The Virginia Composting Council is the state affiliate of the US Composting Council; its mission is to support the efforts and initiatives of the USCC and bring the practice of composting to more Virginians. The Composting Council is growing because of increased efforts by communities to divert food waste from disposal. Demand is growing with increased awareness of composting’s beneficial uses.
The Virginia Council, led by President Ryan Duckett of SCS Engineers, cites the obvious benefits of less waste going to landfills and lower greenhouse gas emissions in the environment. He also points out the jobs and business development potential and using compost for stormwater management, erosion control, and other green infrastructure as benefits. Expanded programs also offer the opportunity to collect edible foods for non-profits feeding many in need while diverting non-edible organics to composting.
The Council brings together manufacturers, municipal managers, organics collectors, researchers, and other compost allies in the waste industry. The group works to educate state regulators, local officials, and the public about composting’s value in a circular system. Members also help develop positions on regulations and legislation that affect composting and the market.
USCC has 13 state chapters that do local work to advance the composting industry alongside the national advocacy and programs. Without their on-the-ground education, attention to and work in regulations and legislation, and building networks of people in the industry, USCC could not be effective.
Vapor intrusion is a regulatory hot button gaining traction on states’ radar nationwide. This is driven by a growing understanding of how vapors travel through the soil into structures, posing health risks to occupants, coupled with research showing volatile vapors can be problematic even at very low concentrations.
As in California, conservative assumptions by regulatory agencies call for careful due diligence during the assessment process. These salient concerns recently brought a real estate developer in Monrovia to seek a professional engineer.
The client plans to convert a commercial property to residential use. But before moving forward, it needs to assess potential environmental issues associated with the property. That’s where SCS comes in, drawing on its concrete knowledge base in geology and chemistry—and leveraging its grasp of regulatory requirements.
The work in Monrovia entails a detailed soil vapor assessment, looking for volatile organic compounds (VOCs); the discovery at this site came as little surprise to Julio Nuno, Senior Vice President, and Project Director, as these constituents are often found during evaluations of this kind.
Assessing for VOCs
In this case, the soil contained eight VOCs, some at non-compliant levels. The good news is, after an extensive, multi-step vetting process, Nuno and his team came up with a relatively inexpensive solution to tackle a potentially daunting problem.
“As part of the soil vapor assessment, we compare concentrations we find on-site to screening levels established by the Department of Toxic Substances Control. We often see levels in exceedance of regulatory thresholds, particularly in industrial areas with releases that can travel from groundwater to soil into the building through the slab,” Nuno says.
Most prominent at the Monrovia site were two chlorinated compounds that have been used as solvents in industrial applications: tetrachloroethylene, also called PCE, and trichloroethene, or TCE. PCE is commonly present in industrial settings and communities as drycleaners widely and routinely used the chemical for decades.
Nevertheless, the work begins even before confirming VOC levels and other specifics around these compounds. The first step is a Phase I Environmental Assessment looking to see if past use of the property or surrounding property may have left a significant environmental impact. The SCS team discovered the adjacent property had a release of VOCs they identified as a ‘recognized environmental condition,’ meaning it needs further evaluation using a Phase II to determine if vapors could migrate onto the client’s property.
During the Phase II Environmental Assessment –the collection of soil and soil vapor samples –the SCS team gets even more specific, determining what’s present, specific locations, what degree of contamination, and what these findings mean for redeveloping the property and its final use.
“We confirm subsurface concentrations and if they exceed state screening levels, and if the site represents a potential risk for future residential use. The information informs our possible solutions to mitigate any migration of certain VOCs into the building and the indoor air,” Nuno explains.
Redevelopment Goals – safety and cost containment
Safety comes first, but containing project costs is a priority, which comes down to knowing design options, how to piece components together with both function and economics in mind. At this site, achieving safety and controlling costs centered largely around looking at the mandatory infrastructure– a ventilation system for a planned underground parking garage to prevent accumulation of carbon monoxide and other vehicle exhaust emissions.
“We knew the underground parking would require a ventilation system. It makes sense to look at the parameters associated with that design to verify if it serves dual purposes to ventilate the garage and mitigate the potential for VOCs to enter the building,” Nuno says.
By studying air exchanges that would occur, the number of times replacing air-containing pollutants with cleaner air per hour, Nuno gets his answer. “We determined that a second, separate system would not be necessary for sufficient ventilation; the assessment enabled us to confirm vapors would not travel into the residential portion of the building.”
The client can save $50,000 to $75,000 in capital expenses upfront while achieving their safety goals and avoids ongoing operations and maintenance costs for added infrastructure.
An added layer of protection
Identifying the issues for site developers and their tenants, then plotting the best course of action to ensure safety and regulatory compliance takes experience and knowledge. SCS devises a soil monitoring plan, alerting developers of indications of potential contamination to the soil, of odor, or anything unusual that could suggest an environmentally adverse condition. The plan advises on how to respond should there be an unexpected condition adding a further protection layer.
“It’s essential that an engineer understand the applicable federal, state, and local standards for completing assessments, as well as understand regulatory stipulations. You must also know the variations in those stipulations to effectively design a sustainable plan,” Nuno says. “In Monrovia, we comply with the Department of Toxic Substances Control requirements, the requirements of the Los Angeles Regional Quality Control Board, and others. Each has specific stipulations for evaluating each contaminant. So, we stay on top of which rules apply to which location,” he says.
Nuno has submitted a draft report for review by his client and its legal counsel; he’ll meet with them to discuss findings and explain their meaning. SCS includes an executive summary, explaining in plain language what is salient; often, a backup report includes thousands of pages. “It’s a lot of complex information, so we work on the language,” Nuno says.
“It’s important to paint an accurate picture and use terms that all parties, whether the client, investors, or other stakeholders understand. These redevelopments are major projects with many due diligence considerations. We want to provide accurate findings and recommendations that the client and their advisors can digest to help them with their decision making.”
More resources:
SCS Engineers provides comprehensive environmental due diligence services nationwide and announces two new SCS National Experts to lead the expanding practice. Vice President Michael Miller and Project Manager Justin Rauzon take the helm to meet the expanding demand for these environmental services. Mr. Miller is in SCS’s Omaha, Nebraska location and Mr. Rauzon in the Long Beach, California headquarters office. Both professionals work nationwide and continue to support their regional clients in their new positions.
Miller focuses on comprehensive environmental management and consulting for private and federal clients. Project solutions typically involve solid waste, hazardous waste, environmental assessment, compliance audit, feasibility studies, environmental permitting, and training. His environmental due diligence experience includes work at fuel storage and vehicle maintenance facilities, petroleum retail sites, agricultural, chemical processing, and pharmaceutical manufacturing plants, active and closed landfill sites, abandoned chemical disposal sites, and numerous dry cleaner sites.
Mr. Rauzon has a diverse background in biological and environmental sciences and regularly performs environmental assessments and compliance audits at North American sites. Rauzon’s technical and management experience is with soil, soil vapor, and groundwater investigations on industrial, commercial, landfill, greenfield, and residential properties. He has extensive experience with environmental laws and regulations in the United States and Mexico.
Both work through all project phases, from developing cost estimates to implementing due diligence tasks ranging from site assessments to full remediation. SCS Engineers’ Environmental Due Diligence and All Appropriate Inquiries practice is comprehensive. The practice’s services cover Environmental Insurance Claims and Underwriting Support, Financing and Company Acquisition Support, Property Inspections and Abatement, Property Transactions, and Solid Waste Management Financing.
SCS’s Brownfields and Voluntary remediation engineers rely on the due diligence practice and developers, contractors, municipal officials and city managers, and advisors such as banks, insurance firms, and attorneys to private and public entities.
SCS Engineers Vice President Ashley Hutchens is now the Environmental Services Director for its Long Beach and Las Vegas operations. Besides managing her current projects and clients, Hutchens will manage the environmental professionals and technicians in each city. She is responsible for allocating resources for business development, project management, and coordinating activities with other SCS offices nationwide.
“Ashley’s proven capabilities solving environmental challenges for industries will serve our Long Beach and Las Vegas clients well,” said Julio Nuno, SCS Senior Vice President.
Hutchens has 18 years of experience in property evaluation and due diligence, site assessment, characterization, remediation; vapor intrusion assessment and mitigation; and hazardous waste management. She has led hundreds of projects, including all phases, from the development of cost estimates for site assessment, mitigation, and remediation, to groundwater monitoring and sampling, preparation and review of final reports, interfacing with regulatory agencies, and management of all aspects of projects, staff, and various subcontractors.
SCS Engineers’ environmental solutions directly result from our experience and dedication to solid waste management and other industries responsible for safeguarding the environment. For more information about SCS, please visit us at www.scsengineers.com, or contact .
Virtual Conference on April 15, 2021, recording on YouTube
Recorded at the Virtual Conference on April 15, 2021, this recording is available online.
Moderated by Michelle Gluck of Cornell Cooperative Extension Dutchess County, the panel discusses waste reduction, composting, anaerobic digestion, compost use, carbon sequestration…so many avenues to reduce climate impacts through organics management.
We’ll hear about New York State’s Climate Leadership and Community Protection Act, the progress of its waste advisory panel, and from a Climate Smart Community on how they’re planning to manage their organics with greenhouse gas emissions in mind.
Panelists include:
Suzanne Hagell, Climate Policy Analyst, New York State Department of Environmental Conservation
Molly Trembley, Environmental Engineer, NYSDEC
Greg McCarron, Vice President, SCS Engineers
Cities like Oviedo, Fla. are investing in the cleanup of defunct brownfield sites, converting even highly contaminated properties from liabilities to assets that pump economic vitality into their communities. And municipalities are getting reimbursed for doing so. But these ambitious undertakings require the expertise of professionals with strong environmental engineering and remediation backgrounds and an understanding of federal and state regulations aimed to protect public health and the environment.
This spring, after over two years of working closely with SCS Engineers and the development team, the City of Oviedo will unveil its redevelopment project: a 3.7-acre public park with a walking and jogging trail. The loop trail will be part of a larger trail system interconnecting through the City and the Cross-Seminole trail, with the latter running throughout the county.
The walking and jogging path surrounds a pond with a dual purpose: to serve as an added feature to this peaceful retreat and part of an enhanced stormwater management system that will allow business owners to convey drainage from their properties via an underground stormwater management system. Along the park perimeter, historical displays will tell the story of the nearly century-and-a-half-old City’s past.
SCS helped the City navigate regulatory issues associated with redeveloping environmentally impacted land, ensuring safe and environmentally sound practices, and maximizing financial reimbursement through the Florida Brownfields Program.
In the 1940s, the site operated as a farm but lay idle and overgrown with vegetation decades after. When SCS came in to complete the environmental assessment, the team confirmed that years of pesticide application did leave arsenic behind in the soil.
“It appears that the pesticides were used appropriately, but with the change in land use and to meet the state’s environmental criteria, we need to address the residuals to redevelop the property as a park. It would otherwise remain as unusable land without this cleanup,” says Kirk A. Blevins, SCS senior project manager.
SCS completed site assessment activities according to Chapter 62-780 FAC, which includes additional testing to delineate the extent of arsenic-impacted soil further and evaluate groundwater conditions. Assessment activities indicated that while not impacting groundwater, the soil contained arsenic above acceptable regulatory levels. In its next step, the team designed a remedial action plan with multiple considerations for success.
“Given that the site would include both a stormwater management pond and a public park, we recommended that rather than cap the soil to reduce potential exposure, the City meet the strictest cleanup criteria. This option is the most protective of human health and the environment,” Blevins says.
The plan included removing approximately 47,000 cubic yards of arsenic-impacted soil, then placement of clean import fill for areas open to the public. Blevins and his team proposed excavating to the property boundary, and they provided technical guidance to the City contractor on how to efficiently and safely execute this undertaking. “It was important to excavate to the property boundary to assure removal of the impacted material so that the City would receive unconditional closure approval from the regulatory agency,” explains Blevins.
Concise reporting of the work is key to securing that approval, so SCS documented the excavation of impacted soil to the appropriate depths and lateral extents, managing it appropriately onsite, and transporting it to an approved landfill for disposal.
The team worked with the City’s environmental counsel to bring the site into the Florida Brownfields Program and prepared its voluntary cleanup tax credit (VCTC) applications for submission to the Florida Department of Environmental Protection (FDEP). All expenses and payment, confirming the expenditures “integral to rehabilitation,” are documented. With this validation, the City of Oviedo is getting back about half of its $1,432,000 related investment. It will receive another 25% bonus once FDEP issues a letter stating that no further action is required.
Documentation and communication with the state regulators is an ongoing process requiring a detailed review of contractor proposals, invoices, pay applications, proof of payment, and a summary of progress each year over the project’s life. “In particular, a line-item review of invoices can sometimes establish additional actions that are critical to remediation that otherwise might have been overlooked and not captured. This process is vital to maximize reimbursement,” Blevins explains.
Cost, as always, is a client priority. So, SCS and the remedial team focused on minimizing offsite disposal of the impacted soil, proposing over-excavating the pond, using the unimpacted soil as the onsite fill, and placing a portion of the impacted soil at the pond’s bottom.
“This was possible because testing indicated that the impacted soil would not leach arsenic into the pond water at a rate that would adversely affect water quality. We confirm that arsenic concentrations are below the strictest regulatory level before any soil from over-excavating the pond can be of beneficial reuse onsite. Safety of people and environmental protection always comes first,” Blevins says.
The ultimate outcome: Oviedo has a regional stormwater pond suited for potential commercial operations to use for drainage, maximizing available land for economic development, as well as a recreational park for the community and visitors.
SCS’s technical expertise was crucial to successfully remediating this site, attests Bobby Wyatt, Public Works Director at City of Oviedo, Florida.
“The team easily navigated and sped up the permitting process for the arsenic removal and provided continuing assistance with monitoring during construction. The process for completing the specific remediation/permitting was unfamiliar to City staff, and SCS provided efficient and competent assistance to get us where we needed to go.
Their experience provided a sense of confidence that we were going to be able to make the park project successful,” Wyatt says.
SCS has worked on brownfields projects and voluntary remediation across the U.S. for over 45 years. We convert once nonproductive commercial and industrial properties into revenue-generators and affordable housing.
Resources:
Brownfields and Voluntary Remediation
What is your title and responsibilities at SCS Engineers?
My title at SCS Engineers is “Project Professional.” In the Southeast region, we have something called “Assistant Project Managers,” which is not an official title. However, as the name suggests, the position entails helping the project manager run the project. My responsibilities include:
What attracted you to join SCS?
While completing my Master of Environmental Engineering, most of my classes were either water or wastewater-related. I had heard of SCS Engineers; from what I had heard and seen, it was focused heavily on landfill engineering. As a millennial, I did not have a positive outlook on landfills; I was interested in the environmental remediation of properties. Luckily, I was in a restaurant and ran into Eddy Smith, Senior Vice President of Client Success. We went over my career goals and the projects at SCS. I applied for a job, and the rest is history!
What attracted me initially to SCS was working in Environmental Services. I have been with SCS for over three years now and have expanded into sustainable materials management (SMM), which is interesting and good for communities and the environment. I’m also eager to build a more comprehensive knowledge of using what was once waste to renewable energy sources and clean-burning fuel. Solid waste management and landfills are fascinating, more than I ever imagined. SMM, renewable energy, remediation, and landfill operations are interconnected and essential for keeping people and communities safe and thriving.
What is your favorite part of working at SCS?
The people at SCS! We hire humble, hungry, and smart people. The knowledge pool is incredible, and everyone is always willing to help, no matter what part of the country you’re working. People are just a phone call away.
What do you feel is your greatest achievement or contribution to date?
I am working on a 500-acre landfill redevelopment project divided into four quadrants. Our client completed construction on one quadrant with nine buildings. We’ve received closure for eight of the nine buildings and anticipate closure for the remaining building soon. I take pride in supporting them to accomplish the closure and earn the environmental approvals safer and faster because of my combined team’s expertise and experience.
What is challenging for you as a YP?
Learning to manage my time was the greatest challenge. Regularly, I would stay late to work on projects and completing my tasks. It wasn’t a sustainable balance in my life. I said yes to everything assigned instead of letting the project manager know that my plate was full. Now, by planning my day better, prioritizing, and giving project managers realistic deadlines. I found the balance that works, and I am more productive.
What has helped with your success?
The support of management and our team at SCS has made me successful. If I have an issue with a project or unsure of the direction I need to take, I know I can rely on my team to help. There have been times when colleagues have dropped what they are doing to help me finish a project on time and within budget.
Do you have a favorite aspect of SCS’s Young Professionals Program, and describe your role as Chair?
My favorite aspect of the YP program is the mentorship program that the committee relaunched in 2020. It is such an incredible opportunity as a YP to be guided by an experienced professional. They have stood where we are today, and getting to learn from their experience is invaluable; our YPs take advantage of it.
I enjoy my role as the Chair of the YP program; I spend my energies organizing by:
What are your favorite hobbies outside of SCS?
I am a bit of a nerd, so my friends and I play Dungeons and Dragons every week. I also like DIY projects with arts and crafts – I made wall décor out of cardboard when I moved into my house!
What advice do you have for others getting into STEM fields?
When I was younger, I was advised not to go into the science, technology, engineering, and mathematics fields by my career advisors and teachers because they did not think I would be successful. In fact, because of their advice, I tried out classes in the non-STEM field like history, commerce, geography, and I did not enjoy them. I was still intrigued by the STEM field, so I listened to my gut and look where I am today! STEM is not biased. My advice would be not to let anyone tell you that STEM is not for you. If you want to study science, technology, engineering, and mathematics, just do it!
Thanks to South Florida’s hot real estate market and impressive growth rates, a dwindling supply of properties are available for development in the area. The Atlantic Ocean limits South Florida’s development options to the east and Florida Everglades to the west. Due to these supply limitations, developers seek to redevelop contaminated landfills, golf courses, and agricultural land. Environmental due diligence is essential to the successful redevelopment of these types of properties. Depending on the property’s size and the extent of the contamination, redeveloping contaminated properties can cost upwards of a million dollars.
Typically, developers will have to deal with contaminants like ammonia at a landfill redevelopment project, arsenic at a golf course redevelopment project, or pesticides at agricultural redevelopment projects. In some cases, remediation and assessment using the standard or “default” cleanup target level (CTL) can stop a project from proceeding. However, before abandoning the project, developers should consider the potential for establishing alternative cleanup target levels (ACTLs) for the site’s contaminants.
Several technical strategies are available to developers considering redeveloping contaminated properties to reduce overall costs and expedite the construction schedule. Costs associated with managing material above a default CTL can include disposal of contaminated material, importing clean fill, and delays to permitting and construction schedules if an environmental regulator determines your assessment is incomplete.
Understanding Default Cleanup Target Levels
Environmental regulators use a range of tools to develop default CTLs. Default CTLs can be based on complex equations that consider toxicity and exposure assumptions such as ingestion rates, body weight, age, and exposure levels. Soil properties are also considered. In some cases, human health may not even be the determining factor in calculating a default CTL. Rather, a particular contaminant’s environmental impact on the local ecosystem may be what determines its default CTL.
While default CTLs are useful tools to formulate remediation strategies on a broad range of sites, default CTL values will be overly conservative for other sites. More explicitly, some sites’ present and future use and exposure characteristics are so different from the assumptions used to calculate the default CTLs – that the default CTL does not accurately correspond to the risk associated with the proposed sites’ use. In such cases, explore the development of an alternative cleanup target level (ACTL).
Establishing Alternative Cleanup Target Levels
With the right approach, a site ACTL could provide significant cost savings while maintaining regulatory compliance. But buyers beware; choose your environmental consultant carefully. The consultant should understand the site-specific factors that affect the calculation of the ACTLs. Often, a knowledgeable consultant has a good idea of the outcome even before investing the client’s time and money pursuing the alternative.
Cost and Schedule Benefits
To illustrate cost and development time-savings, consider a simple example of arsenic-contaminated soil at a residential development. Suppose there are no other reuse options available for the contaminated material, and the material must be disposed of at a landfill. Given 100,000 cubic yards (cy) of contaminated material at a disposal cost of $60 per cy, we estimate 6 million dollars in disposal costs, not including importing clean fill. However, if the site is an age-restricted residential community, certain exposure assumptions could be modified to calculate a much higher ACTL for arsenic. The soil would no longer be regulated as contaminated, and costs associated with disposal, imported material, and soil tracking are eliminated. Soil that was considered contaminated based on the default CTL is now clean based on the ACTL.
Let us look at a more complex example. Consider the case of a site contaminated with dieldrin, a common pesticide found at golf courses and agricultural properties. A leachability ACTL recalculates the default leachability of a particular soil contaminant. A leachability ACTL uses site-specific soil chemical and physical properties, such as soil organic matter content, bulk density, and annual average soil moisture content, and determines a more realistic risk profile associated with soil that could potentially leach contaminants into the groundwater. With an ACTL above the default CTL, remediation may not be necessary, or the site may not require a deed restriction, or ongoing costs associated with monitoring of the groundwater or operation of a remediation system could be eliminated, making the completed project more attractive to potential buyers.
Summary
Developing ACTLs is a careful, thoughtful strategy that an experienced environmental consultant can propose based on the site’s unique conditions. The developer’s financial objectives and schedule and the property end-use must be carefully considered to develop a thorough redevelopment approach. The use of an ASCTL could mean the difference between a project that is financially infeasible and one that is attractive and profitable.
Learn more about remediation and brownfields redevelopment.
About the Author: Troy Schick, PE, specializes in stormwater and groundwater management and voluntary remediation of properties, including brownfields and former landfills. Troy uses his experience at SCS Engineers and education as an Environmental Engineer and Environmental Manager with field inspection, sample collection, documentation, and project management to benefit Florida communities. Troy is available for consultation at tschick@scsengineers.
Achieving Florida’s 75% Recycling Goal presents unique challenges and opportunities for policymakers and professional staff. Across the country, local governments who had become accustomed to receiving operational cost offsets from their recyclable materials are now paying higher fees to continue their recycling programs. Renewable News covers how Leon County and the city of Tallahassee are managing both through their partnership.
They are uncovering opportunities to improve upon current operations, including but not limited to potential changes to facilities, infrastructure, programs, and partnerships. New opportunities are helping both develop long-term policy strategies and recommendations to continue a financially viable recycling program and meet goals.
Read and share the article here.
Look, I get it. If a regulator walks in the front door, send your maintenance folks out the back door with a bucket of paint. We want to make the system look shiny and as new as we can get so that the regulator might cut us some slack. However, the issue is what happens when we don’t remove the lipstick, so to speak, and clean up the dirt (in this case, corrosion) underneath. Imagine what a celebrity would look like if they never washed off the makeup that they applied each day. Now take a look around your system. Do any of your pipes or valves, or even vessels, look like …
Keeping reading Lipstick on a Pig, Bill Lape’s latest article in the Epic Fail section of the RETA Breeze, to meet IIAR6 requirements before the regulator arrives.
Bill Lape is a Certified Industrial Refrigeration Operator, a Certified Refrigeration Service Technician, and a member of the National Board of Directors of the Refrigerating Engineers and Technicians Association. He writes regularly to guide businesses and workers using industrial refrigeration.
Corporate Headquarters
3900 Kilroy Airport Way Suite 300
Long Beach, CA 90806
Telephone
1 (800) 767-4727
1 (562) 427-0805 | FAX
Contact Us
