brownfields

January 10, 2024

Calculation of an Alternative Soil Cleanup Target Level Based on Site-Specific Soil Properties

The contaminated site rehabilitation (cleanup) provisions promulgated in Florida are based on Risk-Based Corrective Action (RBCA) principles. This approach to rehabilitating sites combines traditional site assessment with risk assessment principles and site-specific conditions to develop risk management options (RMOs) that meet the client’s objectives and the mandated human-health risk levels. RBCA allows us to tailor our assessment and remediation strategies to the unique characteristics of each site and avoid costs associated with unnecessary environmental assessment or remediation.

The RBCA provisions offer a number of default RMOs to achieve site closure. The most commonly used RMOs include natural background evaluations, total recoverable petroleum hydrocarbon fraction analysis, and synthetic precipitation leaching procedure (SPLP) analysis. One of the lesser-used RMOs includes calculating alternative soil cleanup target levels (ASCTLs) using site-specific soil properties. A downside of this approach is that one of the input parameters, soil moisture content, requires one year of data collection; this is too long for most of our clients (particularly developers). Nevertheless, given the right conditions, this RMO can yield beneficial results by justifying a higher cleanup level without needing a year of data. An example of how SCS has used this approach is below.

Background – SCS calculated a leachability-based ASCTL using site-specific soil properties for a former agricultural site undergoing redevelopment for residential use. We considered this site to be a good candidate for this RMO due to the following site-specific conditions:

• The upper two feet of soil throughout the site was marl, which often exhibits a higher organic carbon content than the default organic carbon content.
• The contaminant of concern (COC) was dieldrin, which has a high organic carbon partition coefficient (Koc), meaning it strongly sorbs to organic carbon in the soil.
• Considering the soil type and target COC, we suspected that soil organic carbon content would be the driving factor in the ASCTL calculation or, in other words, that soil moisture content (the parameter that requires one year of data collection) would contribute very little to the ASCTL.

Data Collection – SCS collected discrete samples from the relevant intervals to obtain site-specific data for the required soil properties. The measured parameters include a fraction of organic carbon, dry soil bulk density, and soil moisture content. Using these measured parameters, SCS calculated the remaining site-specific soil parameters, specifically, the water-filled soil porosity, total soil porosity, and air-filled soil porosity.

ASCTL Calculation – We calculated the ASCTL using the site-specific soil properties and the equation below. The table following the equation presents the default and site-specific soil property input values and the method for deriving the site-specific values. Refer to the DERM Technical Report: Development of Cleanup Target Levels (CTLs) for Chapter 24, Miami-Dade County Code (September 2005) for information concerning the remaining input parameters.

Using the site-specific soil properties resulted in an ASCTL of 0.046 mg/kg, significantly higher than the default leachability SCTL of 0.002 mg/kg.

Sensitivity Analysis – As mentioned above, soil moisture content requires one year of data collection; generally, this parameter is an average of results obtained from four quarterly events (designed to represent variability in moisture content during wet and dry seasons). Since we speculated that organic carbon content is driving the ASCTL, and the client could not wait a year to get approval of the ASCTL, SCS performed a sensitivity analysis of the various soil parameters on the ASCTL calculation. The results indicated that soil moisture content does not impact the ASCTL calculation for dieldrin (at the site-specific organic carbon content), even using the unrealistic scenarios of 0% and 100% soil moisture content. With this finding, we could justify using a single data point for soil moisture content instead of averaging one year of soil moisture data.

Summary – ASCTLs using site-specific soil properties can be calculated for any COC. However, consider several criteria when evaluating the feasibility of this approach, some of which include:

• The target COC – Organic COCs are best suited for this RMO, as the ASCTL calculation is fairly straightforward. While the calculation is not impossible for inorganics (i.e., metals), it is more complex. The partitioning of metals is represented by the soil/water partition coefficient (Kd), as opposed to the Koc for organic COCs. Since various soil conditions significantly influence the Kd, deriving site-specific values involves a rather intricate process.
• Timing – If the project is time-sensitive, it will be important to eliminate the need to collect one year of soil moisture content. Similar to the example herein, under the right conditions, a sensitivity analysis may be used to support the calculation of the ASCTL based solely on organic carbon content. Organic COCs with low water solubility, high affinity for organic matter, and low volatility, coupled with highly organic soils, offer the best scenarios for this.
• Sample collection – The number and placement of soil samples must represent the soil characteristics from each applicable interval across the site.
• Size of impacted area – The default dilution attenuation factor (DF) of 20 represents a source area of 0.5 acres. Therefore, if the area of potentially leachable soil exceeds 0.5 acres, a site-specific DF may need to be calculated, requiring site-specific aquifer hydraulic conductivity, hydraulic gradient, mixing zone depth, infiltration rate, and source length parallel to groundwater flow.

We can also calculate the direct exposure ASCTLs based on site-specific soil properties. Use the soil properties in the volatilization factor portion of the direct exposure SCTL equation; therefore, COCs with a significant fraction of the risk associated with the inhalation route would benefit most from this RMO.

Ultimately, an environmental professional with expertise in environmental assessment, risk assessment, and soil science/geology can help assess whether calculating an ASCTL would be beneficial in meeting your client’s goals. Approval of a higher leachability-based ASCTL can result in significant savings by minimizing or eliminating the need for additional assessment, remediation, or groundwater monitoring.

Environmental Assessment or Remediation References

DERM Technical Report: Development of Cleanup Target Levels (CTLs) for Chapter 24, Miami-Dade County Code. September 2005, prepared by the Center for Environmental & Human Toxicology, University of Florida. Link

Hagan, D., F. Escobedo, G.Toor, H. Mayer, J. Klein, and C. Dobbs. 2010. Soil Bulk Density and Organic Matter in Urban Miami-Dade County, Florida. SL 327. Gainesville: University of Florida Institute of Food and Agricultural Sciences. Link

Nelson, D.W. and Sommer, L.E. (1982) Total Carbon, Organic Carbon and Organic Matter. Methods of Soil Analysis, Part 2. Chemical and Microbiological Properties, 2nd Edition. ASA-SSSA, Madison, 595-579. Link

About the Authors:

Anabel Rodriguez-Garcia is an environmental scientist, with a decade of experience in sustainable management of soil, heavy metal contamination in soils and organic fertilizers, 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 such as Florida Department of Transportation, Miami-Dade County Regulatory and Economic Resources, public utilities, and for the private sector.

Lisa L. Smith has three decades of experience in a variety of roles in the field of environmental science. Lisa serves SCS clients as a senior technical advisor and expert in the field of 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.

Feel free to share this blog using your email or social media account. We’re here to answer questions, across the nation and in your neck of the woods. Contact us at and find more information on our Brownfields and Remediation website.

November 22, 2023

The Community Change Grants Notice of Funding Opportunity (NOFO), administered through the Office of Environmental Justice and External Civil Rights (OEJECR), has several unique characteristics to advance environmental and climate justice, many of which are responsive to feedback and input the agency has heard from communities. The NOFO will be open for a year, closing on November 21, 2024, and the EPA will review applications on a rolling basis. This allows applicants to utilize technical assistance and possibly resubmit a new application if not initially selected. EPA encourages applicants to apply as early as possible.

OEJECR will also host multiple informational webinars while the NOFO is open, with the first being held on December 7, 2023. These webinars will address questions, and some may facilitate the formation of partnerships and information sharing. More information on upcoming webinars can be found on EPA’s Inflation Reduction Act Community Change Grants Program webpage.

Community Change Grants will deliver 100 percent of the benefits of this program to disadvantaged communities that are marginalized by underinvestment and overburdened by pollution. This program also dedicates $200 million of Inflation Reduction Act funding to provide technical assistance to applicants and grant recipients, which will enhance the ability of disadvantaged communities to access resources for environmental and climate justice activities. The activities to be performed under the grants are expected to fall under the following categories:

• Climate resiliency and adaptation.
• Mitigating climate and health risks from urban heat islands, extreme heat, wood heater emissions, and wildfire events.
• Community-led air and other (including water and waste) pollution monitoring, prevention, and remediation.
• Investments in low- and zero-emission and resilient technologies and related infrastructure.
• Workforce development that supports the reduction of greenhouse gas emissions and other air pollutants.
• Reducing indoor toxins and indoor air pollution.
• Facilitating the engagement of disadvantaged communities in state and federal advisory groups, workshops, rulemaking, and other public processes.

Environmental engineers, consultants, and scientists at SCS devise and implement solutions for pollution, energy consumption and emissions reductions, land remediation, water/wastewater treatment, and waste management. For assistance with Community Change Grants, contact or visit SCS’s Brownfields and Voluntary Remediation site.

September 22, 2023

Millions in FY24 Brownfields Grants Available – Deadline for Submissions is November 13, 2023

EPA anticipates awarding an estimated 60 Community-wide Assessment Grants for an estimated total of $30 million, subject to the quality of applications received, availability of funds, and other applicable considerations.

A Community-wide Assessment Grant is appropriate for communities beginning to address their brownfield challenges and for communities with ongoing efforts to bring sites into productive reuse. The project period for Community-wide Assessment Grants is up to four years.

Open EPA Brownfields Grant Funding Opportunities in FY24  — Applications for each are due November 13, 2023

FY 2024 Technical Assistance to Tribal Nations and Entities Addressing Brownfields Grant $4 million, with a $4 m ceiling, one grant expected

FY 2024 Multipurpose Grants $20 million, with a $1 m ceiling, 20 grants expected

FY 2024 Community-wide Assessment Grants $30 million, with a $.5 m ceiling, 60 grants expected

FY 2024 Assessment Coalition Grants  $40 million, with a $1.5 m ceiling, 26 grants expected

FY 2024 Community-wide Assessment Grants for States and Tribes $50 million, with a $2 m ceiling, 25 grants expected

FY 2024 Cleanup Grants $95 million, with a $5 m ceiling, 65 grants expected

The closing date and time for receipt of applications is November 13, 2023, 11:59 p.m. Eastern Time (ET). You must submit applications through https://www.grants.gov/. Please take a look at the Due Date and Submission Instructions in Section IV.B. and Appendix 1 for more instructions.

Please contact your EPA regional support staff or SCS Engineers at for help. We’re happy to help answer questions.

September 19, 2023

About CALRC

It’s time for the California Land Recycling Conference (CALRC) in Carson, California, September 26-28. The Center for Creative Land Recycling (CCLR) is hosting the conference, and this year’s event theme is “People, Partnerships, Progress.”

SCS Engineers is exceptionally proud of our relationship with CCLR and of our clients who are winning Phoenix, EBJ, and other awards for their valuable contributions to their communities across all 50 states.

Environmental Justice

Achieving environmental justice means taking a sustainable, holistic approach to site remediation and land recycling.  One that meets each party’s social, environmental, and economic goals. These experts can help; they’ve been in the business of sustainability for decades and are always open to knowledge sharing about funding, permitting, and remediation processes that will keep your project on track.

Headline Presentations

Should it Stay or Should it Go? In-situ vs. Ex-situ Solutions with Michael McLaughlin of SCS Engineers, Senior Vice President of Environmental Services and National Specialist on Brownfields & Landfill Redevelopment
Tuesday, September 26th at 3:15 PM in the Community Hall Section A

With numerous approaches and examples of pilot studies, innovative technologies, and work done to execute alternatives to excavation, this session will help you overcome the practical challenges of sustainable remediation. With an overview of conducting pilot tests and examples of innovative technologies, this session will help project managers and site owners take the next steps in bringing sustainable solutions to clean up contaminated sites and answer the question, can in-situ technologies be used to avoid costly excavation and disposal?

Getting to the Finish Line: Navigating Projects Through the Water Board Process with Jim Ritchie, Vice President, SCS Engineers.
Wednesday, September 27th at 10:30 am  in the Community Hall Section A

We aim to get your remediation or brownfields project done sustainably, meeting economic and environmental goals such as the mission of the Water Boards to preserve the quality of California’s water resources and drinking water to protect the environment, public health, and beneficial uses. Join Jim and company to learn the best practices.

Gather more information or register for CALRC.

September 5, 2023

It’s time for the California Land Recycling Conference (CALRC) in Carson, California, September 26-28. The Center for Creative Land Recycling (CCLR) is hosting the conference, and this year’s event theme is “People, Partnerships, Progress.” SCS Engineers is a Visionary Sponsor and will have our experts presenting at the conference and discussing best practices for those in California and nationwide. Please stop by our booth to discuss the various land recycling possibilities for your site, funding, and permitting.

We are exceptionally proud of our relationship with CCLR and our clients who are winning Phoenix, EBJ, and other awards for their valuable contributions to their communities across all 50 states.

Achieving environmental justice means taking a sustainable, holistic approach to site remediation and land recycling.  One that meets each party’s social, environmental, and economic goals. These experts can help; they’ve been in the business of sustainability for decades and are always open to knowledge sharing about funding, permitting, and remediation processes that will keep your project on track.

Should it Stay or Should it Go? In-situ vs. Ex-situ Solutions with Michael McLaughlin of SCS Engineers, Senior Vice President of Environmental Services and National Specialist on Brownfields & Landfill Redevelopment
Tuesday, September 26th at 3:15 PM in the Community Hall Section A

With numerous approaches and examples of pilot studies, innovative technologies, and work done to execute alternatives to excavation, this session will help you overcome the practical challenges of sustainable remediation. With an overview of conducting pilot tests and examples of innovative technologies, this session will help project managers and site owners take the next steps in bringing sustainable solutions to clean up contaminated sites and answer the question, can in-situ technologies be used to avoid costly excavation and disposal?

Getting to the Finish Line: Navigating Projects Through the Water Board Process with Jim Ritchie, Vice President, SCS Engineers.
Wednesday, September 27th at 10:30 am  in the Community Hall Section A

We aim to get your remediation or brownfields project done sustainably, meeting economic and environmental goals such as the mission of the Water Boards to preserve the quality of California’s water resources and drinking water to protect the environment, public health, and beneficial uses. Join Jim and company to learn the best practices.

Get more information or register for the California Land Recycling Conference.

August 30, 2023

This year’s National Brownfields Conference in Detroit, Michigan, was notable. The evening before the conference began, the United States Environmental Protection Agency (USEPA) hosted an ‘Environmental Justice’ caucus in which over 150 people from both the public and private sectors came together to learn more about what Environmental Justice is and how it informs our work in economic development efforts.

USEPA defines Environmental Justice (often called ‘EJ’) as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” We’ll achieve this goal when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment to live, learn, and work.

Distilled to its core, EJ is a call to action for all individuals and entities engaged in helping sustain and grow their communities. It posits that multiple demographics (including but not limited to people of color, inhabitants of rural areas, and people with less access to education and well-paying jobs) are disproportionately subject to harmful impacts from exposure to toxins and pollutants. Accordingly, it is incumbent upon those engaged with those populations to pay heed to find ways to mitigate or reduce those exposures.

EPA formally established the Office of Environmental Justice and External Civil Rights on October 6, 2022, and since that time, has engaged over 200 people across the agency to perform tasks specifically addressing EJ, including “processing grant applications from communities with environmental justice concerns, reaching out to residents to understand their concerns, and enforcing civil rights.” The EPA also established the Environmental Justice Thriving Communities Grantmaking (EJ TCGM) program in direct response to two Executive Orders issued by the Biden administration (EO 14008 and 13985) and will soon award ~$550 million to 11 distinct entities (which must be community-based nonprofits or partnerships between community-based nonprofits and either Tribal government or institutions of higher education) to spearhead more inclusive and easily accessible resources/support for communities seeking EPA funding to address EJ concerns.

EPA also established 16 technical assistance centers across the nation under the EJ Thriving Communities Technical Assistance Centers Program (EJ TCTAC), aimed at “providing technical assistance, training, and related support to communities with environmental justice concerns and their partners. The services provided will include training and assistance on writing grant proposals, navigating federal systems such as Grants.gov and SAM.gov, effectively managing grant funds, community engagement, meeting facilitation, and translation and interpretation services for limited English-speaking participants.”

Furthermore, the 2022 Inflation Reduction Act created the Environmental and Climate Justice Block Grant program in section 138 of the Clean Air Act (CAA). It provided EPA with $2.8 billion in grant funding for the program for projects to benefit communities with environmental justice concerns.

All told billions of dollars are currently available to communities that seek to spur environmental cleanup and revitalization efforts. SCS specializes in helping communities connect with this funding (even providing in-house Brownfields grant writing services) and has a proven track record of forming successful partnerships which result in timely and meaningful rejuvenation projects.

Two of the projects SCS teamed on this past year are awardees of the EPA’s prestigious 2023 Phoenix Award. The first of such projects, performed in EPA Region 6, involved the restoration of the historic First National Bank Building in downtown Oklahoma City, OK. This project created a mixed-use space, including apartments in the heart of the bustling business district, to help revive a struggling downtown and create jobs for residents. The second project, performed in EPA Region 9, provided affordable housing in San Diego, CA, and included upgrades to storm drains, water and sewer lines, underground powerlines, and streetscape improvements, significantly enhancing area infrastructure.

In both these projects and countless other projects performed under federal and state Brownfields programs, SCS is a trusted partner providing technical expertise and conscientious approaches to community engagement and planning that align with EJ protocols. SCS is a Foundational Member and Advisor of the Center for Creative Land Recycling (CCLR), which aims to turn abandoned land into thriving spaces that serve communities meaningfully.

This year’s Brownfields Conference theme was “Sustainable Communities Start Here,” in sync with SCS’s long culture and mission of achieving sustainability through holistic processes. The most successful remediation projects are when all stakeholders have a voice and redevelopment efforts are thoughtfully, creatively, and deliberately planned and implemented.

Additional Resources:

• 2023 California Land Recycling Conference
• 2023 Phoenix Awardees – SCS Engineers Supported Clients in Regions 6 and 9
• Brownfields and Voluntary Remediation
• SBA Alert: Lender and Development Company Loan Due Diligence – SOP 50 10 7 Effective August 1, 2023

About the Author: Rachel McShane, LEP, has over 15 years of experience in environmental due diligence projects (Phase I, II and III Environmental Site Assessments) as well as Brownfields redevelopment, risk-based corrective action, and remediation projects. She is also familiar with National Environmental Policy Act (NEPA) environmental assessments, vapor investigations and mitigation, radon, asbestos, and lead based paint surveys, and leachate monitoring/solid waste management. You may reach her at or via LinkedIn.

July 18, 2023

Look for SCS Engineers’ environmental professionals Kirk Blevins and Amy Guilfoyle to answer your environmental questions.

May 29, 2023

SCS Engineers welcomes two experienced environmental consulting professionals to our St. Louis regional office.

Susan Robertson, MBA, is Senior Project Manager. Robertson’s comprehensive environmental due diligence and remedial work rejuvenates prime commercial properties back to health while supporting municipal and private industries’ plans for economic redevelopment.

In the environmental industry for nearly 20 years, Susan has worked on a wide range of consulting projects, including environmental due diligence Phase I and Phase II Environmental Site Assessments. She performs Indoor Air Quality and radon assessments, lead-based paint, and asbestos inspections.

Susan is known for her Brownfield-Voluntary Cleanup Program work under the Missouri Department of Natural Resources¹, Illinois EPA Tiered Approach to Corrective Action, and Missouri Risk-Based Corrective Action risk assessments and historic preservation projects under the Missouri Department of Economic Development².

Julia Hunter is an SCS Project Professional. Julia has five years of experience in environmental consulting, primarily performing environmental due diligence for commercial and telecommunications clients nationwide. She has a Master of Science in Environmental Geoscience from St. Louis University.

Hunter uses the highest standards of care in her due diligence and building sciences investigations, analyzing the data to determine if a property is feasible for its proposed use and future requirements to speed the closure process and ensure no surprises.

“The service these two women perform for our clients is strategic and comprehensive,” states Rachel McShane, SCS – St. Louis project director. “The results of their work help determine the true value of a property before purchase, and if there are any environmental or health concerns, how to remediate them.”

Additional Resources:

• Environmental Consulting – Brownfields | Voluntary Remediation
• Environmental Due Diligence
• Want your work to matter? Join a nationwide team of environmental consultants, engineers, and scientists!

May 24, 2023

SCS Engineers welcomes Melissa Schick to the environmental firm’s Brownfields and Voluntary Remediation practice, which works nationwide, supporting municipal and public/private sector ventures to remediate previously thought unusable properties back to life.

These properties are not exclusively but often found in urban areas with existing supporting infrastructure. New technologies and environmental processes can turn these well-situated properties safe again for almost any redevelopment purpose, whether housing, recreational facilities, retail/office, or logistics centers.

Schick brings her knowledge of state and federal brownfield redevelopment and voluntary remediation cleanup program regulations. She specializes in U.S. Environmental Protection Agency (USEPA) Regions 3, 4, and 6, supporting the grant application process or overseeing the implementation of USEPA assessment and cleanup grants which provide funds for municipalities to redevelop sites.

Since brownfields and voluntary remediation create valuable economic and natural resources for communities, clients find her experience coordinating communications, outreach, and educational events helpful. As this work demands, Schick often focuses on improving the communications between private developers, regulatory agencies, community leaders, and other partners to smooth project implementation, keeping projects on track and within budget.

“Importantly, Melissa is an ethical and caring person whose work in communities matters to her,” states Kirk Blevins, SCS Project Director. “As a local environmental engineering and consulting firm, she enhances our national practice as a detail-oriented resource to augment communications, outreach, and reporting for comprehensive and cohesive project success.”

Schick has professional affiliations with the Florida Brownfield Association – Board of Directors, the Society of American Military Engineers, and the Florida Association of Environmental Professionals.

We welcome you to learn more about Melissa Schick’s work, background, and education in land remediation services on the SCS website.

Additional Resources:

• ‘The land is just too precious:’ The landfill remediation will become a massive nature park in 60 years
• Video Library
• Brownfields and Voluntary Remediation

May 9, 2023

The Center for Creative Land Recycling (CCLR) is hosting its annual California Land Recycling Conference (CALRC) in Carson, California, September 26-28.  This year’s event theme is “People, Partnerships, Progress.” SCS Engineers is a Visionary Sponsor and will have these experts presenting at the conference.

Please stop by our booth to discuss the various land recycling possibilities for your site, funding, and permitting. We are exceptionally proud of our relationship with CCLR, and our clients who are winning Phoenix, EBJ, and other awards for their valuable contributions to their communities.

Should it Stay or Should it Go? In-situ vs. Ex-situ Solutions with Michael McLaughlin of SCS Engineers, Senior Vice President of Environmental Services and National Specialist on Brownfields & Landfill Redevelopment
Tuesday, September 26th at 3:15 PM in the Community Hall Section A

With numerous approaches and examples of pilot studies, innovative technologies, and work done to execute alternatives to excavation, this session will help you overcome the practical challenges of sustainable remediation. With an overview of conducting pilot tests and examples of innovative technologies, this session will help project managers and site owners take the next steps in bringing innovative sustainable solutions to clean up contaminated sites and answer the question, can in-situ technologies be used to avoid costly excavation and disposal?

Getting to the Finish Line: Navigating Projects Through the Water Board Process with Jim Ritchie, Vice President, SCS Engineers.
Wednesday, September 27th at 10:30 am  in the Community Hall Section A

We aim to get your remediation or brownfields project done sustainably, meeting economic and environmental goals such as the mission of the Water Boards to preserve the quality of California’s water resources and drinking water to protect the environment, public health, and beneficial uses. Join Jim and company to learn the best practices.

The U.S. Environmental Protection Agency (EPA) Region 9 and the CA Department of Toxic Substances Control’s (DTSC) Office of Brownfields are co-collaborators of this conference.

Get more information or register for the California Land Recycling Conference.