In degraded ecosystems, manipulating sediments can aid in recreating natural sediment processes, establishing suitable substrate conditions for aquatic life, and supporting the recovery of vegetation and wildlife. In the United States, sediment management revolves around the presence of contaminated sediment. Contaminated sediment sites pose intricate technical challenges that demand significant resources to address and mitigate the associated problems effectively.
Over the past three decades, significant progress has reduced the discharge of toxic and persistent chemicals into waterways throughout the United States. However, a persistent problem remains, characterized by elevated concentrations of contaminants in the sediment found at the bottom of rivers and harbors. The situation has raised considerable concerns about its potential risks to aquatic organisms, wildlife, and humans.
This paper by Dave Palmerton delves into the technical challenges environmental engineers and consultants face in addressing and mitigating this issue, especially during waterfront remediation projects. Furthermore, he explores strategies to optimize resources to tackle the problem at hand effectively and efficiently.
Active monitoring and data collection is critical throughout the remediation process. These activities enable evaluating the chosen strategy’s effectiveness, identifying necessary adjustments, and ensuring compliance with environmental regulations. Adaptive management approaches allow modifying or refining the sediment remediation strategy based on monitoring results and stakeholder feedback.
The utmost importance lies in choosing the appropriate remediation techniques; base the decision on site conditions, the specific contaminants present, and the desired remediation goals. After reading the paper, you may get a better idea of the options available for achieving effective and sustainable sediment remediation outcomes.
About the Author: David Palmerton, PG, is has extensive experience in environmental site assessment remediation, due diligence, and construction quality control. Experience includes providing consulting services to a variety of large commercial, industrial, and academic entities. He has also provided litigation support. He has managed and performed numerous Phase I, Phase II, due diligence, and remediation projects, including a solar farm geotechnical and environmental project. He has managed the closure of large oil fields, plugged over 1,000 oil and gas wells, deconstructed oil and gas pipelines and facilities, and performed remediation of petroleum contaminated soil and groundwater.
SCS Engineers welcomes Ryan D. Francis as Environmental Services Project Director in Texas. He investigates and remediates petroleum or chlorinated solvent-contaminated properties for continued use or beneficial reuse.
Mr. Francis is a licensed professional geologist with over 16 years of experience, including senior management of a nationwide portfolio of petroleum storage tank closures; technical and project management of petroleum soil and groundwater site investigations and remediation; third-party technical review; property administrative controls; and serving as the geologist-on-record for multiple environmental projects in Arkansas, Louisiana, and Texas.
Ryan supports national clients in the logistics and oil & gas businesses, focusing on midstream and downstream infrastructure, such as underground and above-ground storage tanks, pipelines, and aging infrastructure; many in the U.S. are over 75 years old. He works closely with local and state environmental quality agencies to ensure appropriate environmental protection for each project and to support clients in complicated cases involving multiple responsible parties.
“At SCS, we guide our clients through the regulatory framework as it impacts each project’s work, whether infrastructure or properties, states Vice President Jeff Reed. “Ryan’s deep knowledge of midstream and downstream environmental regulations and ability to target what is most appropriate for the specific environmental conditions is a valuable addition to our O&G and Remediation teams.”
Meet Ryan D. Francis.
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.
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.
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.
Application Process for $275M in California Grants Opened Jan. 31
A couple of months ago, I wrote about the opportunities and challenges of getting brownfields back into productive use. There are certainly viable strategies for remediation of contaminated property that will make them safe for a range of developments. Of course, the cleanup costs are a significant factor in any project analysis. But the state of California is providing some assistance that could make more brownfield sites pencil out for redevelopment.
I am happy to report in this article that the passage of SB 158 by the California legislature provides $500 million in cleanup funding for brownfields. Approximately $270 million of that total is targeted for grants.
The California Department of Toxic Substance Control (DTSC) administers the Equitable Community Revitalization Grants funded through SB 158. On January 31 of this year, the DTSC started accepting full applications for these grants. The application window closes on April 4, 2022, with award announcements expected on May 31, 2022.
The DTSC gives the highest priority for grants in disadvantaged communities with significant housing needs.
$270 million is a big investment. The USEPA has a similar program, with typical funding for the entire country, of less than $100 million (https://www.epa.gov/newsreleases/epa-announces-selection-151-communities-receive-665-million-brownfields-assessment-and). Since DTSC started accepting applications at the end of January, nonprofits, public agencies, municipalities, tribes, and private developers must act quickly.
Eligible entities may apply for ECRG grants for properties they own or control in high poverty areas with a CalEnviroScreen score of 75 percent or more for reuse. DTSC will also accept applications outside of the CalEnviroScreen score of 75%+ if the proposed reuse provides significant community benefit.
As I outlined in my previous article, it is important to have a risk management strategy that includes a thorough understanding of the environmental issues on the site and how those issues can impact your redevelopment plans and bottom line. Environmental and legal support experienced in identifying, anticipating, and managing risks on brownfields is critical to success.
There are an estimated 200,000 brownfields currently identified in California, many of which are useful for housing after remediation. Many of these sites are in the urban core and perfectly fit infill strategies for solving the housing crisis by reducing commute times and related greenhouse gases.
An example of such a project is COMM22 in San Diego, developed by BRIDGE Housing, in which SCS provided environmental oversight during remediation. COMM22 is a mixed-use, mixed-income, transit-oriented development located at Commercial and 22nd streets in San Diego.
The site where COMM22 stands today was a former San Diego Unified School District vehicle maintenance and general maintenance facility. The site included leaking underground storage tanks and fill soils containing various metals, including lead.
After successful remediation, the parcel today hosts 211 affordable housing units, including apartments for low-income seniors (including HUD-subsidized units), supportive housing for youth transitioning out of the foster care system, and eleven townhomes for low- and moderate-income families.
Many more badly needed projects, like COMM22, could become a reality thanks to SB 158. If you have a brownfield in mind that fits the criteria or have questions about the grant application process, contact the Center for Creative Land Reuse (www.cclr.org). CCLR partners with the DTSC to give free assistance in applying for funding.
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 nearly two decades of experience in environmental consulting, general contracting, commercial and residential development, and property and asset management. He has performed and reviewed over 500 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.
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 include 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.
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.
Take a deeper dive into this topic in the Daily Transcript article Vapor intrusion rules hamper infill projects.
The Department of Toxic Substances Control’s Office of Brownfields’ Equitable Communities Revitalization Grant (ECRG) provides funds to incentivize cleanup and investment in disadvantaged areas of California. ECRG is setting a new path for land use that will have immediate and lasting benefits for communities, parks and green spaces, commercial enterprises, and housing.
Apply for grant funding to help Californian government units, nonprofit organizations, and Tribes assess, clean up and reuse idled and contaminated properties in the state’s environmental justice communities.
The application deadline is April 4, 2022.
Don’t miss this unique opportunity for grant assistance to clean up and revitalize our communities.
“The Infrastructure Investment and Jobs Act, signed into law last month, will dedicate more than $1.5 billion to the U.S. EPA Brownfields program. The Act includes hundreds of millions of dollars allocated to Multipurpose Grants, Assessment Grants, Cleanup Grants, Revolving Loan Fund Grants, and technical assistance intended to improve equity, create jobs, and mitigate environmental degradation.”
CCLR has provided the expected breakdown and timelines from EPA. The EPA has hundreds of millions of dollars allocated for FY22 that will be applied for in July and awarded in November 2022. This timeline is different and with much larger individual grants possible, up to $10mil per grant.
SCS Engineers has a stellar win rate for brownfields grant writing and implementing brownfields programs. Please let our brownfields and remediation experts know if you have any questions or if we can provide assistance in grant support.