Historic fill is common on properties that were once rural and have become prime redevelopment sites as communities expanded. The fill may include contaminated materials like foundry sand, ash, demo and construction debris, and even municipal waste. In the past, these materials were used to fill wetlands or change the grade of the property before initial development. Today regulations have evolved, and state agencies require property owners to manage these materials appropriately during redevelopment. Also, particular types of historic fill are often not robust enough to structurally support your new building.
There are many different kinds of fill materials – each with different physical properties and different potential contaminants. Knowing what is on your property before you start designing the site layout, and certainly, before you start digging, will help you plan your project to save time and money, and to receive state agency approval.
Before You Buy
The more you know about the property and the earlier you know it, the better prepared you will be to make decisions about how best to protect yourself from potential environmental liabilities and prepare for the environmental and geotechnical issues that historic fill can cause. Since every property is unique, the first thing you need to do is gain a thorough understanding of the property’s history and past use. Invest in a comprehensive Phase 1 Environmental Site Assessment (ESA). Consider it a starting point for clues about the possible types and amounts of historic fill which may be present on the property.
If the results of the Phase 1 ESA warrant it, conduct a Phase 2 ESA and geotechnical study to collect soil, fill, groundwater, and soil vapor samples. The Phase 2 ESA and geotechnical studies will help you understand if fill and contaminants are present and the best options for addressing them during the development planning stage.
Historic fill on a property is no longer the impediment to development that it once was. Take these steps to get ahead of potentially contaminated historic fill, and keep your project on time and budget.
By testing early, performing a proper geotechnical evaluation, and incorporating design adaptations where needed, you can successfully develop projects with historic fill within your schedule and without breaking your budget.
SCS professionals are available to answer questions or concerns you may have pertaining to commercial, residential, or private development on brownfields – we provide remediation, brownfields, and Environmental Due Diligence services nationwide. Contact or one of our experts.
About the author: Ray Tierney
Ray Tierney, PG, is a Vice President of SCS Engineers and one of our National Experts on Sustainability. He has 30 years of experience in environmental and sustainability engineering and has helped a wide range of organizations control and reduce their legacy environmental impacts and liabilities, lower their costs, obtain grants and permits to expand, and implement cost-saving practices. Ray serves the Midwest region and projects throughout the U.S.
JohnTabella, PG, LEED AP®, is SCS Engineers National Expert for Environmental Due Diligence and for Federal Services. In this capacity, he oversees all aspects of environmental services opportunities and projects primarily throughout the eastern seaboard and supports on opportunities and projects throughout the U.S.
Floyd Cotter specializes in solid waste management projects. His project work involves all areas of solid waste management including planning, permitting, transportation, landfill design, construction, and monitoring. Floyd is also experienced in general civil engineering, construction oversight, environmental site assessments, closure and post-closure plans, and permit and contract document preparation. Floyd is located in the Central region.
Randy Bauer has nearly 3 decades of experience conducting environmental site assessments, subsurface investigations, groundwater monitoring programs, soil and groundwater remediation, and geotechnical investigations at industrial hazardous waste and solid waste facilities. Randy is available to answer questions on the western seaboard.
An ammonia system that has accurate valve tags, gives detail within facility documentation of SOPs, verifies the accuracy of facility P&IDs, and provides safety measures for operators and contractors for exercising the appropriate valves on the system. Standard operating procedures with proper valve tag placement also helps prevent human error.
Remember, you have the potential to improve safety and minimize risk. A strong training program and accurate operating procedures making a positive impact on worker safety and system operations.
Imagine that one of your employees comes and tells you that a 100-gallon spill just took place at your facility and it is flowing swiftly toward a storm sewer on your property.
Suddenly all eyes are on you. What you do next will show your leadership and skill at addressing the issue and limiting the company’s liability. Are you ready to be the hero, or is spill preparedness the one item that just keeps slipping down your to-do list?
Use the techniques recommended in Chris Jimieson’s latest article to make your spill response training engaging and interactive for staff handling oil. Spill preparedness becomes part of your routine and you’re ready to be the hero if a spill occurs.
Improve Your Spill Preparedness
SCS Management Services™ helps many of our clients’ incorporate economic planning, financial analysis, and feasibility studies into their master planning and have requested copies of our articles. All can be found and filtered by topic area, and we are always ready to help you find the information you need.
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Contact Vita Quinn for more information. Ms. Quinn is SCS Engineers’ National Expert on Solid Waste Finance and Rate Studies. She has 12 years of experience as a financial analyst and management consultant. She has extensive experience working for local government and has developed financial sustainability solutions for various general governments, special revenue funds, and utility enterprise funds. Ms. Quinn has an MBA in Finance and a Bachelor’s Degree in International Economics.
An Exercise in Sound Fiscal Planning: A Rural County’s Public Works Professionals Evaluate Future Solid Waste Service Scenarios, Costs, and Financing Options
Residential Automated Collection Makes Sense for Idaho Falls
The Nuts and Bolts of Implementing a Residential Automated Collection Program
Conducting a Rate Analysis as Part of a Master Plan Study in Killeen, Texas
https://www.scsengineers.com/scs-articles/conducting-a-rate-analysis-as-part-of-a-master-plan-study/
Financial Tools Assist in Completing Cost of Service Studies
Conducting Solid Waste Rate Studies and Business Plans
https://www.scsengineers.com/conducting-solid-waste-rate-studies-and-business-plans/
Get a Firm Handle on Solid Waste Costs to Optimize Performance
https://www.scsengineers.com/get-a-firm-handle-on-solid-waste-costs-to-optimize-performance/
Cash Flow Analysis Forestalls Long-Term Debt
Is Privatization the Answer? You Need to Consider Several Factors Before Making the Decision for Solid Waste Services
https://www.scsengineers.com/publications/articles/page/11/
Developing a Strategic Business Plan for Your Agency
Economic Feasibility 101 – Understanding the Tools of the Trade
Assessing a Solid Waste Agency’s Financial Health
Are Your Rates Correct? Collection and Disposal Rate Studies are a Valuable Tool
Integrating Financial Analysis into Solid Waste Operations Planning
High Costs and Limited Markets Put a Crack in Glass Recycling
Recycling Trends in the United States
https://www.scsengineers.com/scs-articles/6555/
Calculated Decisions: An Engineer’s Feasibility Report Can Help Communities and Financiers Assess the Risk of a Waste Conversion Project
Anaerobic Digester Economics
Give SCS a call or send an email to if you have questions. Find your local office here: https://www.scsengineers.com/locations/. Visit our Solid Waste Planning Services page for additional information, articles, whitepapers, and case studies.
Over years of working on operations and maintenance of landfill gas collection and control systems and leachate management systems, SCS found that too many times data is collected and no one has the time to review and analyze it for improved decision-making.
As an industry-wide issue, SCS developed systems to streamline the process using technology and our field expertise to help perform routine and sometimes complex data analysis and to automatically push reports and alerts to operators, engineers, and project managers.
The improvements are dramatic; by removing human error from reviewing pages of data we now focus our time and energy on what really matters, using what the data tells us to make informed decisions. Let’s put the technology into the context of everyday operations – identify, troubleshoot, and solve landfill gas and leachate challenges.
This SCS paper illustrates several sites using integrated systems for data collection and analysis and how they are used to identify, troubleshoot, and solve real problems in an effective and efficient manner.
Privately share this article using the email icon on the left navigation bar. Print the article using the Download icon just under the article, or your browser commands.
About the Authors:
David P. Hostetter, PE, Denver, Pennsylvania
Phil Carrillo, Huntington Beach, California
Darrin D. Dillah, Ph.D., PE, BCEE, Reston, Virginia
By October 17, 2016, coal combustion residual (CCR) landfills subject to the Environmental Protection Agency’s (EPA) CCR regulations published at 40 CFR 257, Subpart D, also known as the Federal CCR Rule, were required to prepare a Run-on and Run-off Control System Plan. Your plan documents how you have designed and constructed your landfill to prevent storm water from running onto or off the active landfill. But, what’s next?
Have you addressed run-on and run-off control system operation and maintenance?
Spring is a great time to review your storm water control plans and, more importantly, your storm water controls. The snow is gone now and spring rains are on their way, so knowing that your storm water controls are working and water is going where you intend it to go should be part of your spring inspection routine. Don’t want to waste money managing clean storm water with your leachate management system, or put your facility at risk by allowing unintended runoff from the landfill. A few basic inspection tasks will help ensure you don’t.
A spring run-on and run-off control system inspection should include the following:
Don’t let spring rains catch you off guard. SCS Engineers can help you assess the effectiveness of your run-on and run-off control systems. For help conducting storm water inspections as well as studies to review leachate, contact water, and storm water minimization and reuse opportunities, or for questions about run-on and run-off control system inspections or more information about minimization and reuse studies, please contact:
Mike McLaughlin, PE, Senior Vice President
Eric Nelson, PE, Vice President
Steve Lamb, PE, Vice President
Kevin Yard, PE, Vice President
Or, contact your local SCS Engineers office.
Learn more about the author Eric Nelson:
Eric J. Nelson, PE, is a Vice President of SCS Engineers and our National Expert for Coal Combustion Residuals (CCR). He is an experienced engineer and hydrogeologist. His diverse experience includes solid waste landfill development, soil and groundwater remediation, and brownfield redevelopment.
Mr. Nelson has worked with utility clients to complete numerous projects for dry CCR landfills, CCR ponds, and general environmental monitoring and compliance. He has been involved with CCR landfill projects that include feasibility analyses and permitting of landfill expansions; hydrogeologic and geotechnical site investigations; site design and operating plans; soil borrow source identification and permitting; liner and final cover construction liner, cover, and storm water management repairs. He has worked with utility clients to evaluate, plan, permit and complete CCR pond repairs and closures.
Mr. Nelsons environmental monitoring and compliance experience includes groundwater monitoring; oil containment design and construction; and Spill Prevention, Control, and Countermeasure (SPCC) planning. This diverse project experience has provided him the opportunity to work on challenging and innovative projects that have included design and permitting for wetland and stream mitigation, identifying and avoiding former underground mines during site design, and assessing the feasibility of installing a solar photovoltaic system on a closed CCR landfill.
Mr. Nelsons additional areas of expertise include remedial action planning, cost estimating, bidding and construction documents, and construction quality assurance. He has worked with electric utilities, solid waste facility owners/operators, and private property owners and developers.
The Wisconsin Department of Natural Resources (WDNR) initiated a Waste and Materials Management (WMM) Study Group to provide constructive feedback on policy and technical issues. There are also five subgroups assigned to research selected topics and develop recommendations for presentation to the full group.
The study group and subgroups include a mix of regulators, industry representatives, environmental group representatives, researchers/professors, and consultants.
The WMM study group has five subgroups working on along with resources related to the area of study:
Get Involved
Feel free to contact Tom Karwoski or Betsy Powers for more information; active study group members ready to answer your questions and help you get engaged in the WMM.
Did you know Wisconsin has more than 80,000 properties with a history of contamination or remediation? What if you could transform even the most challenged property into a center of economic prosperity? You can with three well-established reimbursement programs.
PECFA
The Petroleum Environmental Cleanup Fund Award (PECFA) program is administered by the Wisconsin Department of Natural Resources (WDNR) and is funded by a petroleum inspection fee. PECFA has provided funding for investigation and cleanup of petroleum contamination from petroleum product storage systems at tens of thousands of properties in Wisconsin since it started in the 1980s.
The WDNR estimates there are more than 100 eligible, enrolled sites that have stalled and are at risk of not being reimbursed for eligible costs. If you have an open PECFA project, and especially if you have a stalled PECFA project, act now or you may lose your funding. The program is closed to new applicants and will sunset on June 30, 2020. No claims will be accepted after this date.
ACCP
The Agricultural Chemical Cleanup Program (ACCP) provides financial assistance for agricultural chemical investigations and cleanups to property owners and people who have caused or own/control spilled agricultural chemical(s). Companies that apply for ACCP funds include ag-chem cooperatives, ag-chem transport companies, farm enterprises, and other ag-chem suppliers and users. Cleanup costs can be reimbursed at 75% of eligible costs between the deductible and the $400,000 discharge site maximum with a proposed increase to $600,000 per site maximum in the Governor’s 2017 budget. To qualify, you typically need a site investigation and remediation by a professional engineer and hydrogeologist.
DERF
The Dry Cleaner Environmental Response Fund (DERF) provides financial protection for Wisconsin dry cleaner owners if contamination occurred from their operations. The program began in 1997 and is funded by fees on dry-cleaning receipts and the solvents used in the dry-cleaning process. The maximum award is $500,000 per facility. DERF is closed to new applicants; however, eligible owners can still receive reimbursements for site investigation and remediation activities. The estimated reimbursement time is two to three years from claim submittal.
Thousands of Wisconsin property owners have used PECFA, ACCP, and DERF to address contamination on their properties. Contact SCS Engineers to learn how you can use these programs to ease your redevelopment costs.
Contacts in Wisconsin:
Ray Tierney, PG
608.216.7332
There is no single best approach to financing fleet replacement costs. With the financial challenges facing local governments today in providing cost-effective and timely solid waste management services, evaluation of these various approaches should be made focusing on ways to minimize costs while providing value-added services to the public.
Marc Rogoff discusses a number of alternative vehicle/equipment purchasing programs, which are being used by solid waste agencies to preserve cash. Each of the financing methods described has its own particular advantages and disadvantages, which can be influenced by local municipal circumstances.
Read the complete article here.
By Chris Jimieson, PE and Jared Omernik, PE
Do you know how much oil and fuel you store in aboveground containers at your facility? If you have more than 1,320 gallons, you may need an SPCC Plan. What is an SPCC Plan? SPCC stands for Spill Prevention, Control, and Countermeasure, and it is a federal rule (40 CFR 112 in the Federal Register) designed to prevent oil-based products from entering navigable waterways of the U.S. But it’s about more than just compliance. It’s an important tool to help you limit your liability.
Facilities covered under the SPCC rule are subject to agency inspections and potential enforcement actions if the facility’s practices are found to be out of compliance.
Does the SPCC rule apply to me?
The 1,320-gallon threshold isn’t the only trigger for an SPCC Plan. One of the keys to take away from the SPCC rule is that it does not count oil/fuel storage in containers less than 55-gallons in size. Another trigger is that a facility must reasonably be expected to discharge oil into navigable waters or adjoining shorelines of the U.S.
The Environmental Protection Agency (EPA) does not define what “reasonably be expected” means. Rather, the responsibility is on the facility owner or operator to determine the potential for discharge. In reality, it’s usually easy to think of a scenario where spilled oil could reach a waterway. Even if you think a spill would never reach the stream, what if there was a significant rain event that washed away spilled oil on the ground through a storm sewer? Often the “reasonably to be expected” is not challenged, so it is best to err on the side of caution.
The SPCC rule applies to my facility, now what?
There are three options: 1) Prepare the plan yourself. 2) Use a third party provider to prepare your plan, or 3) Have a licensed professional engineer develop your plan. The option you choose depends on how much oil you store at your facility and your working knowledge of the SPCC rule.
If you have less than 10,000 gallons of oil and no single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you may be able to prepare your own SPCC Plan, following the EPA’s Tier I qualified facility template.
You can download the EPA’s Tier I qualified facility template here: https://www.epa.gov/sites/production/files/2014-05/documents/tier1template.pdf. The template is the least expensive way to comply with the SPCC rule. However, some users feel it is a little confusing.
If you have less than 10,000 gallons of oil and have a single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you could qualify under the EPA’s Tier 2 qualified facility category. The EPA does not provide a plan template for a Tier II qualified facility. You can still prepare the plan yourself, or you may hire a third party or professional engineer to develop the plan for you.
If your facility has greater than 10,000 gallons of oil storage, you must have a licensed professional engineer prepare your facility’s SPCC Plan.
Working on an SPCC Plan with a Third Party Provider
If you decide to work with a third party provider, here are some things you can expect as part of the process. The provider will conduct a facility site visit to review the oil storage. Prepare to have a staff member familiar with the oil storage escort the provider to each of the sources. The provider will ask questions about spill prevention features at each source location, including secondary containment, overfill protection, and interstitial monitoring, if applicable.
After visiting the oil sources, the provider may ask to see any available tank data such as specifications, current inspection protocol, and tank repair or integrity testing documentation. You can eliminate follow-ups and help keep costs down by having this data available for review.
Following the site visit, the provider will prepare an SPCC Plan that you should review for accuracy before implementation.
The Value of an SPCC Plan for Your Facility
An SPCC Plan is about more than just compliance. An SPCC Plan contains inspection forms and protocols that can help to prevent a spill at your facility. It identifies the single point of contact, an “SPCC Coordinator” for the facility. If there is a spill, the Plan contains steps necessary to contain the spill initially and control the discharge, and the proper contacts to notify internally and externally.
The SPCC rule requires all oil-handling personnel receive annual training to respond appropriately to spills in their work areas. The annual training requirement is another key element to spill prevention, but also covers aspects on how to properly take control and countermeasure actions in the event of an oil spill.
Work with your staff to determine if the SPCC rule applies to you. An SPCC Plan is a required document for certain facilities to help you comply with the SPCC rule and gain the benefits of having a plan in place. However, more than that, it is a practical document that’s designed to assist with training and inspections and to help prevent spills from occurring. Moreover, if spills do occur, an SPCC Plan provides the guidance to help control the spill and limit your liability.
Chris Jimieson and Jared Omernik have more than 26 years’ combined experience helping various types of clients with environmental compliance. Chris and Jared have extensive experience helping customers build and review SPCC and Storm Water Pollution Prevention Plan (SWPPP) projects. For questions about the SPCC rule or how to comply, Contact Chris at
For questions about the SPCC rule or how to comply, Contact Chris at or 608-216-7367, or contact Jared at or 608-216-7348 in the Upper Midwest.
To find an office near you click here.
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