Executing Brownfield Redevelopment
Green spaces are dwindling rapidly as real estate development forges ahead; meanwhile, a plentiful inventory of brownfields lie idle or underused that have great potential to become vibrant, revenue-generating resources.
Well-executed brownfield redevelopment projects make the most of existing infrastructure, leaving green spaces green. They create jobs and increase property values. They improve the health and safety of the environment and people. And turning former liabilities into neighborhood jewels cultivates a spirit of goodwill among residents.
As developers and governments realize the benefits, old gas stations, defunct factories, and closed landfills are among the properties redeveloped into community parks, retail, industrial, or mixed-use properties to become productive assets.
But while communities and private investors can reap tremendous payoffs, successfully repurposing brownfields can be complicated. They may be laden with hazardous substances and other contaminants from past uses, calling for specialized technical expertise to ensure sustainable environmental and financial outcomes.
Meet Amy Guilfoyle
SCS Engineers’ Amy Guilfoyle has been deeply rooted in brownfield redevelopment work for 20 years, supporting plans to ensure projects are technically sound, on time, and on budget.
Groundwater and soil assessment and remediation are her primary focus. Her job involves more than these essential tasks—from helping local governments apply for U.S. EPA Brownfield assessment and cleanup grants and voluntary cleanup state tax credits to ensuring and documenting regulatory compliance.
When Amy was a new biology graduate, she was not sure exactly what career direction she would choose until she got a full taste of fieldwork with an environmental focus.
“I like working on practical solutions to our clients’ day-to-day problems. And I like the creativity involved in finding and developing the best options in each case. Every scenario is unique, challenging you to keep the wheels in your mind turning,” she says.
Guilfoyle’s work typically begins with a Phase I Environmental Assessment, entailing an inspection of the property and a review of documents to evaluate for potentially hazardous pollutants and contamination. She will move on to a Phase II Environmental Assessment, depending on her findings, collecting and analyzing soil and groundwater samples to determine concentrations, locations, and other details to inform what may become her next course. The results help lead her team in developing and executing a rigorous cleanup strategy to meet regulatory standards.
The practiced brownfields veteran has her work cut out for her, especially on her dedicated turf; the state of Florida, whose groundwater and soil quality standards are even more rigorous than the U.S. EPA’s. Guilfoyle must not only stay on top of stringent regulatory demands but know how to strategically approach complex challenges tied to the region’s unique physical conditions.
“For one, as we monitor and plan remediation, we consider soil characteristics. Like much of the Southeast part of the country, Florida is sandy, making it easier for contaminated water and materials to move through the ground than in rocky areas,” she explains.
“Additionally, we give careful thought to the fact that the water table is shallow, which means saturated soil is close to the land surface, increasing the risk for groundwater contamination.”
Protecting groundwater is the most meaningful work she can do in her eyes.
“Keeping groundwater clean is so important to our public health and safety, as it is the major source of drinking water,” Guilfoyle says.
Sizing up cleanup options
In determining the best method to tackle soil and water impacts, she considers multiple variables: regional standards, the proposed use of the property, and clients’ overall goals.
Every success story hinges on protecting human health and the environment while keeping an eye on the bottom line—economics.
“Our clients are taking on huge projects that can have substantial cleanup costs. Our priority is to develop solutions that limit their out-of-pocket costs and liability. But doing it more effectively, so the outcome is a rich resource that serves communities well into the future,” Guilfoyle says.
A solid understanding of regulations is key to delivering sound technical and financially feasible outcomes.
She exemplifies this, beginning with a recent approach involving removing contaminated soil and using the nonimpacted soil as part of a pond construction to expand stormwater holding capacity.
“In this scenario, you save on the cost to transport hundreds of tons of soil and put it to use to build out existing infrastructure. Also, fewer trucks are coming in and out of the site, mitigating a nuisance and greenhouse gases.
“In other scenarios, we have been able to negotiate cleanup levels above the standard by providing documentation to show they are sufficient for full compliance.”
Forging industry relationships through professional engagements
Guilfoyle knows the agencies well through her work at SCS and professional engagements beyond.
Among her involvement, she’s a board member of the Florida Brownfields Association (FBA), supporting educational and outreach efforts and legislative initiatives to secure funding for cleanup projects.
She serves on the Florida Association of Environmental Professionals (FAEP) board, reporting business activity to local chapter members.
She lends her expertise as a board member for Metropolitan Environmental Training Alliance (METRA), promoting free and low-cost training on hazardous waste management requirements and other environmental regulations.
Outside her leadership roles in industry organizations, she finds time for her passion—telling others about the environmental industry. She has been involved with teaching Boy Scouts and Girl Scouts at Science, Technology, Engineering, and Mathematics (STEM) events and introducing college students to job opportunities in these disciplines.
“It’s important to provide a real role model in science and introduce youth to the wide range of job opportunities. We need more sharp young minds. And we especially need more women in environmental sciences,” Guilfoyle says.
“We have done good work. But we have more ahead of us. We will continue making progress by increasing youths’ awareness of what we do and why we do it–and by educating and supporting industry organizations.”
Brownfield Redevelopment Resources, Funding, Careers:
On December 5, 2022, the EPA released a memo providing direction under the NPDES permitting program to empower states to address known or suspected discharges of per- and polyfluoroalkyl substances (PFAS). Note that the list of Applicable Industrial Direct Discharges (page 2, paragraph A.1) includes landfills. The memo cites state programs in Michigan and North Carolina that other states may want to replicate. These approaches and others could help reduce PFAS discharges by working with industries, and the monitoring information they collect, to develop facility-specific, technology-based effluent limits.
As stated in its memo, the EPA’s goal is to align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges.
The Agency hopes to obtain comprehensive information by monitoring the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS. The EPA will need this information since new technologies and treatments are in development but remain unproven to work successfully in specific industries.
Other proposed actions by the Agency include designating two PFAS as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances and an order under EPA’s National PFAS Testing Strategy requiring companies to conduct PFAS testing and nationwide sampling for 29 PFAS in drinking water starting in 2023.
In a letter to Congress, SWANA and NWRA associations request that regulation under CERCLA for addressing PFAS contamination assign environmental cleanup liability to the industries that created the pollution in the first place. Both associations note that landfills and solid waste management, an essential public service, do not manufacture nor use PFAS. Therefore, the general public should not be burdened with CERCLA liability and costs associated with mitigating PFAS from groundwater, stormwater, and wastewater.
Resources:
We are deeply saddened by the passing of our founder Tom Conrad, but we celebrate his spirit by continuing the culture he established at SCS Engineers. Tom was energetic, creative, hard-working, and fun-loving! His accomplishments in preventing and mitigating environmental damage are just one of the reasons we respect him so much.
Another reason is that Tom believed in providing opportunities for everyone. He founded and ran SCS based on giving individuals the tools they need to thrive while providing for their families, the environment, and their communities. These tools are trust, mentorship, and open dialog. By building these philosophies into our culture, Tom sparked multiple innovations and environmental solutions by some of the finest people you’ll ever want to meet.
These SCSers continue our culture of caring and listening. Anyone at SCS can contribute their ideas for improving a process or technology. Our executives promote forums to keep the conversations and idea exchanges going and open to all. And just as Tom would insist, innovations are proven before they are implemented.
We’re proud of all SCSers, especially our young professionals, who consistently bring in fresh ideas and perspectives by asking “why and how” questions. Designing sustainable environmental solutions requires a deep understanding of systems, processes, and industry knowledge. Asking the right questions and seeking answers indicates a curious mind; Tom called these people “thinkers,” one of the best compliments we could get. Asking these questions indicates a self-actualized mind. And answering the questions takes a team. At SCS, we encourage both.
SCS’s mentorship and young professionals programs are thriving. They were established more formally in the last decade but have always been a part of SCS. President and CEO Jim Walsh called Tom “The best mentor anyone could ever have,” going on to say that Tom “taught me a lot, but more, he let me figure things out on my own… I’ve often said that my best four years of education were not high school or college; it was learning from Tom Conrad.”
SCS’s culture survives because of trust. So as Tom did, we continue to place trust and confidence in SCS’s employee-owners. Tom understood long ago that trust creates a culture of teamwork and respect, enabling effective problem-solving. In fact, Tom was so proud and confident in the firm’s environmental accomplishments in 1987 that he modified the company’s Employee Stock Ownership Plan to expand ownership of SCS to all employees. Today SCS remains 100% employee-owned and is a driving force for SCSers to deliver high-quality and ethical solutions to our clients.
Tom’s other major and no less important philosophy was to “have fun!” We take the time to engage and laugh with our colleagues, clients, and associates.
Our nationwide offices are busy year-round helping their communities, especially during the holidays. A special thanks to our young professionals, who think BIG, for organizing our annual Feed America campaign, always with a healthy, fun competition between our offices!
You can learn more about how SCS continues in Tom Conrad’s spirit today by watching this short video made by SCSers coast to coast.
The announcement of new developments, especially new housing, is always welcome, given nationwide shortages. Wood Partners recently spoke of its Alta Cuvee project in Rancho Cucamonga, CA., an area experiencing high growth rates. With the construction currently underway, the community plans to open in late 2024.
Careful development companies follow all environmental guidelines set forth by local, state, and federal agencies to ensure sustainability. At the Alta Cuvee project, SCS Engineers performed a Phase I Environmental Site Assessment, ensuring due diligence on the part of Wood Partners.
Today’s commercial real estate 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.
When looking for a new home, look for reputable companies that perform due diligence. When looking for environmental due diligence services, look for engineers and consultants providing comprehensive services for the welfare of future tenants, owners, and your firm’s reputation.
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.
Learn more:
EPA intends to update and expand its November 2021 oil and gas regulation proposal by reducing methane emissions and other harmful air pollution from new and existing oil and natural gas operations. The Agency has issued a supplemental proposal adding proposed requirements for sources not previously covered.
Registration is open for EPA’s virtual public hearing impacting hundreds of thousands of existing oil and gas sources nationwide. The Agency states it will promote innovative methane detection technologies and other cutting-edge solutions which are being developed.
Hearing information:
To register to speak or to watch a live stream of the hearing on both days, please visit EPA’s website for the supplemental proposal.
The registration deadline is January 5, 2023. See instructions for submitting a written comment.
In December, the SCS Madison office hosted the Great Lakes Graphics Association’s “Women in Print” luncheon and program. The purpose of this group is to bring together “women working in a man’s world” and give them a space to share experiences, offer coaching and advice, and share examples with women of all ages. The group motivates and encourages each other to push past old gender norms and share experiences with women of all ages. It was wonderful that SCS hosted 17 women from their early 20s to women in their late 60s who were among the first to call print shops their employers.
Environmental sustainability is part of many printers’ business models. The network and GLGA provide opportunities to discuss best practices for moving in a green direction, addressing critical regulatory issues, and environmental reporting — while having many minds contributing great ideas and proven solutions.
This was the 5th meeting of the group, and we’re proud to host them, as it is challenging to find safe places to meet during COVID, RSV, and flu season. Cheryl Moran spoke about how she grew up in print, from her coursework in college to her first job as a secretary in a print house to her evolution as an environmental, health, and safety trainer, manager, and director. She continues to offer her expertise to printers across the US while she trains and develops her team here at SCS.
It was wonderful to see everyone, especially after being virtual for so long. We look forward to hosting more Great Lakes Graphics Association events and opening our doors even wider in 2023. If you are interested in joining us, you can contact Cheryl Moran.
Resources:
On December 5, 2022, the EPA released a memo providing direction under the NPDES permitting program to empower states to address known or suspected discharges of per- and polyfluoroalkyl substances (PFAS). The memo cites state programs in Michigan and North Carolina that other states may want to replicate. These approaches and others could help reduce PFAS discharges by working with industries, and the monitoring information they collect, to develop facility-specific, technology-based effluent limits.
As stated in its memo, the EPA’s goal is to align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges.
The Agency hopes to obtain comprehensive information by monitoring the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS. The EPA will need this information since new technologies and treatments are in development but remain unproven to work successfully in specific industries.
Other proposed actions by the Agency include designating two PFAS as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances and an order under EPA’s National PFAS Testing Strategy requiring companies to conduct PFAS testing and nationwide sampling for 29 PFAS in drinking water starting in 2023.
In a letter to Congress, SWANA and NWRA associations request that regulation under CERCLA for addressing PFAS contamination assign environmental cleanup liability to the industries that created the pollution in the first place. Both associations note that landfills and solid waste management, an essential public service, do not manufacture nor use PFAS. Therefore, the general public should not be burdened with CERCLA liability and costs associated with mitigating PFAS from groundwater, stormwater, and wastewater.
Resources:
Illinois EPA Environmental Justice Procedures
The Illinois EPA Bureau of Air recently implemented more stringent procedures for securing an air permit for a new emissions source or emissions unit when the operations are located in, or within a mile of, an Environmental Justice area. How long the new procedures will remain in effect is not known, but any increase in air emissions will subject the project to more extensive review by the Illinois EPA and possibly the United States Environmental Protection Agency (USEPA) Region V, which could extend the permit application review by a substantial amount of time. Depending on the location of the source, the type and amount of the pollutant(s) being emitted, and the amount of interest or objection by interested parties, there is also a chance that the permit may not be approved. Interested parties include, but are not limited to, local activists, local government agencies, neighboring citizens, and other entities with an interest in Environmental Justice (EJ).
Assuming a permit with a net increase in emissions is approved, it will likely include the following elements.
Illinois EPA is recommending that a company seeking to construct and operate a new or modified source, or add a new emissions unit to an existing source, identify ways within the plant to lower air emissions of the applicable air contaminant(s) such that the project will not result in a net emissions increase. Illinois EPA is not expecting a source to conduct a formal netting exercise, but instead suggests considering product substitutions such as alternative cleaning solutions with low or no volatile organic material (VOM) or hazardous air pollutants (HAPs); for instance, a mixture of acetone and water, or detergents. Other approaches may include the installation of add-on pollution control equipment, use of cleaning solutions with low vapor pressures which evaporate more slowly, capturing some of the VOM in shop towels and cleaning rags rather than emitting them to the atmosphere, installation of recovery equipment (e.g., distillation equipment), and considering other raw material substitutions or equipment replacements.
When an air permit application is submitted to the Illinois EPA for a proposed project that does not result in a net emissions increase, the application will be processed by the permitting department, and then a draft permit will be forwarded to the EJ group at Illinois EPA. The EJ group will forward a copy of the draft permit to interested parties specific to that EJ area. If no comments are received within two weeks, the permitting group will issue a draft permit to the permittee for review and comments. Any substantive comments received from interested parties will be addressed by the Illinois EPA, and this process could cause delays, particularly if a public hearing is requested and granted.
Environmental Justice Background
The USEPA defines environmental justice 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.” Environmental justice was originally established by Title VI of the Civil Rights Act of 1964, which prohibits recipients of federal financial assistance (states, grantees, etc.) from discriminating against these populations in any program or activity. The scope of Title VI was expanded by Executive Order 12898 by President Clinton on February 11, 1994. Executive Order 12898 was issued to direct federal agencies to incorporate achieving EJ into their mission, and to identify and address, as appropriate, disproportionally high adverse human health and environmental effects of their programs, policies, and activities on minority and low-income populations. More recently, President Biden issued Executive Order 14008 Tackling the Climate Crisis at Home and Abroad on January 27, 2021.
Illinois EPA has adopted policies and procedures to conform to Title VI of the Act and Executive Orders 12898 and 14008. According to Illinois EPA, “environmental justice is the protection of the health of the people of Illinois and its environment, equity in the administration of the State’s environmental programs, and the provision of adequate opportunities for meaningful involvement of all people with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”
EJ areas in Illinois are derived from US Census Block Groups where the population consists of a substantial amount of minorities and/or the area is heavily populated by persons and families living below the poverty line. Further information on how EJ areas are established can be found at Illinois EPA EJ Start (arcgis.com), which also includes a map identifying all EJ areas in the state.
About the Author: Ann O’Brien is a Project Manager at SCS Engineers with 33 years of experience in the printing industry. She assists companies with air, water, and waste management; EPCRA; environmental compliance audits; and Phase I Environmental Site Assessments.
For more information or assistance with identifying ways to lower air emissions or help with maneuvering through the air permitting process at Illinois EPA, contact Ann O’Brien () in Chicago, IL, or Cheryl Moran () in Milwaukee, WI. For assitance in other states please contact .
Agricultural growing and harvesting operations are typically exempt from air planning, permitting and odor nuisance regulations. However, cannabis operations may require approval from the local Planning Commission. They may also require air permits from the local air regulatory agency for manufacturing operations (e.g., for solvents and associated combustion equipment such as boilers). Air permit applications for cannabis manufacturing operations may include the following based on project-specific conditions:
In addition to these permitting services, and to avoid costly nuisance complaints, cannabis growers may also need odor-related services such as:
While these may seem like imposing lists for air planning they are not for engineers who work in the industry.
Developing effective plans to mitigate odors is vital in gaining Planning Commission approvals which often depend upon resolving concerns raised by the public. Comprehensive OAPs and OMPs include odor control Best Management Practices (BMPs) and adaptive management strategies for responding to odor complaints when cannabis operations are near residences and schools.
Odor Control – Odor Nuisance Mitigation Case Study
Cannabis greenhouses in the Carpinteria, California region were causing off-site odor nuisances at nearby residences. The inherent smell needed addressing, as odor-neutralizing vapors along cannabis greenhouse perimeters and ridgelines were not providing adequate odor control.
Working with Cannabis Association for Responsible Producers (CARP) Growers, Pacific Stone, Groundswell, and Envinity Group, SCS Engineers utilized its air quality and odor expertise to collect continuous measurements using our SCSent-i-PED (Pollutant and Environmental Data). SCSent-i-PED is a state-of-the-art method for measuring TRS compounds to the parts per billion (ppb) level. The system can assess concentrations in real time, and a single machine can assess multiple locations and sources within a facility. This method successfully assessed relative odor levels and spatial/temporal fluctuations in odor-causing emissions.
Data collection is vital and useful to:
SCS, through its years of experience in air quality and odors, provides cost-effective, sustainable solutions that enable greenhouses and facilities to coexist in urban and suburban environments. Our clients not only get solutions, but they also have the data and science to understand better how odors behave and vary within a cannabis greenhouse.
To learn more, watch a video about air planning and managing greenhouse odors at https://www.scsengineers.com/services/clean-air-act-services/odor-monitoring-and-control/
About the Author: Paul Schafer is a Vice President and Project Director at SCS Engineers and the firm’s National Expert on Ambient Air Monitoring. During his technical career, Paul has assumed key roles in several nationally significant monitoring efforts. He has in-depth experience interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and continuous process monitors, which SCS operates for our clientele. He has had direct working experience with multiple local, state, and federal agencies regarding monitoring programs and air quality impact assessments. As with all solutions at SCS, cost control management and defensible technical performance are primary goals integral to all sustainable monitoring programs.
In its October 28, 2022, meeting, the Virginia Waste Management Board voted to adopt changes to the Virginia Solid Waste Management Regulations known as Amendment 9. Amendment 9 was initiated several years ago, and the amendments address issues that have arisen since the previous amendment. The changes involve updated standards for siting, operation, and monitoring of landfills as well as revising exemptions for open burning of waste. Following adoption by the Board, the amendment is now undergoing Executive Branch Review.
Some of the key changes that are part of this amendment include the following:
Follow SCS Engineers on your preferred social media channel for additional details, or contact us at .
About the Authors:
Josh Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He supports LFG engineering projects involving remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Mike Mclaughlin, PE, JD, is SCS Engineers’ Senior Vice President of Environmental Services. He is a licensed engineer and attorney with over 40 years of professional experience providing advice on environmental matters. He is an expert on environmental compliance, remediation, and allocation of response costs. He is a member of the Board of Governors of the Virginia State Bar Environmental Law Section, and Budget Officer of the American Bar Association’s Section of Environment, Energy and Resources (ABA SEER).
