Donald Barfield (Don) joins SCS Engineers as a Project Director specializing in environmental assessment and brownfield remediation, the first step in returning damaged sites and property to productive use. Barfield brings AAI expertise developed at over 2,000 assessments and brownfield projects throughout the United States and globally, keeping them on schedule and budget.
“Don’s proven track record fits our aim to create sustainable environmental solutions. Our consulting engineer teams include members with field and financial experience to create solutions that meet and remain compliant with local, state, and federal policies while economically and socially practical, states Senior Vice President and Southeast Business Director Carlo Lebron.
All Appropriate Inquiries (AAI) is a process of evaluating the environmental condition of a property and assessing the likelihood of contamination. Parties must comply with the requirements of the AAI Rule or follow the standards set forth in the ASTM E1527-13 or E1527-21 Standard Practice for Phase I Environmental Site Assessments to satisfy the statutory requirements for conducting all appropriate inquiries.
Today’s commercial property transactions take environmental issues into consideration. Complex laws can impose significant environmental liabilities on purchasers, sellers, and lenders, whether or not they caused the problem and whether or not they still own the property.
Don brings years of experience helping municipalities, developers, and industrial clients prepare and submit EPA Brownfield Assessment and Cleanup Grants, including the compliance reporting and due diligence associated with making these projects successful for communities and businesses. His project experience includes due diligence and risk reviews for large acquisitions or mergers and the assessment and development of closure plans for RCRA Regulated Units.
“Sustainability and environmental compliance are important factors in moving projects forward while protecting communities,” says Don. “There are funding, grants, tax credits, and incentives available now. In Florida, the Voluntary Cleanup Tax Credit Program could support mixed-use developments and potential partnerships right now.”
Barfield is an LEED® Accredited Professional, HAZWOPER Certified, and an ASTM Environmental Professional. He earned his MBA at the University of North Florida and a BS in Biology at Jacksonville University.
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver essential services and products. For more information about joining us, please visit the SCS Engineers website, or watch our video to see what we can do for your business and community.
I’ve always felt good about my work as an environmental geologist, but nothing has moved me as much as attending the CHW Dreambuilders event last week. I’ve worked on affordable housing projects in the past and have been involved in environmental assessment and developing and implementing plans for cleaning up contamination to prepare a property for redevelopment. But I had never before been able to hear from the people whom these projects benefit. The Dreambuilders Gala, held at Humphreys By The Bay, was a night of smiles and tears of joy, where we were able to hear the stories of struggling families who were provided with homes; children who were able to have a safe place to sleep and play; a teenage girl who had her own room for the first time. The story that affected me the most was about Tony, a grandfather who had struggled with mental health issues and now has a home where his grandchildren can visit him. He was positive and joyful as he spoke of how his neighbors all knew his grandkids!
Community HousingWorks is a nonprofit organization that develops and operates affordable housing communities throughout California. Not only does the organization provide housing to family, seniors, and people with disabilities, they provide additional services to help residents thrive. Financial planning programs, after-school and summer study programs, and healthy living programs are offered to residents, and scholarships are available to youth and adults for postsecondary education.
SCS has been involved with many of the Community HousingWorks developments throughout San Diego County, including family housing projects such as Ulric Street Apartments and the currently under-development Cortez Hill Apartments; North Park Seniors Apartments; and Paseo Artists Village, providing housing for artists as well as a resident art gallery and studio.
I feel so proud to work for a company that is involved in this type of work; not only are we making the land healthy and safer for residents, we are contributing to changing the lives of fellow community members and generations to come!
You can help too!
Jennifer Morton is a licensed professional geologist working at SCS Engineers. Her work with environmental engineers leads to the development of remediation systems used to clean up soil and groundwater and develop site mitigation plans that help keep communities safe from contamination. And like many SCSers, she has a passion for helping others.
The FY 2023 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Grant Guidelines are now available (go to Open Solicitations). The application submission deadline is November 22, 2022.
Please see the link below for Multipurpose, Assessment, RLF, and Cleanup (MARC) Grant Application Resources: https://www.epa.gov/brownfields/multipurpose-assessment-rlf-and-cleanup-marc-grant-application-resources#Open%20Solicitations
From the official guidance:
SCS Engineers has a successful track record supporting communities interested in land recycling and obtaining EPA Brownfields grants. Please visit our website for more information.
The FY 2023 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Grant Guidelines are now available (go to Open Solicitations). The application submission deadline is November 22, 2022.
Please see the link below for Multipurpose, Assessment, RLF, and Cleanup (MARC) Grant Application Resources: https://www.epa.gov/brownfields/multipurpose-assessment-rlf-and-cleanup-marc-grant-application-resources#Open%20Solicitations
From the official guidance:
SCS Engineers has a successful track record supporting communities interested in land recycling and obtaining EPA MARC Brownfields grants. Please visit our website for more information.
On Friday, September 9, SCS attended a meeting with CCLR and the State of Arizona on Land Reuse Grants. CCLR’s Ignacio Dayrit said that the guidance for EPA’s MARC Brownfields grants is expected to be released this week, opening the 60-day application period. If you plan to speak to any communities/non-profits about grant applications, now is the time to reach out to them. EPA Brownfield grants are often a significant funding source for assessing and cleaning sites with potential environmental contamination. This year, historical funding levels from the Bipartisan Infrastructure Law (BIL) mean more grants and significantly larger awards, making it a good investment to apply.
Although this information is subject to change before the guidance is finalized, here are the anticipated funding details:
SCS Engineers has a successful track record supporting communities interested in land recycling and obtaining EPA MARC Brownfields grants. Please visit our website for more information.
Amy Guilfoyle joins SCS Engineers as a Project Director specializing in performing and managing Phase I/II environmental site assessments; contamination assessments; remedial planning and implementation; tank closures; permit applications; SPCC plans; Brownfields grants, and compliance audits.
Amy brings years of experience helping her clients prepare environmental compliance reporting and due diligence associated with land reuse, making these projects successful for communities and businesses. She feels her knowledge of Florida’s Department of Environmental Protection Standard Operating Procedures, Florida Administrative Code, Petroleum Restoration Program procedures, Low Scored Site Initiative, and legislator and compliance agency personnel help keep projects on track and support plans for more sustainable development.
Amy’s combination of leadership skills, field experience, and environmental consulting, as SCS clients know, leads to more sustainable and economically viable environmental solutions. Her fieldwork includes the installation of monitoring wells using conventional and sonic rigs; direct push technology sampling; soil, sediment, and groundwater sampling; storage tank closures; spill bucket closures; Phase I/II ESAs; site assessments; remedial actions; NPDES Permits; SPCC Plans; TIER II; stormwater compliance; Industrial Wastewater Permit compliance; safety audits, and waste management.
Guilfoyle serves on the Seminole County Port Authority Board of Directors and is the former President of the Florida Association of Environmental Professionals, Central Florida Association of Environmental Professionals, and the Metropolitan Environmental Training Alliance.
As a national employee-owned environmental engineering, consulting, and construction firm, SCS seeks professionals like Amy with a demonstrated commitment to their clients, environment, and community. Amy volunteers time to the Back to Nature Wildlife Refuge and STEM-related events that reflect her mission of making a positive difference.
Amy grew up in Bradenton, Florida. Her environmental career began with an internship at the Orange County Landfill while attending the University of Central Florida in Orlando, where she earned a Bachelor of Science in Biology. She is honored with leadership recognition from the Zweig Group’s ElevateHER Program, a National Association of Environmental Professionals President’s Service Award, and by the Orlando Business Journal as one of the Women to Watch Honorees, Women Who Mean Business Awards.
If you are interested in working with environmental leaders like Amy Guilfoyle, please visit SCS’s website to see our open positions.
The construction cranes dotting suburban and urban areas indicate many cities’ new residential, office, and commercial building developments. Mixed-use development continues rising in popularity; the pandemic accelerated a swing already in motion. But there are other factors at play here, and one may surprise you. Today, our blog discusses these two factors and how brownfield redevelopment can play a role in addressing both.
One: Sustainability
According to Architecture 2030, a non-profit, non-partisan organization established to transform the building sector away from being a major emitter of greenhouse gases, there is work to do. As with almost all industry segments, tracking and reducing their carbon footprint is considered an essential element of doing business. It’s important to Americans and shareholders.
Brownfield redevelopment presents adaptive reuse of existing buildings and properties and is a sustainable form of construction. Completing the due diligence and environmental studies associated with redevelopment shows brownfields can provide cost benefits from a development perspective and in excellent locations with existing infrastructure. The conversion of existing land or buildings, as opposed to new-build construction, is far more environmentally sustainable.
An EPA 2020 study examines and reports the environmental benefits that continue accruing when brownfield sites are redevelopment. The study finds that accomodating housing and job growth decreases the need for more roads and reduces emissions from commuting.
As population density increases, real estate prices continue to rise, and less land is available, mixed-use development is an economical choice for developers. It is also one of the best-case scenarios for end-users because it prioritizes practicality and sustainability. Many potential sites exist in desirable locations or emerging areas. They should be available below market value and may have been on the market for a long time. The development of Comm-22 is a great example of a mixed-use community. Businesses find brownfields attractive options because they are closer to their customers – good for business and the environment.
Two: Grant Programs and Offsetting Expenses
The U.S. Environmental Protection Agency has grant programs that can pay for the assessment and cleanup of brownfields, but these programs are only available to governmental and non-profit organizations. However, a private entity may be able to team with these eligible parties. The bipartisan Congressional action has delivered the single-largest investment in U.S. brownfields infrastructure. The Bipartisan Infrastructure Law invests more than $1.5 billion through EPA’s highly successful Brownfields Program.
In addition, grants are available from some state agencies and the private sector through EPA regional programs – these are most often found within the transportation sector. Your environmental engineer or consultant can help you find funding; the firms with comprehensive environmental services keep watch as substantial federal infrastructure funding trickles down to the states in 2022 and next year. Note that each grant program will have its eligibility criteria, but many of these are designated for mixed-use developments supporting
Obtaining a grant or loan with the help of a qualified environmental consultant or an environmental attorney can be the difference in acquiring, cleaning up, and redeveloping a property. The grants don’t typically cover all the costs associated with the necessary cleanups, but they can cover most of these costs.
A new property owner can obtain an environmental insurance policy to cover cleanup requirements, third-party claims for bodily injury and property damage, and associated legal expenses resulting from pollution or contamination. These insurance policies are available with various term lengths and deductible amounts to satisfy the concerns of lenders or equity investors.
Other solutions include “insurance archaeology” to find old insurance policies that may have coverage for “pollution conditions.”
Comprehensive Environmental Support Keeps Redevelopment on Track
Mixed-use development provides a healthy, safe place to work, play, and live along with job creation. The most important risk management strategy is to keep the project on schedule. Your environmental engineer and consultant have a thorough understanding of the environmental issues on the site and how those issues can impact your redevelopment plans and bottom line. It is critical to have environmental and legal support experienced in identifying, anticipating, and managing risks on brownfields.
SCS evaluates brownfields by performing a Phase I Environmental Site Assessment (ESA) first to study historic site information and previous uses. SCS will perform a Phase II study if the Phase I ESA identifies potential issues (known as Recognized Environmental Conditions). Phase II includes collecting and analyzing samples (i.e., soil, soil vapor, and groundwater) to assess whether environmental impacts are present. If enough sampling is completed, the extent of the impacts can be estimated.
SCS Engineers has a long and successful track record with brownfields projects. Our clients appreciate the security of having comprehensive and experienced professionals who lower their risk keeping projects on schedule, safely remediating in-situ that lowers greenhouse gas emissions and can provide cost savings.
With proper planning and the help of a qualified environmental consultant, the mitigation or remediation of impacts can be incorporated into the acquisition and development processes and result in a vibrant, profitable project that is protective of human health and the environment.
About the Author: Luke Montague is a Vice President of SCS Engineers and a Project Director. He is a Professional Geologist and licensed contractor with two decades of experience in environmental consulting, general contracting, commercial and residential development, and property and asset management. He has performed and reviewed hundreds of Phase I environmental site assessments (ESAs), and has completed subsurface investigations, human health risk assessments, removal action work plans, site remediation activities, geotechnical investigations, asbestos and lead-based paint surveys, and asbestos air monitoring.
With the new available housing supply critical in San Diego and across the country during the current housing crisis, affordable housing options for low-income people in need are more important than ever. Below are several examples of recent Brownfields projects that have been or are under development by affordable housing developers to benefit the critical needs of the developmentally disabled and seniors.
Mercy Housing, Villa de la Vida – Mercy Housing Corporation (MHC) redeveloped a creek-front Poway site with multiple former leaking underground storage tanks (USTs) into Villa de Vida, a home for adults with developmental disabilities. The site had been historically used as a San Diego County Department of Public Works Road Station with fueling stations operating from 1942 to 1998 and had several leaking USTs, which had impacted the soil and groundwater with gasoline. In addition, operations at former structures on the site had caused elevated lead concentrations in shallow soil from lead-based paint and asbestos in materials used for building construction. The UST case was closed in 2004 but left behind petroleum hydrocarbon impacts in both soil and groundwater. Working under the regulatory oversight of the County of San Diego Department of Environmental Health, MHC hired SCS Engineers to perform Phase I and II Environmental Site Assessments. SCS prepared and implemented a Soil Management Plan (SMP) to ensure proper management and removal of lead- and petroleum hydrocarbon-bearing soil to ensure the safety of future residents and the environment in the development area, including the adjacent Poway Creek.
Community Housing Works, North Park Seniors – The North Park Seniors Project is San Diego’s first LGBT senior housing project. The housing was built in an area historically developed as early as 1921 with previous commercial and residential land uses. Due to the historical land uses at the site, which included a former blacksmith and horse stables circa 1921, elevated concentrations of lead were present in the soil that exceeded residential screening levels. To protect human health for future residents and workers and save costs on soil disposal at a landfill, SCS proposed a unique plan. In collaboration with Community HousingWorks, the County of San Diego Department of Environmental Health, and the project design team, lead-bearing soil could be reused or safely buried beneath the project during grading activities. The plan also greatly reduced the amount of truck traffic and greenhouse gas emissions during site preparation.
RD Brown Company and EAH Housing – Imperial Seniors – A former gasoline service station in the City of Imperial is being redeveloped into an assisted senior living facility. The project has gasoline impacted soil, groundwater, and currently has an open unauthorized release case overseen by the Regional Water Quality Control Board. The Water Board allows the proposed development to move forward while the case is still open, provided that a vapor barrier is installed beneath the proposed building and groundwater remediation and monitoring continue until gas/benzene levels in groundwater meet acceptable levels. Construction is on schedule to start in 2022.
Save the Date for Land Recycling!
Seize the opportunity to meet with colleagues working to reuse, rebuild, and revitalize communities through land recycling! This June, the Center for Creative Land Recycling (CCLR), U.S. EPA Region 9, and the CA Department of Toxic Substances Control’s (DTSC) Office of Brownfields will host the third California Land Recycling Conference (CALRC) in person in Carson, CA. The Conference offers an exciting space to learn, connect, and be inspired.
CALRC will focus on the most timely issues unique to California and resonate with the national big-picture, including affordable housing, vapor intrusion, funding, and equitable development. As evidenced by the Bipartisan Infrastructure Law (BIL), Build Back Better, and other federal and state revitalization priorities, we see historic investment in brownfields, climate, and economic revitalization. And California is leading the charge.
Come reuse, rebuild, and revitalize! Save the date for June 21-23, 2022, in Carson, CA!
Introduction
Contamination at thousands of shopping centers across California from previous business operations presents problems for property owners who wish to continue commercial use, redevelop, and maintain property value. Commercial property remediation targets returning these buildings and land to predevelopment conditions, presenting opportunities for reuse and redevelopment.
One property owner discovered that securing adequate funding and working closely with state and regional regulatory agencies leads to success despite changing regulations and oversimplifying regulatory health risk assessment methods. The Draft Cal-EPA Supplemental Vapor Intrusion Guidance (DSVIG) suggests changes to the methods in which vapor phase transport and potential health risks are modeled and calculated for occupants of buildings with known soil or groundwater contamination beneath them. These changes, the result of a multi-year working group collaboration, recommend an arguably more conservative calculation of indoor air quality. The changes rely on EPA work and guidance, with empirically derived attenuation factors (AFs), which will increase the number of sites requiring additional environmental assessment and mitigation to achieve health risk standards. Although the DSVIG is currently draft guidance, there is evidence that regional regulatory agencies have already adopted AFs in calculating indoor air quality.
Diamond Bar Commercial Center Assessment and Mitigation
Drucker Survivors Trust owns and operates a multi-tenant commercial building in Diamond Bar, California, including a dry cleaner at one time. The former cleaners caused an unauthorized release of dry cleaning solvent containing chlorinated volatile organic compounds to the subsurface during its operation.
Financing for this all too common situation requires environmental due diligence in the form of research commonly completed in a Phase I Environmental Site Assessment followed by an assessment to characterize potential liabilities associated with chlorinated solvent releases before lenders provide funding.
Regulatory oversight in California can either be voluntarily engaged or involuntarily if assessment activities on an adjacent or nearby property indicate the presence of chlorinated volatile organic compounds in the subsurface linked to dry cleaning operations in the vicinity.
The Drucker Survivors Trust sought approval from the applicable regulatory agency, Los Angeles Regional Water Quality Control Board (LARWQCB), to assess and mitigate the chlorinated solvent release to ensure the protection of human health and reduce environmental liabilities associated with the property.
Regulatory closure is the acceptance of assessment and remediation activities by the governing regulatory entity to bring the site into compliance. Compliance, in this case, required assessment and mitigation of beneficial use groundwater underlying the property impacted by the solvent release and completing soil vapor assessment and health risk screening calculations under current state and federal guidelines.
Guidance on vapor assessment and associated health risk screening methods have changed rapidly in California state environmental regulations. As environmental engineers and consultants, SCS professionals manage an extensive list of vapor assessment, health risk assessment, and vapor intrusion mitigation projects resolving these vapor–related issues.
To start this project, the SCS team prepared a successful grant application securing more than $650,000 in funding from the California State Water Resources Control Board’s Site Cleanup Subaccount Program (SB 445, established in 2014). This state-provided grant money enables the assessment and mitigation necessary to close with the LARWQCB.
Subsurface assessment activities defined the extent and scale of chlorinated solvent impacts to soil vapor, soil, and groundwater, enabling the design of a remediation program. To reduce the groundwater contamination to cleanup levels set by the LARWQCB, SCS Engineers designed and implemented an injection program to deliver engineered chemicals directly to the groundwater plume. The injected chemicals destroy the chlorinated solvents via in situ chemical reduction and stimulation of biological degradation.
While challenging drilling conditions precluded previous consultants from attempting groundwater remediation, SCS industry experts safely achieved up to a 99 percent concentration reduction within the groundwater plume. SCS designed a soil vapor assessment that relied more on site-specific data collection and less on conservative default assumptions while conforming to the most current regulatory guidance targeted at minimal impact on the building tenants.
SCS managed all aspects of the project, including grant requirements and communication between the client, regional and state water board staff, city staff, and subcontractors. Obtaining and managing entrance under state waste discharge requirements is necessary, and SCS completed all necessary permitting and reporting requirements to facilitate the groundwater mitigation activities. Careful planning and experience with similar projects minimized impacts on tenants and kept the project on a strict timeline with no missed regulatory deadlines. SCS continues working with the LARWQCB to conclude the client’s final closure requirements and is in the process of applying for an additional $900,000 in SCAP funding to implement the final stages of the project targeted at obtaining final regulatory closure.
Changes Coming to Regulatory Guidance
Recent changes to regulatory guidance in California are arguably making obtaining closure on sites with vapor intrusion health risk concerns more difficult to achieve. The Draft Cal-EPA Supplemental Vapor Intrusion Guidance (DSVIG) suggests changes to the methods in which vapor phase transport and potential health risks are modeled and calculated for occupants of buildings with known soil or groundwater contamination beneath them. These changes, which result from a multi-year working group collaboration, recommend a more extensive and site-specific data collection effort. They include indoor air quality calculation methods relying on EPA work and guidance and empirically derived attenuation factors (AFs) which some would argue lead to overestimating potential health risks.
The consequences of the DSVIG are potentially significant if adopted as is and appear likely to result in more sites being “screened in” with vapor intrusion issues and more sites requiring mitigation. The impact, resultant costs, and possibly detrimental secondary effects such as decreases in affordable housing production, particularly in urban infill areas. And while none would argue with appropriate protection of health risk, the question is whether the studies and empirical data used to support the DSVIG represents the best available science and is truly representative and predictive of risk.
The DSVIG adopts an attenuation rate of 0.03 for the flux of both soil and sub-slab vapor to indoor air based on a previous 2012 EPA Study comprised of empirical data collected from buildings arguably not representative of modern construction in California.
The development of a reliable screening level attenuation factor for California based on high-quality, recent, California-specific data:
1) Will be protective of human health, as no toxicological imperative or basis supports a call for accelerated or immediate action (as evidenced by the fact that the DSVIG workgroup commenced its work in 2014 and issued the review draft in 2020).
2) Will ensure California’s environmental policy satisfies the gold standard for data quality and insightful analysis in which the state once took pride.
3) Will not unnecessarily decimate the California housing development market. The empirically derived screening level AF in the DSVIG is overly conservative based on the available data. More accurate empirical data and measurement methods for site-specific measurement are available.
With respect, oversimplifying the VI health risk assessment methods has constrained the environmental community’s ability to apply science-based health risk screenings, often resulting in costs associated with additional environmental assessment and mitigation. An additional revision to the DSVIG to utilize a screening level AF more reflective of the current California data and building specifications could save state resources, increase infill development by reducing urban sprawl, promote housing development, all while protecting human health.
About the Author: Keith Etchells is a professional geologist and hydrogeologist with over two decades of experience assisting clients in managing environmental risks associated with ownership, transfer, or operation of commercial, industrial, and waste disposal properties. His particular technical expertise involves aspects of groundwater science and engineering relevant to contaminated sites and landfills, including supervision and conduct of subsurface data acquisition, remedial design and implementation, conceptual site model development, aquifer testing, extraction well design, groundwater quality evaluation and treatment, vapor intrusion health risk assessment and mitigation, predictive modeling, and contaminated soil and groundwater remediation design.
He is responsible for designing analytical, geotechnical, and hydrogeological data collection programs to complete subsurface assessment and remediation. He has prepared subsurface assessment documents, property mitigation plans, vapor intrusion risk assessment documents, soil management plans, aquifer characterization documents, conceptual site models, and groundwater remedial design and implementation documents.
