Is the Earth Around Millennium Tower Sinking 1

Is the Earth Around Millennium Tower Sinking?

Is the earth around the Millennium Tower sinking? Built in 2008, the Millennium Tower in San Francisco has reportedly sunken about 17 inches into the ground surface. This subsidence is a consequence of an improper geotechnical engineering design, and potential changes the hydro-geological setting. Moreover, surveyors indicate the structure is tilting, with a difference of approximately 3 inches from side to side. At the moment, the local building and safety department states the structure is safe for continuous living. However, the rate of subsidence isn’t likely to change or stop anytime soon. Thus, expert geotechnical engineers are handling this corrective action project, and believe the foundation can be salvaged with final solution. At this time, cost estimations for this mitigation effort range between $300,000,000 and $500,000,000. Updated December 25, 2018.

Is the Earth Around Millennium Tower Sinking?

Is the Earth Around Millennium Tower Sinking?

The Solution to the Millennium Tower Sinking

After years of testing, analysis and surveying, geologists and engineers are now proposing an updated mitigation plan. This corrective action proposal comprises a series of retrofit piles which aim to counterbalance the sinking foundation. As a result, the geologists and drillers plan to supersede the depths of the bay area mud underlying the building, and securely tap the new piles into the underlying bedrock. Ultimately, these devices intend to stabilize the downward sinking side of the existing high rise structure. Whereas the opposite end would temporarily continue to sink. And theoretically, the tilting building should reach an equilibrium, and straighten itself within equal or lesser time.

According to an article, the executive partners at O’Melveny & Myers (Millennium Tower resident legal representation) state the geotechnical engineers are confident the latest corrective action plan will stabilize the building overtime.

Demonstration cross-section of micro pile system to uplift sinking Millennium Tower

Micro Pile (Photo Cred: Vision Winter / O’Melveny & Myers +

The Geology of San Francisco

The geology of the San Francisco bay area is complex. Much like other areas, this introduces an abundance of complications and liabilities with land development projects. Bay mud is a common sedimentary deposit comprising of sand, silt and clay. Generally, these sediments contain shallow static groundwater levels, which also keep the soil in a consistent state of saturation. As a result, bay muds have a high porosity (retaining water) and low permeability (movement of water within). Furthermore, bay muds have high compression factors and low shear strength, making it hazardous for structural development. Especially within the seismically active and fault ridden area of San Francisco, California.

Subsidence and liquefaction are the typical geological hazards in association with bay mud. And static groundwater levels fluctuate as a result of precipitation, periods of drought, water pumping and de-watering activities at nearby construction sites. Consequently, the soil-characteristics of the bay mud are subject to change, when soil zones go from wet to dry. For instance, subsidence can occur when groundwater levels decline. On the other hand, liquefaction can occur when groundwater levels rise.

Bedrock underlying the Millennium Tower is approximately 200 feet below ground surface. The corrective action proposal entails drilling and installing a series of piles into the bedrock underlying the bay mud. Moreover, these piles are likely to base another 100 to 150 feet within the bedrock it’self. As a result, drilling requirements may require approximately 350 feet of total depth at each pile location.

The Importance of a Proper Geological Assessment

The earth around the Millennium Tower sinking, is a subject which truly highlights the importance of a proper geological assessment. Cutting costs on any geological engineering service, can backfire greatly.

Geology for Rock Climbers 4

Geology for Rock Climbers

Geology for rock climbers, tends to be a science of newfound interest. A field of study, which apparently, wasn’t the most popular among millenials during their formative years. Although to be honest, most people do remember Earth Science class in high school for its tranquilizing effect. But fast forward 10- to 20- years, and suddenly the booming sport has people everywhere enthusiastic about geology for rock climbers. One can reasonably presume this curiosity stems from a climber’s motive to enhance their performance. And of course, there is the obvious common denominator (rock formations). 

With a wide variety of rock types out there, perhaps climbers aim to heighten their abilities in bouldering, top roping and sport-climbing with rock knowledge. On the other hand, perhaps a natural curiosity is born from the rush of problem-solving and triumphing something greater than mankind itself. Something that is a natural part of this 4.6 billion year old planet. And something that might also be here long after humans as well. 

“Geology for Rock Climbers” is an informative article by a Professional Geologist & 3rd-year rock climbing hobbyist – December 24, 2018.

Geology for Rock Climbers

The Geo Forward Guide: Geology for Rock Climbers ©Bhairav


This is an article about Geology for Rock Climbers. Rock climbing is a dangerous sport, which can result in serious bodily injury or death. This article solely intends to provide insight on the subject of geology for rock climbers. This article is not a guidance on how to rock climb, nor does it intend to advise or motivate any person to rock climb. The author of this geology article recommends proper rock climbing lessons by a certified instructor, prior to any attempt to climb.

Additionally, readers of this article are not advised to rely on the information herein as a health and safety guidance. The author and administrator of this article do not, and cannot guarantee any safety measures in rock climbing. This article implies absolutely no liability, warranty, guarantee or representation for health and safety. And no action or claim may be brought against the author or administrator of this scientific article, at anytime.

Geologists & Rock Climbers 

A seemingly timeless joke in the scientific community (and at most universities), is that “geologists are not real scientists…” They are often referred as the “more-athletic” or “jock-like” members of the scientific community. Sadly, this is far from the truth (most of the time). Because physicists, mathematicians and chemists practically lock themselves indoors when studying, they perceive their geological allies to be professional rock climbers or mountaineers or sorts. Or adventurers who just happen to kinestheitcly research via rock climbing. And although these preconceived notions are typically incorrect, most geologists are flattered to be mistaken as rock climbers.

One things for sure, the TV show “American Dad” hit the satirical nail with the hammer in this bit:

In a Nut Shell

Nonetheless, the reality is that geology does require an enormous amount of reading, mathematics, physics, chemistry, engineering and even biological background (paleontology). Years of studying, research, training, fieldwork and examination are only part of a professional geology career. In fact, a wise professor of geology at the California State Polytechnic University in Pomona once summed it up nicely: “geology differs from most other disciplines of science and engineering, in that geologists study a little about a lot, whereas others study a lot about a little.” Of course, this does not discredit other fields of study at all. But rather explains the general nature of studying geology, for rock climbers.

The point here is, there is a recognizable union of interests between geologists and rock climbers. And both groups can benefit greatly by sharing basic knowledge and experiences with each other. Thus, the purpose of this article is to share some basic information on geology for rock climbers.

Starting with the Geologic Time Scale

Geology for Rock Climbers 101: Rock climbers aspiring to understand geology, should begin with the geologic time scale. It’s not likely one will need to memorize (or even use) the time scale for rock climbing. However, this system is one of the foundational elements of earth science, and can bring context to geology for rock climbers. Scientists use it to correlate earth events with geologic formations, and specific time frames of the planet’s history. These geologic time frames are called eons, and are broken down into eras, periods, epochs and ages. In fact, a new geologic age has been added to the timescale for the current time frame, and it is called the Meghalayan Age. Furthermore, the geologic time scale has a chronological structure, beginning approximately 4.6 billion years ago.

As of now, scientists believe the earth is roughly 4.6 billion years old. The lower Precambrian represents the beginning of earth. This time scale system is overseen by the International Commission on Stratigraphy.

Geological Nomenclature

Nomenclature, in the subject of geology for rock climbers, can seem like a different language. Frankly, entry level geology students view it the same. However, it’s important to understand that age strongly applies when classifying the very same rocks that climbers want to conquer. For example, a Miocene sandstone is a sedimentary rock with a depositional date ranging from 7 to 23 million years ago. The rock’s age and  environmental affects from weathering and erosion over time, plays an important role in rock climber interest.

Scientists quantify smaller time frames within each geologic age group by using the pretense terms “upper” and “lower.” For instance, a lower Miocene sandstone would have a depositional time frame from about 15 to 23 million years ago. Whereas an upper Miocene sandstone would have a depositional time frame from about 7 to 15 million years ago.

How & Why Rock Age Matters

Geologists determine the age of rocks using a few scientific techniques. Understanding these methods might not directly benefit a rock climber. However, a brief overview doesn’t hurt, and might even bring some clarity to the subject. Radiometric rate age dating includes carbon-dating methods, and more. Biological rate dating includes analyzing amino acids within bio matter in soil. Evolutionary methods include the study of the fossils inside the rocks, and comparing their known time of existence. Last but not least, geologists implement various laws, such as the law of superposition and the law of cross-cutting relationships, to estimate rock ages and relationships.

Some interesting and trivial info on the geologic time scale:

Types of Rocks & Climbing Characteristics

There are three primary categories of rocks on earth:

Sedimentary Rocks

Sedimentary rocks are one of three geologic rock classifications discussed in the article. Many popular rock climbing sites are composed of sedimentary rocks. For instance, the sandstones and siltstones of the popular bouldering site, Stoney Point Park in Chatsworth, California, are sedimentary formations. And sedimentary rocks are a result of one or two processes: 1) the gradual consolidation of other loose particles, which form “Clastic Rocks,” and 2) precipitation from solutions forming “Chemical Rocks.” Depositional environments can be marine or land based. And typical sedimentary rock climbing sites, are the types which form by the deposition of various earth materials.

Shale, sandstone and limestone are the three most abundant types of sedimentary rock. Together, they form approximately 95% of the sedimentary rocks in the earth crust. Shale it’self, comprises approximately 65% of all sediments on earth. Whereas sandstone and limestone are about 25% and 10%, respectively.

Clastic Sedimentary

Sedimentary deposits typically contain fragments of igneous rocks, metamorphic rocks, other sedimentary rocks and various standalone minerals. Continental sedimentary deposits are normally a result of winds, landslides, mud flows, glaciers, and more. Marine sedimentary deposits are usually a result of oceanic water flow.  Consequently, these formations usually (but not always) include bedding and layering patterns, as well as fossils. For instance, some rock climbing sites in California include the Modelo Formation, a shallow marine siltstone and sandstone. These are 15 million year old layered oceanic sediments, which have since been subject to uplift and overturn, and contain marine fossils.

Clastic rocks are classified according to particle size, sorting, distribution and chemical content. And the size of these particles determine the rock name. For example, silt-sized grains form siltstone. Whereas clay-sized grains form a clay-stone, also known as shale. Moreover, sand-sized grains among mostly silt grains, form a sandy-silt. And the list goes on. Equally important, sorting and particle distribution provide evidence of the rock’s depositional environment. For example, most desert dune sands and beach sands have well sorting. Whereas sands from turbid current deposits generally have poor sorting.

Geology for Rock Climbers - Sedimentary Rock

Geology for Rock Climbers – Sedimentary Rock

Chemical Sedimentary

Chemical sedimentary rocks classify according to chemical composition, deposition, texture and environment. Common examples are limestone, dolomite, coal, and more. Limestone is another marine sediment, which tends to be friable and weak compared to shale, siltstone and sandstone. Consequently, it doesn’t make for a good rock climbing formation. Rock climbing handholds easily weather away, and anchor bolts aren’t likely to bear a proper load. On the other hand, limestone does have a calcium carbonate composition, just like rock climbing chalk. In fact, natural chalk is a fine grained type of calcium carbonate, and can be used for the same purpose.

Furthermore, limestone formations are known for their juxtaposition to shale and sandstone formations, due to a geological sequence called transgression and regression. As a result, perhaps one who studies geology for rock climbers, can benefit from the use of a natural chalk source, as well as an enjoyable shale and sandstone site nearby.

Igneous Rocks

Igneous rocks are another category, and primarily originate from lava and magma. These rocks comprise about 75% of the earth’s crust on land, and about 90% of the earth’s oceanic crust. They can be intrusive or extrusive, or as geologists put it: plutonic or volcanic. Classification of igneous rocks are based on the mineral content and chemistry. For example, the plutonic igneous rock that makes up the popular rock climbing site El Capitan in Yosemite Valley, California is a granite, and is shown by the mineral content and grain size.

Generally, igneous rocks tend to be sturdy, and make for great rock climbing and bouldering sites. Furthermore, of the three categories, it might be the best rock candidate for anchor bolting. However, the types of igneous outcrop can also play a huge role in a climber’s performance. For instance, plutonic igneous rocks can have fine grain textures (phaneretic), to coarse grain textures (aphanitic). And volcanic igneous rocks can have highly fine mineral texture (micro-crystalline), to fine with some distinct crystals (porphyritic). Some volcanic rocks even have a sharply pitted texture (vesicular) formed by bubbling when cooling.

Rock Climber Geology - Igneous Rock

Rock Climber Geology – Igneous Rock

Intrusive Igneous

Intrusive igneous rocks, or plutonic igneous rocks, form below the ground surface by large pools of magma. Giant bodies of magma inside other rocks or sediments identify as batholiths. And these batholiths chill overtime to produce igneous rocks. Then-after, either the surrounding sediments erode away, or the rock gets uplifted and outcropped for rock climbers to conquer. There are various types of igneous rocks with a diversity of mineral compositions and crystal grain sizes. Consequently, the earth’s pressure and length of crystallization time play a significant role in the type of igneous rock produced. For instance, the faster the magma cools, the smaller the crystal grains tend to be. Whereas a slower crystallization time frame generally results in larger grains. Earth pressures additionally impact crystallization, as well as the mineral composition of the rock.

Extrusive Igneous

Extrusive igneous rocks, or volcanic igneous rocks, have been erupted on the surface of the earth, usually by mode of a violent ejection or explosion, or calmly by the flow lava. As a result, these igneous rocks are generally finely crystalline or glassy. Moreover, they are generally smooth and slippery, or sharp and jagged.

Although most igneous rocks will prove to be strong and reliable climbing outcrops, the various types and textures will affect safety, comfort and quality of one’s climbing experience. For example, a vesicular basalt would make for a jagged, sharp and horribly painful hand hold. Whereas a micro-crystalline basalt might be too smooth for sufficient gripping. But, a phaneretic or aphanitic granite may be a perfect combination of anchoring durability and hand hold gripping texture.

Metamorphic Rocks

Metamorphic rocks are the result of transforming versions of other sedimentary or igneous rocks (and sometimes, other metamorphic rocks). Metamorphism is the actual transformation process, and occurs as a result of pressure, friction, heat and time. Metamorphism, weathering and erosion each play a significant role in geology for rock climbers. This affects the hand hold texture, durability and the safety factor of a climbing experience. The changes to rocks can be chemical, physical or both. Metamorphic rock types are studied in three general groups: strongly foliated; weakly foliated; and nonfoliated. Foliation is the modification of rocks to be split into sheet sections.

Rock Climber Geology - Metamorphic Rock

Rock Climber Geology – Metamorphic Rock

Strong Foliation

A shale or siltstone (sedimentary rock), that undergoes low-grade regional metamorphism by pressure, will become a metamorphic rock over time, called slate. Slate typically has a strong foliation structure, and is used for flooring, roofing and billiard table materials. Similarly, slate makes for sturdy rock climbing material, as long as weathering, erosion and fracturing hasn’t affected the outcrop. On the other hand, slate does have a smooth and platey surface (foliation), which can be challenging for hand holds. Moreover, rock climbing anchor bolts aren’t likely to be reliable in slate, due to the potential fracture planes in layering sections.

Weak Foliation

Other igneous rocks that undergo high-grade regional metamorphism, may become a gneiss. Without the aftermath of weathering and errosion, gneiss can make for a sturdy and well textured rock climbing material. In terms of a rock climber interests, gneiss likely shares many of the properties of an plutonic igneous rock, such as granite. Otherwise, it can be brittle and unreliable.


A sandstone (sedimentary rock) that undergoes contact or regional metamorphism may become a nonfoliated metamorphic rock called quartzite. Quartzite is one of many nonfoliation types of metamorphic rock, and can offer a nice grippy texture and sturdy structure. Quartzite can make for a great rock climbing outcrop, as long as it is without the affects of weathering, erosion and fracturing. Furthermore, drilling into quartzite for rock climbing anchor bolts may not be the easiest task, but also isn’t possible.

Lessons in Geology for Rock Climbers

Geology for Rock Climbers ©GalynaAndrushko

Most Favorable Rocks for Climbing

Overall, geological evaluations indicate the top choice climbing rock is an intrusive (plutonic) igneous rock, with phaneritic to aphanitic features. This includes granite, diorite, pegmatite, monzonite and more. This rock type is equally favorable to boldering, as it is to sport-climbing and top roping. In fact, these igneous rocks have a higher degree of strength associated with anchor bolts. Furthermore, the rock surface textures make for nicely gripping hand holds, and are more resilient against weathering within a human lifetime (comparing to other sedimentary and metamorphic rocks).

Although less favorable than a plutonic rock, some extrusive (volcanic) igneous rocks can also be good for climbing. Despite the smoothness being a difficult hand hold concern, basalt outcrops (with non-vesicular surfaces) are frequently climbed. Moreover, other porphyritic volcanic rocks, such as rhyolite and andesite provide many (but not all) of the same benefits to rock climbers as a the plutonic igneous rock.

2nd & 3rd Most Favorable Rocks for Climbing

The next favorable rock (particularly for bouldering) is a fine to coarse grain, strongly consolidated, clastic sedimentary rock, such as a siltstone or sandstone. The sandy content of these rocks continuously provide a good gripping texture for hand holds and foot holds, even through weathering and erosion. However, these sedimentary rocks are more susceptible to structural weakening by erosion and weathering over time. As a result, there is a lesser degree of certainty and reliability with anchor bolts. Thus, it is most ideal for bouldering with the use of a crash pad. And less ideal for sport-climbing and roping.

Lastly, some favorite rock climbing sites include un-erroded and non-weathered shales (sedimentary rocks) and gneiss (metamorphic rocks). Without the compromising affects of weathering, erosion and metamorphism, these rocks can bare the proper characteristics for desired for bouldering, and potentially sport-climbing. Although, there is a lesser degree of reliability with rock climbing anchor bolts on sedimentary and metamorphic rocks, comparing to igneous rocks.

The Geology of Popular Rock Climbing Spots

The following is a list of popular climbing sites, along with a brief on the geology for rock climbers. Popular Rock Climbing Sites:

El Capitan, Yosemite National Park, California:

El Capitan is a plutonic igneous rock. In particular, it is a large granite batholith from the Cretaceous period, and is a result of glacial carving.

Red River Gorge Geological Area, Daniel Boone National Forest, Kentucky

The primary geologic formation for rock climbers in the Red River Gorge area is the Corbin Sandstone. This is a clastic sedimentary rock from the Carboniferous Period, and is a result of shallow river delta deposits. Since deposition, the formation has been uplifted and overturned.

Gibraltar Rock, Santa Barbara County, California

The rock climbing sites of Gibraltar rock are within a well consolid clastic sedimentary formation known as the Matilija Sandstone. This sandstone is extremely hard. As a result, rock climbers report that this formation is proper for top roping, with reliable anchor bolts. Moreover, the rock texture includes good hand hold grips, thus ideal for bouldering with a crash pad. The sandstone deposition occurred during the Upper Eocene Period, and is a result of other granite particles from nearby decomposing outcrops, consolidating in a shallow marine environment.

Los Angeles County Well Permit and Drilling Permit 3

Los Angeles County Well Permit and Drilling Permit

Per the Department of Public Health Drinking Water Program, a Los Angeles County Well Permit and Drilling Permit is mandatory for most environmental, geotechnical and hydro-geological projects in LA County. As of August 2018, the County of LA enforces a new set of stricter well permit guidelines. The new standards require oversight for soil sampling boreholes deeper than 10 feet. Additionally, permits are necessary for any borehole that encounters groundwater. Lastly, a C-57 Licensed Driller is mandatory for this process. There are various drilling service categories under the purview of a Los Angeles County Well Permit and Drilling Permit. And various forms of supporting documents are essential to the application process. Updated December 10, 2018.

Los Angeles County Well Permit and Drilling Permit

Los Angeles County Well Permit and Drilling Permit

Los Angeles County Exclusions

Most Phase 2 Environmental Site Assessment and remediation projects will require a Los Angeles County Well Permit and Drilling Permit. However, a Well Permit and Drilling Permit are not necessary for soil gas probe boreholes without soil sampling. Moreover, the Environmental Protection Agency exempts the requirement of a drilling permit for Superfund CERCLA sites. Although, to qualify for this exemption, there may be additional forms to provide Los Angeles County.

Some cities within Los Angeles County, such as the City of Pasadena, Long Beach, Vernon and more, have their own Health Departments which require Well Permits and Drilling Permits. In such a case, other permits may be required in addition to the Los Angeles County Well Permit and Drilling Permit.

Environmental Projects with Well Permit and Drilling Permits

Environmental Site Assessments and geological investigations within Los Angeles County boundaries are subject to a variety of permits, depending upon the nature of the sampling. Notably, for locations within the unincorporated County limits, and within certain city jurisdictions, the Department of Public Health (LADPH) requires an approved Los Angeles County Well Permit and Drilling Permit to advance soil borings and groundwater monitoring wells. Additionally, permit fees apply for each sampling event from existing groundwater monitoring wells may apply.

Typically, environmental soil borings and groundwater monitoring wells assist in researching contamination conditions and concentrations at specific locations. For example, subsurface investigations help to identify the source of an environmental release. Furthermore, deep soil borings aim to define the width and depth of a plume. Moreover, exploratory boreholes identify a site’s geology and soil characteristics. Groundwater monitoring wells are devices which aid in identifying hydro-geologic and environmental conditions, as well as the the lateral and vertical extent of aquifer contamination. Using this information, geologists can also define contamination migration pathways. Groundwater monitoring wells are also usable for remediation purposes.

Approval for Los Angeles County Well Permit & Drilling Permit

Approval for Los Angeles County Well Permit and Drilling Permit ©remg

Exploration Projects with Well Permits and Drilling Permits

Los Angeles County Well Permit and Drilling Permit is also necessary for “Exploration Hole” purposes. Typically, these boreholes explore subsurface and hydro-geological conditions at a property. For instance, any soil sampling boring, hydropunch boring and Cone Penetrometer Test (CPT) will require oversight. Furthermore, any soil sampling boreholes with depths exceeding 10 feet into the vadose zone, and any borehole or CPT encountering groundwater will require oversight by the Los Angeles County Department of Public Health (LADPH).

Prior to commencing work, consultants must submit a work plan and well permit application to the Drinking Water Program within the LADPH. The investigative work may only commence after the County’s approval of the well permit and drilling permit.

Soil Vapor Probe Investigations and LA County Permitting

The vadose zone is a area represented by dry soil, above the groundwater table. Generally, soil gas probe boreholes only (within the vadose zone) do not require an LADPH Well Permit and Drilling Permit. In fact, if a CPT or soil boring does not extend beyond 10 feet below grade, it will also be exempt from a Los Angeles County Well Permit and Drilling Permit.

However, if any probe or borings extends into a groundwater zone during installation, a permit will become necessary. Similarly, if an investigation involves the installation of a groundwater monitoring well, groundwater production well, piezometer, injection well, extraction well, sparge well, CPT boreole into groundwater, or a HydroPunch temporary well, a Los Angeles County Well Permit and Drilling Permit is mandatory. As with the soil boring permits, applicants must provide a comprehensive work plan and application to the Drinking Water Program. And the package must disclose the professional C57 contractors and geologists overseeing the job.

Methane Soil Gas Survey Probe Set

Permanent Methane Testing Probe Set

Although groundwater depths are variable in Los Angeles County, some areas have water tables shallower than 10 feet. In fact, some beach areas have reported first-encountered groundwater as shallow as 2 feet below grade. For instance, Santa Monica, Venice Beach and Long Beach area are generally known to have shallow groundwater. As as result, a well permit and drilling permit will be required, even for boreholes less than 10 feet.

Groundwater Monitoring Well to Test Groundwater for Possible Contamination during Environmental Site Assessments

Groundwater Monitoring Well to Test Groundwater for Possible Contamination during Environmental Site Assessments

Well Permit & Drilling Permit Service Categories 

Additional well service categories that require a permit from the LADPH include irrigation, production and geothermal heat exchange wells. And the Los Angeles County Well Permit and Drilling Permit application also includes services such as well decommissioning, rehabilitation and renovation of existing wells. Moreover, some procedures to service existing water supply wells are likely to require oversight. For example, yield evaluations, yield enhancement procedures, performance tests, in situ water treatment and more.

In the same way, permit approval may be required for periodic sampling of commercial food service facility water, for United States Department of Agriculture (USDA) certification.

The LADPH turnaround time for processing these permits is approximately 10 business days. The processing time commences upon receipt of the application and payment of fees. And work plan modifications or design amendments might be mandatory to achieve approval by the LADPH.

Properties undergoing soil or groundwater assessment within Los Angeles County are more than likely in need of a Well Permit and Drilling Permit, as well as a work plan prepared by a Professional Geologist. Contact Geo Forward for more information, or to determine if your project requires a Los Angeles County Well Permit and Drilling Permit.

By: Devina Lee Horvath 

Contaminated Soil Excavation & AQMD Rule 1166

Contaminated Soil Excavation & AQMD Rule 1166

AQMD Rule 1166 applies to Southern California construction sites undergoing contaminated soil excavation. To start, AQMD Rule 1166 requires a mitigation plan.  Moreover, this report is also goes by the title “Contaminated Soil Excavation Plan.” Additionally, the rule requires air quality testing during excavation. The primary oversight agency is the Air Quality Management District (also referred to as the AQMD or SCAQMD in the South Coast). Updated February 19, 2019.

Contaminated Soil Excavation and AQMD Rule 1166 ©Dmitry_Kalinovsky

Contaminated Soil Excavation and AQMD Rule 1166 ©Dmitry_Kalinovsky

Discovering Contaminated Soil Excavation Issues

Unless a Phase 1 Environmental Site Assessment or Phase 2 Subsurface Investigation calls it out, you may be surprised to find contaminated soil at a job site. It happens from time to time. As a result, there are legal requirements for disposal and monitoring. Consequently, an environmental engineering firm should be retained to achieve proper contaminated soil excavation and AQMD Rule 1166 compliance.

In the first place, the process starts with soil sampling by an environmental consultant. Next, the consultant will prepare a waste profile and manifest. At this point, the engineering firm should also complete a mitigation plan. Some mitigation plans are site-specific. Others are for various locations. Lastly, the SCAQMD will need to approve the mitigation plan, and issue a permit to dig.

Tasks that require AQMD Rule 1166 Compliance

Per the rule, compliance is necessary for each of the following activities:

  • Removal of any underground storage tank (UST) or associated product piping.
  • Contaminated soil excavation.
  • Stockpiling and movement of contaminated soil.
  • The treatment of contaminated soil at a disposal facility.

Accordingly, there is a need to monitor disturbed soil via an organic vapor analyzer (OVA). Often times a photo-ionization detector (PID) is exemplary. Other times a flame-ionization detector (FID) may be more ideal.

Costs for Contaminated Soil Excavation

Unfortunately, we are unable to provide any general cost estimates via the internet. There are just too many variables in each project. A custom price quote is a requirement for each specific project.  However, you can expect to pay for the following items for an AQMD Rule 1166 compliant contaminated soil excavation:

  • Soil sample laboratory analysis.
  • AQMD Rule 1166 permit application.
  • Mitigation Plan preparation.
  • Contaminated soil excavation air monitoring labor.
  • Permit closure process.
Finish the Job Right and Save Money

AQMD Rule 1166 compliance is a requirement for contaminated soil excavation. Although this process is costly, the fines and penalties for violating them are more. Thus, its best to consult an proper environmental engineering firm. Moreover, a Phase 1 Environmental Site Assessment at the purchase stage is the best recommendation for staying one step ahead. If contaminated soil becomes apparent during the assessment, a proper budget can be set.


Can You Retest Methane Test of Soil?   Recently updated !

Can You Retest Methane Test of Soil?

Is it worthwhile to get a retest methane test of soil: Generally Not. Sometimes a methane test will show high results of the hazardous soil-gas on a property. And developers will try a retest methane test to get “favorable results.” Regardless, there is a general legal requirement to still submit the original test data (whether it has higher or lower methane levels). This is a public health code concern governed by law, and delves into the matter of developer ethics. The rule is to submit the original report with the retest methane test report for the agency to review. And even when multiple reports indicate conflicting data; more than likely the agency will use the highest overall results. Thus, retesting in hopes of “favorable results” can be pointless and a waste of money. Updated June 19, 2019.

The City of Los Angeles Department of Building and Safety (also known as the LADBS agency) has distinguished methane zones and methane buffer zones. Additionally, the Los Angeles Fire Department (also known as the LAFD agency) has oversight. As a result, methane mitigation standards apply. And therefore, a methane test becomes necessary.  Other cities and counties also administer the same methane test policies. Cities like Huntington Beach have their own standards, while others may reference the LADBS policies and guidelines directly.

Can you retest methane test soil in oil fields?

Interest to Retest a Methane Test

Building Safety Codes base the standard on the highest overall test results. Consequently, the LADBS and LAFD typically select a Level per the highest overall result. For Example, consider a scenario with two methane test reports by different companies. The first methane test reports Level 5, and the retest methane test reports Level 4. In this case, the agency is likely to use the highest methane test, which is the Level 5.

The Legal Requirement to Report all Methane Test Data

High levels of methane soil gas become a matter of public health concern. Anyone that has discovered high levels of methane test results, is required to obey the California Health and Safety Code and report results to LADBS and LAFD. In other jurisdictions, all potential public health hazards should also be reported to the appropriate agency for proper evaluation.

Thus, the policy entails the appropriate agency receive a copy of each methane test report, including the original and retest methane test.

What will the Agencies Decide?

Only the appropriate oversight-agency has the authority to decide what methane level a property is. One cannot guarantee whether the agency decides to accept the original report or retest methane test. For instance, in the scenario above, the decision in the matter is entirely up to the City of Los Angeles.

Methane Test Results for Properties with Oil Wells

Developers must acknowledge that properties including (or within proximity to) oil wells typically result in high-level methane mitigation systems. Thus, it is common that a Level 5 mitigation system has an appropriate level of building safety components. Accordingly, the higher results between a methane test and a retest methane test are likely to prevail. Building an appropriate level mitigation system is not just about construction costs. Its about the health safety of those who will use the building.

For more information about the inquiry and your specific property, call (888) 930-6604 and request a free consultation today.

Additional Information & Sources: 

DTSC Reporting Nonemergency Hazardous Substance Releases

EPA Groundwater & Drinking Water

EPA Risk Assessment


U.S. EPA Guidance for CH4 Landfill Gas Sampling & Testing

City of Los Angeles, Department of Building & Safety

The CH4 Zone – The Land Developer’s Guide