117 HMS Halsted Dr., Hingham, MA 02043 USPS #22-358 | Vol. 37, Issue 12 Subscription rates: 1 year $99.00, 2 years $148.50, 3 years $247.50 & $4.00 single issue - plus postage
Importing and Exporting Soil Scott Bisbort, LSRP
I mporting and exporting soil are routine compo- nents of redevelopment and remediation projects. How- ever, the presence of PFAS— even at background concen- trations—has introduced new regulatory and logistical chal- lenges, as their presence can complicate soil movement, trigger compliance obligations, and limit disposal options. The presence of PFAS in soils may be due to well-known point sources, like industri- al discharges or firefighting foam, or lesser-known diffuse sources, such as atmospheric deposition, urban runoff, or long-range transport. Even if PFAS levels fall be- low regulatory limits at a proj- ect site, imported soil may still contain concentrations above the background of the receiving site. This can lead to additional testing requirements, delayed approvals, and the need for regulatory justification and documentation. Additionally, exporting soil with PFAS con-
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centrations above or below reg- ulatory standards—regardless of whether they originate from background sources—may prompt regulatory scrutiny and potential liability, required source investigations and site characterization, and complex disposal logistics. As a result, many landfills and treatment facilities are reluctant to accept materi- als containing PFAS. These facilities also consider po- tential challenges related to the persistence of PFAS and potential for groundwater contamination, costly leachate management requirements, and evolving state-level re- strictions or bans on PFAS- containing waste. The impact of PFAS on soil imports and exports cannot be
overlooked, especially as PFAS regulations continue to evolve. Recommended best practices for managing PFAS in soil movement include: • Conducting a compre - hensive review to determine if PFAS is a contaminant of concern at the import site prior to importing any material. • Conducting PFAS testing, including leachability assess- ments. • Reviewing available docu - mentation and information for any export site to support the absence of PFAS. • Reviewing state-specific regulations and landfill ac- ceptance criteria. • Documenting all transport and disposal activities to con- firm regulatory compliance. continued on page 4A
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