Updated Arsenic Toxicity Values Have Implications for Soil Cleanup in Florida
In 2024, SCS Engineers published an article about the ongoing update to the U.S. EPA’s Integrated Risk Information System (IRIS) Program toxicological review of inorganic arsenic. The update included proposed changes to the oral cancer slope factor (CSFo) and the oral reference dose (RfDo). In January 2025, the final IRIS Toxicological Review of Inorganic Arsenic was released.
The final review proposes a combined oral cancer slope factor (CSFo) of 32 (mg/kg·day)⁻¹, which accounts for both lung and bladder cancer risks. This replaces the previous CSFo of 1.5 (mg/kg·day)⁻¹, a significant increase in assumed potency compared to earlier assessments.
The updated, more conservative CSFo for arsenic will substantially lower allowable soil concentrations. Specifically, the residential soil cleanup target level (SCTL) decreases from 2.1 mg/kg to 0.1 mg/kg, and the commercial/industrial SCTL decreases from 12 mg/kg to 0.6 mg/kg, assuming all other input parameters remain the same. Note that there will be no direct change to the arsenic groundwater cleanup target level (GCTL), as Florida uses the drinking water standard under Rule 62-550 FAC as the GCTL.
Most residential sites already require background studies because it is often infeasible to meet the current residential SCTL of 2.1 mg/kg. Moving forward, background studies will also be important for commercial/industrial sites, which could affect project planning and site management.
Even though the updated CSFO has not yet been incorporated into the current Florida soil standards, staying aware of state and county regulatory changes is critical for anyone involved in property transactions. For buyers, this means that potential environmental liabilities could increase if cleanup standards change. For sellers, understanding potential changes in SCTLs can help them proactively address environmental issues and avoid delays in property sales or redevelopment. Completing remediation under the current rules can reassure buyers and streamline the transaction.
Changes in SCTLs don’t just affect compliance; they also influence risk assessments, remediation strategies, and resource allocation. For clients with pending transactions or redevelopment plans, this knowledge helps you make decisions proactively, saving time, money, and effort and reducing regulatory uncertainty. By keeping track of regulatory updates and understanding how SCTLs might change, we as consultants can guide our clients, both buyers and sellers, to protect themselves, plan, and ensure smoother property transactions.
The following links will direct you to the proposed toxicological review and additional resources:
Anabel Rodriguez-Garcia is an environmental scientist with a decade of experience in the sustainable management of soil, including heavy metal contamination, and in organic fertilizers, as well as in the physical, chemical, and biological characterization of soils, including sample collection and documentation. She serves SCS clients as a senior project professional and is particularly valuable for environmental site assessments. She has worked on projects for government agencies, including the Florida Department of Transportation and Miami-Dade County Regulatory and Economic Resources; public utilities; and private-sector clients.
Lisa L. Smith has three decades of experience across a variety of roles in environmental science. Lisa serves SCS clients as a senior technical advisor and expert in risk-based corrective action (RBCA). She has worked as an environmental regulator at the Miami-Dade County Department of Environmental Resources Management (DERM), a risk assessor at a national environmental consulting firm, and a research chemist at the University of Florida.
SCS Engineers presents an overview of a live webinar titled “Phased by Design: Aligning Data, Dollars, and Decisions in Planning,” which focuses on a case study from the City of High Point, North Carolina. The webinar demonstrates how a phased, financially grounded procurement process can lead to more targeted, practical, and cost-effective outcomes in waste management planning, with broader applications for municipalities and utilities.
The City of High Point adopted a phased approach, sequencing its planning process first to diagnose financial and operational challenges, which then inform subsequent decisions, resulting in a more focused scope and budget. This contrasts with traditional broad RFPs, which often yield generic, overly comprehensive proposals.
The webinar features Melinda King, Assistant Public Works Director of High Point, NC, who has extensive experience managing public works divisions, including landfill and environmental services. Melinda led the RFP effort in the case study. Vita Quinn, a national expert on utility finance and rate studies at SCS, also presents, sharing expertise on financial sustainability solutions and utility rate design across various services, including solid waste and recycling.
Procurement teams often create RFPs under time pressure, without close collaboration with the utility or the department that needs the project. This can lead consultants to respond to poorly defined scopes, resulting in expensive and broad plans that are difficult to implement. A phased approach begins with procurement and realistic expectations, enabling more precise consultant bids, sharper solutions, and easier plan execution.
While the case study centers on solid waste management, the phased procurement process applies to any business, municipality, utility, or public works department seeking improved planning and procurement outcomes.
Attendees will learn how to:
Participants will gain a repeatable procurement framework that integrates financial analysis, operational feasibility, and long-term strategy into a phased project roadmap. They will also better understand how to structure scopes that protect budgets while attracting innovative consultant solutions.
The webinar encourages questions during and after the session and offers certificates of attendance on request for the live session. For those unable to attend live, a recording is available upon RSVP.
Phased by Design, our first 2026 live webinar, unpacks a real case study from the City of High Point, North Carolina, showing how a phased, financially grounded procurement process can produce more targeted, practical, and cost-effective outcomes for solid waste management planning.
Rather than relying on broad RFPs that result in generic, full-scope proposals, the City intentionally sequenced its planning process to diagnose financial and operational challenges up front. That first phase informed every decision that followed, allowing for a more focused scope and budget.
Hear directly from Melinda King, Assistant Public Works Director, High Point, NC, and Vita Quinn, SCS’s National Expert on Utility Finance and Rate Studies, as they translate lessons from solid waste into a broader City procurement strategy.
Why This Matters
Procurement teams often write an RFP because it’s on the annual calendar, and there may be pressure to move quickly. But they don’t always work alongside the utility or department that needs the project. Consultants then respond to what’s written in the RFP. If the scope wasn’t written to address the issues, the proposal won’t address them either, resulting in plans that are broader than required, more expensive than necessary, and harder to implement. A targeted phased approach starts with procurement and sets realistic expectations for project elements and the timeline to project success. Consultants bid more specifically, solutions get sharper, and the final plan is easier to execute.
Who Should Attend or Watch?
The case study is based on a solid waste management plan, but the process can apply to any business, municipality, utility, or public works department.
What You Will Learn
How to consider underlying financial and operational drivers before releasing your initial RFP, so your procurement is informed, not speculative. How to scope feasibility and risk early through a feasibility analysis phase, reducing cost exposure and improving bidder differentiation.
How a phased implementation design logically sequences deliverables so each step earns its scope from the one before it.
How tailored procurement can help reduce planning costs and provide a clearer path to implementation.
You’ll Walk Away With
A repeatable procurement framework that integrates financial analysis, operational feasibility, and long-term strategy into a phased project roadmap.
A clearer understanding of how to structure scopes that protect your budget while still attracting innovative and differentiated consultant solutions.
As with all SCS Client Webinars, we’re here to answer your questions throughout the forum and afterward. As always, SCS Engineers does not share or sell your contact information. For those joining the live webinar, we will provide a Certificate of Attendance upon request.
Navigating environmental permitting for new construction or expansion projects can be daunting. The process is filled with regulatory hurdles, stakeholder concerns, and the ever-present risk of costly delays. Drawing from the expertise of Sara Rains and Mike Dustman, Senior Project Managers at SCS Engineers, here’s a practical guide to help you avoid common pitfalls and achieve smooth compliance.
Start with Strategic Planning
The foundation of successful permitting is built early in the process, through thorough planning. Before breaking ground, conduct comprehensive environmental assessments—think Phase I & II Environmental Site Assessments, hazardous material surveys, and Operations & Maintenance plans. These steps help identify potential issues before they become roadblocks.
Pro Tip:
Use a management of change process to document every modification—whether it is new construction, a physical upgrade, or a chemical change. This ensures you are not blindsided by regulatory requirements later.
Know Your Permit Types
For example, in Missouri, projects typically require several permits. These permit requirements commonly apply to other states as well.
Identifying the right permits early is critical; missing one can halt your project in its tracks.
Engage Early and Communicate Often
One of the most overlooked strategies is early engagement with regulatory agencies and stakeholders. Reach out to agencies such as the Missouri Department of Natural Resources (Missouri DNR), the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and local city or county authorities as soon as possible. Open, transparent communication builds trust and helps resolve issues before they escalate.
Stakeholder Map:
Manage Timelines and Expectations
Permitting timelines can vary widely depending on project complexity and agency workload. Set realistic schedules and clearly communicate expectations to all parties. This prevents unpleasant surprises and keeps your project moving forward.
Avoid Common Pitfalls
Many projects stumble over the same hurdles:
Compliance Is a Continuous Journey
After you secure your permits, the real work begins. Continuous compliance monitoring, accurate reporting, and diligent recordkeeping are non-negotiable. Neglecting these can lead to fines, delays, or even shutdowns.
Best Practices for Success
Final Thoughts
Environmental permitting doesn’t have to be a headache. With careful planning, early engagement, and a commitment to compliance, you can avoid common pitfalls and keep your project on track. For more guidance, reach out to experts like Sara Rains and Mike Dustman on LinkedIn.
Have questions or want to share your own permitting experiences? Drop them in the comments or contact us at SCS Engineers.
As an employee-owned environmental consulting and construction firm, SCS Engineers supports the communities we live and work in year-round. But we all want to be doing something extra during the holidays.
In 2024, SCS donated to 43 local registered IRS 501(c)(3) charities during the holidays, positively impacting over 90,000 people! Our Corporate program has proven to be successful, so we plan to grow it this year.
In addition to supporting this year’s annual SCS Young Professional Group’s holiday fundraising, we plan to send significant donations to the four charities below that align with the environmental nature of our business and do so much for others. We will continue funding the Robert Stearns SWANA and the Environmental Research & Education Fund Scholarships.
These charities rely on consistent donations from patrons like SCS and you. We thank them all for their continuing humanitarian work. As always, we will continue to donate year round to the Red Cross and World Central Kitchen in support of people impacted by natural disasters worldwide.
During the October 2025 Committee Week in Atlanta, Georgia, ASTM International named Justin Rauzon to be the Recording Secretary Officer based on his technical and management experience with investigations at industrial, commercial, landfill, greenfield, and residential properties, combined with his extensive experience with environmental laws and regulations in the U.S. and Mexico. At SCS Engineers, he guides clients through complex real estate and redevelopment projects, emphasizing sustainable and defensible outcomes.
What is the ASTM Committee E50?
The ASTM Committee E50 is the main technical committee that develops voluntary consensus standards for environmental assessment, risk management, and corrective action. The E1527 Standard for Phase I Environmental Site Assessments (Phase I ESAs) is a critical standard in use nationwide for conducting environmental due diligence in commercial real estate transactions. It supports compliance with the U.S. Environmental Protection Agency’s All Appropriate Inquiries rule under the Comprehensive Environmental Response, Compensation, and Liability Act and related laws.
The E1527 Standard is updated typically every five to seven years, and the next round of updates kicks off in January 2026. Given the significant impact that standards like E1527 have on real estate transactions and risk management, a meticulous and reliable recordkeeper is vital for the integrity of the committee’s work. As Recording Secretary, Mr. Rauzon will support the documentation and coordination of subcommittee activities, including standards updates, meeting summaries, and procedural communications among ASTM committee members.
Due Diligence and Environmental Experience and Expertise
Justin Rauzon is SCS Engineers’ national expert on environmental due diligence and is experienced in all aspects of environmental services. He has a diverse background in biological and environmental sciences, and regularly performs environmental assessments and compliance audits at sites in the U.S. and Latin America. He completed ASTM Officer Training in West Conshohocken, Pennsylvania, in September 2024. His appointment reflects his deep expertise in environmental assessment practices and his longstanding commitment to maintaining high environmental quality and risk management standards.
“I’m honored to be part of the next standard update. Contributing to the next round of discussions and revisions to such an important standard is humbling and rewarding. I was pleased that my colleague, Megan Husic, will join me at ASTM Committee Week as an ASTM Emerging Professional. I look forward to working jointly with her and the other officers on the 1527 Committee,” said Mr. Rauzon.
If you’d like to contact Mr. Rauzon, please visit SCS Engineers or say hello on LinkedIn.
SCS Engineers announces the promotion of Eric Williams as the firm’s new National Director of Brownfields Redevelopment. Eric has over three decades of experience providing a full range of environmental services, focusing on brownfield redevelopment. His career includes experience with large environmental consulting firms, helping a specialty lender build a national footprint for brownfield funding, and running his own companies that exclusively developed environmentally challenged properties. His expertise spans various industries, including local government, commercial businesses, heavy industry, landfills, and mined land restoration.
As a thought-leader, Eric puts his expertise to work – investigation and cleanup, environmental liability management, real estate transactional functions, project entitlements, and funding. His multifaceted skill set helps our clients, from identifying environmental liabilities before buying or selling to addressing contaminants cost-consciously, and restoring the land’s health and value, states Senior Vice President and National Environmental Market Leader Michael Miller.
Eric has developed deep expertise in brownfield project funding. Currently, EPA and state brownfield grants support many projects in the U.S. The 2025 EPA brownfield grants were awarded to recipients earlier this year, and EPA will open applications for the next round of brownfield grants sometime in the next couple of weeks, but it will be even more competitive than ever as the Bipartisan Infrastructure Law dollars will no longer fund these programs.
As Eric Williams put it in his 2025 National Brownfields Training Conference Workshop called “Stack & Sequence”:
Brownfield projects require multiple capital sources to succeed; the more difficult the project, the more capital sources. We must build funding strategies that include various brownfield capital sources, ranging from brownfield-specific funding to traditional redevelopment financing and more creative sources. A deeper dive shows how sources can be integrated and stacked, then used sequentially for the various stages of redevelopment to be combined with private investment.
To learn more about Brownfields, please visit the SCS Engineers’ website to find educational materials or contact the firm’s experts. You may also reach Eric Williams on LinkedIn.
The upcoming round of EPA Brownfields Multipurpose, Assessment, RLF, and Cleanup (MARC) Grant applications is your community’s final opportunity to benefit from expanded funding through the Bipartisan Infrastructure Law (BIL). With this expanded support ending, competition is expected to be intense, and future grants could be smaller and scarcer.
Don’t miss this critical moment to secure transformative resources for revitalization and economic growth. Partner with SCS and start preparing your application now to stand out and make an impact.
EPA anticipates issuing the following solicitations for funding in fall 2025:
Let’s lay the groundwork today, so you’re ready when it counts. Reach out to SCS to start building your competitive, on-time application. After you contact us, one of our grant experts will reach out to schedule a virtual meeting.
The strongest applications don’t come together overnight. They are forged well in advance through strategic planning and expert insight.
At SCS, we guide our clients through every step of the process, helping you confirm eligibility, craft a compelling story, and compile the documentation that makes your application stand out. Our team has a strong track record of securing Brownfields funding for communities nationwide. When you work with us, you’re not just meeting deadlines but increasing your chances of success.
MARC Grant Funding Resources:
SCS Engineers is excited to participate in the MATC Business, Creative Arts & STEM Career & Internship Fair!
Join us on Wednesday, October 1, from 11:00 a.m. – 2:00 p.m. at the MATC Downtown Campus to explore career opportunities with our team. SCS Engineers provides environmental consulting and engineering services in solid waste management, renewable energy, remediation, and sustainable infrastructure.
We’re eager to meet students and alumni from the Business, Creative Arts, and STEM pathways who are ready to make an impact through internships, apprenticeships, and full-time career opportunities. Stop by our booth to learn how you can grow your skills and career while contributing to a more sustainable future with SCS Engineers. Register now.
Congratulations to Gabrielle Stephens for her promotion to lead SCS’s Southwestern U.S. Air Compliance Group. She brings over two decades of client success to the role.
Greenhouse gas (GHG) reporting or verification, regulatory air compliance, and air permitting services fall within Ms. Stephens’ purview. She leads teams that support clients in the solid waste and manufacturing industries, who find value in having a regulatory liaison to navigate ever-changing federal, state, and local regulations. These teams help maintain efficient operations and enhance business communication with stakeholders.
Regulatory agencies often operate independently, and knowledgeable environmental consultants know how best to meet multiple agency data requirements, resulting in positive relationships between agencies and clients. SCS clients find that improved communication helps minimize or prevent permitting and compliance delays. Agencies, especially air district staff, can depend on the accuracy of Clean Air Act experts who are experienced with newer technologies proven to work, but potentially new in a district.
Ms. Stephens’ experience spans multiple states, numerous air districts and local enforcement agencies.
Beyond her work in air permitting and compliance, Ms. Stephens works on emissions estimates and inventories and has extensive experience preparing permit-to-construct/operate and Title V permit applications. She has also undertaken projects evaluating and reporting to meet the federal Greenhouse Gas (GHG) Rule and the AB 32 Landfill Methane Rule. Her collaborative efforts with the solid waste industry contribute to multiple facilities obtaining landfill gas-to-energy and RNG permits that positively impact air quality.
Ms. Stephens’ air compliance audits, permitting, and compliance reporting for manufacturing facilities, including fiberglass boats, product removers, ceramics, paper products, and cement/aggregates, help ensure regulatory compliance and improve operational efficiency.
Additional Clean Air Act Resources:
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