Brownfield Coalition of the Northeast Articles and Resources from BCONE Sponsors

Fast-Track Assessment of Vapor Intrusion Risk at Brownfields Properties

Fri, 10 Apr 2026 14:45:13 GMT

By David Shea, P.E.

Environmental due diligence for potentially contaminated properties should include an assessment of vapor intrusion risk, among other environmental concerns. Vapor intrusion is defined by U.S. EPA as the migration of hazardous vapors from any subsurface contaminant source, such as contaminated soil or groundwater or contaminated conduits, into an overlying building or structure through any opening or conduit. [1] The ultimate concern with vapor intrusion is the potential for human exposure to hazardous vapors in indoor air. Figure 1 illustrates potential vapor intrusion pathways from subsurface contamination.

Vapor intrusion has been a recognized human exposure risk since the 1980s, with concerns centered on radon entry into homes and schools. Radon is a colorless, odorless, radioactive gas that is naturally occurring in soil in many parts of the United States. The awareness of radon intrusion foreshadowed concerns associated with properties containing subsurface vapor-forming chemicals (VFCs). Some common VFCs responsible for vapor intrusion are: perchloroethylene (PCE), often associated with dry cleaner releases; trichloroethylene (TCE), often found at industrial sites; and benzene, often connected to hydrocarbon releases. Since these VFCs and others may also be found in consumer products, distinguishing vapor intrusion from indoor sources of air quality concerns can be an investigation challenge.

Most states, in addition to U.S. EPA, have published technical guidance for assessing and mitigating vapor intrusion. [2] Potential vapor migration (i.e., the movement of hazardous vapors in the subsurface) is included in the scope of an ASTM E1527-21 Phase I Environmental Site Assessment, [3] while ASTM E2600-22 is a guide for evaluating vapor encroachment, defined as the presence of contaminated vapors at a subject property due to an on-site or off-site release. [4]

Conventional Assessment Approach Takes Time

Despite the long-standing awareness of vapor intrusion risk and its inclusion in the scope of property transaction due diligence, as well as the thousands of properties that have been identified with potential vapor intrusion concerns, little has changed or improved over the past two decades in the methods typically used to investigate and test most of these sites. The conventional vapor intrusion assessment approach is to collect samples of soil vapor from either below a building (termed sub-slab vapor samples) or from outside the building footprint (termed exterior soil vapor samples), oftentimes in combination with indoor air samples. The samples are then sent to a laboratory for analysis of volatile organic chemicals (VOCs). The steps are often repeated to address data gaps or new questions arising from the initial results. With laboratory wait times of several weeks, followed by data analysis and reporting, this can be a drawn-out process if multiple sampling events are required to address uncertainties and data gaps – an undesirable situation when human health, environmental impact, and business interests in the property are in question.

Furthermore, vapor intrusion is an inherently highly variable and structure-specific phenomenon as reflected in highly variable VOC concentrations in indoor air over periods ranging from hours to months. [5] A single, conventional sampling event is unlikely to provide an accurate representation of the vapor intrusion risk. Thus, many states require multiple sampling events across different seasons, including the winter in the northeast when vapor intrusion is more likely to occur due to the stack effect (i.e., when indoor-outdoor temperature differences drive indoor convection currents that favor drawing soil vapor into a structure). As a result, a vapor intrusion investigation that adequately assesses the indoor air exposure risk can take months to years using conventional methods.

Adaptive Investigations Using Real-Time Analysis

To accelerate and improve the efficiency of vapor intrusion assessments, a leading approach is to employ field instruments that can analyze samples of soil vapor and indoor air in real time as opposed to waiting for laboratory results. The Interstate Technology Regulatory Council (ITRC) recently published a Fact Sheet on the use of real-time monitoring for vapor intrusion assessment. [6] Real-time sample analysis supports adaptive, high-confidence investigations, whereby the initial results guide investigators, while they are still in the field, on where to collect supplemental samples to address questions that arise from the initial results. Near-continuous, real-time analysis at stationary locations over a day or more can reveal underlying variability in VOC concentrations.

Rapid on-site testing also allows for the analysis of many more samples, more than 100 per day depending on the instrument, at lower cost per sample than conventional laboratory analysis. Lots of quick, inexpensive data offers opportunities to identify patterns and variability in the results, which are likely to lead to faster insights into the sources and pathways of the vapor intrusion risk and inform potential mitigation solutions. Real-time analysis can also help identify indoor sources of VOCs by allowing for targeted sampling near suspected indoor sources, as well as facilitate more sophisticated investigation methods, such as building pressure cycling to distinguish vapor intrusion from indoor sources of VOCs. [7]

Instruments and analyzers capable of providing real-time results range from total VOC analyzers, such as hand-held photoionization detectors (PIDs), to equipment capable of analyzing and reporting individual VOCs, such as portable gas chromatographs (GCs), which are often coupled with various detectors or mass spectrometers (MS). This equipment is available for rental or purchase from manufacturers or vendors of environmental instruments. Figure 2 shows some examples of real-time analyzers deployed in the field.

The accuracy and detection limits of field analyzers for individual VOCs continues to improve, which is important because certain VOCs, such as PCE and TCE, have very low indoor air screening level concentrations established by U.S. EPA and most states. The instruments are sufficiently rugged so that they can be moved between sampling locations by hand or on a cart. Alternatively, the instruments can be set up in a stationary location in the field and the samples brought to the instrument for analysis using a sampling syringe or sampling bag.

Overcoming Limitations

Purchasing or renting field instruments for vapor intrusion assessment is typically a cost adder to the conventional approach of collecting samples and sending them to a laboratory for analysis. However, the cost per sample decreases with every sample analyzed using real-time instruments; thus, the overall cost of the investigation is likely to be lower as a result of obtaining more data in a single field event, and by reducing or eliminating the need for multiple field campaigns to obtain sufficient data to appropriately evaluate the risk. A recent vapor intrusion assessment of a 10,000-square-foot industrial building using real-time analysis was completed at about a third of the cost of the conventional approach. The cost savings were achieved by completing the real-time investigation in one mobilization as compared to the conventional approach, which would likely have required three or more sampling events to identify the vapor intrusion pathway.

Another potential limitation is that field instruments can be susceptible to loss of accuracy or malfunction that is difficult to diagnose and trouble-shoot without specific expertise. To ensure consistent data quality, real-time analysis should include calibration checks at the beginning and end of each day at least, or after obtaining a high-level reading. This requires having a gas standard on hand with a known VOC concentration to test the accuracy of the instrument within the concentration range of interest.

Real-time analysis of soil vapor and indoor air samples using field instruments may be considered by regulators to be “screening” data that does not completely replace conventional sampling for vapor intrusion and other environmental investigations. Nevertheless, most regulators have embraced real-time vapor intrusion assessments because of how quickly health risks can be evaluated and mitigated if warranted. Even though conventional laboratory sample results are still likely to be required by regulators to support final decisions and approvals, the number of such samples and associated costs can be drastically reduced by doing most of the investigation using real-time analysis.

Closing

Like investigations of soil or groundwater contamination, vapor intrusion assessments can potentially prolong schedules for mitigation and reuse of contaminated properties. Fast-track assessment using real-time analytical instruments is a way to streamline vapor intrusion investigations as compared to conventional approaches that rely on collecting samples, oftentimes over multiple site visits, for laboratory analysis. Limitations of real-time analysis include the cost and reliability of using field instruments, but these are typically outweighed by rapid, higher resolution assessments that can lead to lower overall investigation costs.

References

[1] U.S. EPA, OSWER Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air, June, 2015.

[2] Eklund, B. et al., Overview of State Approaches to Vapor Intrusion: 2023 Update, Groundwater Monitoring & Remediation, February 7, 2024.

[3] ASTM E1527-21, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, December 21, 2021.

[4] ASTM E2600-22, Standard Guide for Vapor Encroachment Screening on Property Involved in Real Estate Transactions, May 18, 2022.

[5] Holton C. et al., Temporal Variability of Indoor Air Concentrations under Natural Conditions in a House Overlying a Dilute Chlorinated Solvent Groundwater Plume, Environmental Science & Technology, Vol. 47(23), 2013.

[6] ITRC Vapor Intrusion Toolkit, Real-Time Monitoring Fact Sheet, January 2026.

https://itrcweb.org/vapor-intrusion-toolkit.

[7] Guo, Y. et al., Development and Validation of a Controlled Pressure Method Test Protocol for Vapor Intrusion Pathway Assessment, Environmental Science & Technology, Vol. 54(12), 2020.

The Author:

David Shea, P.E. is a Senior Vice President at Sanborn, Head & Associates, Inc. based in Bedford, NH, where he has led vapor intrusion assessments and mitigation for commercial, industrial, and residential buildings for more than 25 years.

Six Regulators, One Project: the Acton Superfund’s Guide to Brownfield Solar Permitting

Tue, 24 Mar 2026 14:50:56 GMT

by Prateek Tare, Co-Founder & Executive Vice President, Distributed Energy Infrastructure

The business case for brownfield solar redevelopment is well-established: idle contaminated land, ITC benefits, and, in several Northeast states, a state policy environment that actively incentivises putting solar on sites nobody else wants.

What gets discussed less is what it actually takes to navigate the regulatory gauntlet between a viable site and a permitted, constructed project. Having recently completed a 4.9 MW AC solar and battery storage installation on a former W.R. Grace Superfund site in Acton, Massachusetts, I want to offer a frank account of what that process looked like, and what we learned from it.

Six Regulators, One Project

A standard distributed solar project already requires a long, multilevel permitting process. On brownfield sites, that complexity is squared. For a Superfund site like Acton, the process involved half a dozen distinct regulatory stakeholders:

● The E.P.A.

● The Massachusetts Department of Environmental Protection

● The Acton Planning Board & Building Department

● The Board of Health

● The Conservation Commission

● W.R. Grace, the landowner, which operates an adjacent active facility

None of these stakeholders, or their demands, are unreasonable. Each has a legitimate interest in ensuring that solar construction on a capped contamination site doesn't disturb what was carefully contained.

But half a dozen approval processes from different federal, state, local, and private agencies did mean that their requirements didn’t always align, their review cycles didn't coordinate, and my EPC team was the one entity responsible for synthesizing all of them into a single coherent plan.

The result of that synthesis was a project-specific site health, safety, and quality management plan that addressed all agencies' requirements in a single document. Getting that document approved — before any construction activity could begin — took roughly twice as long as pre-construction permitting on a comparable greenfield project. We recommend that any developer or financier evaluating a brownfield (especially a Superfund) site factor that extended timeline into their schedule from day one.

Regulatory Inertia: When Managing Asbestos Is Faster than Documenting It

One of the more frustrating realities of multi-agency brownfield permitting is that the pace of review is largely outside anyone's control. Each agency manages many obligations with limited bandwidth, and may end up reviewing a particular submission once a week. A question comes back; you answer it; you wait another week. Multiply that across six agencies, and even a well-prepared response to an unexpected finding can consume months.

We encountered this during Acton’s construction, when the team found asbestos approximately two inches below the surface in one area of the site. The affected zone was small, roughly a 10-by-30-foot rectangle. Developing and securing approval for the remediation plan took 8 months, from discovery in November 2024 to approval in May 2025.

The actual remediation work, once approved, took 2.5 days.

That ratio isn’t an anomaly on Superfund sites; it’s just the nature of building on formerly hazardous land. Understanding this from the beginning, rather than treating it as a problem to be solved, enables a project team to plan around longer review times effectively.

Contingency Planning as Regulatory Strategy

The way to manage regulatory inertia is not to try to speed it up; it’s to anticipate it. On Acton, we’d already developed contingency protocols before breaking ground for a range of scenarios, including:

● Encountering contaminated soil

● Finding asbestos

● Monitored air quality exceeding safety thresholds

These plans were pre-submitted and pre-approved. So when the asbestos was found, we weren’t starting a regulatory process from scratch; we were activating a plan that already existed in the agencies' files.

Our preplanned approach also allowed construction in other areas of the site to continue safely in parallel, while the asbestos remediation plan worked through the approval process. So we didn’t have to wait eight months to make progress on the site; the delay was contained to a single zone rather than stopping the project entirely.

The same logic applies to the day-to-day construction activity on a capped site. Environmental scientists were on site continuously during any soil disturbance work, with authority to stop activity immediately if monitoring thresholds were triggered. Having that protocol embedded in the approved health and safety plan — rather than improvised in the field — is what kept the project in good standing with every agency throughout construction.

When the EPC Gets Involved: the Earlier, the Better

On Acton, my EPC team came in when the developer, Syncarpha Capital, had completed about 80% of the site's permitting. That was the right moment to add EPC-specific construction expertise to the remaining approvals, as we were able to shape several conditions to make construction more efficient.

On a standard project, design flexibility late in development is a minor inconvenience. On a Superfund site, it can be a significant cost driver. Road routing, equipment placement, foundation system selection, and electrical infrastructure pathways all have environmental implications that agencies will scrutinize, and changes to approved plans require the same multi-agency review cycle as the original submission.

Getting EPC input earlier in the development process, before permitting locks in specific construction approaches, produces better projects and fewer costly mid-course corrections.

Engineering Decisions Are Regulatory Decisions

One thing that becomes clear quickly on contaminated sites is that engineering and regulatory strategy are inseparable. Every design choice has a regulatory implication, and the agencies are paying attention to the details.

On Acton, our decision to use helical screw foundations (rather than traditional driven piles) allowed us to explain to regulators how each foundation penetration would minimize dust exposure, limit disturbance to the immediate zone, and leave no open bore. The decision to route all electrical infrastructure above grade was also a regulatory argument as much as an engineering one: no trenching, no soil exposure, no unknown material encountered.

Presenting these choices clearly and proactively, rather than waiting for agencies to ask questions, significantly accelerated review. Regulators are more confident in approving plans that show the developer has already thought through their concerns, than plans that require back-and-forth to address those issues.

A Replicable Model and Growing Opportunity

The Acton project interconnected with Eversource in summer 2025, in budget and on schedule. The town of Acton now collects property tax revenue from a parcel that was previously a net liability. W.R. Grace receives lease income. The project is being featured in an EPA newsletter as a replicable model for Superfund solar development — which, practically speaking, means this regulatory approach is one EPA considers worth repeating.

There’s no shortage of similar sites across the Northeast. While the regulatory complexity is real, it’s also navigable. The projects that succeed aren’t the ones that find ways around the process — they’re the ones that treat regulatory engagement as a core competency, plan for what they cannot predict, and get the right expertise involved before decisions get locked in.

The Author:

Prateek Tare is Co-Founder of Distributed Energy Infrastructure LLC (DEI), an EPC firm specializing in utility-scale solar, battery storage, agrivoltaics, and brownfield redevelopment. DEI's founders have collectively completed 50+ brownfield solar projects across the U.S.

Performance and Persistence Differences Between Abiotically- and Biotically-Generated Mackinawite-Structured Iron Sulfides

Fri, 27 Feb 2026 21:11:24 GMT

Derek A. Pizarro¹ , Thomas P. McCullough² , Gary J. Meyer²

1. INTRODUCTION

The introduction of reactive iron species for treatment of inorganic contaminants is well known, yet the efficiencies of these various irons – zero valent iron (ZVI), ferrous or ferric sulfate, and iron sulfides, differ greatly in reactivity, efficiency, and cost. One group of reactive iron species are “reactive iron sulfides” which have been successfully used for the reduction and precipitation of inorganic contaminants such as chromium, arsenic, and mercury.

This memorandum focuses on the use of a particular subset of reactive iron sulfides - mackinawite structured iron sulfide and sulfonated iron-aluminum layered double hydroxide (LDH), collectively referred in this paper as “FeS”.

Another standalone reductant the environmental remediation industry has long studied and recognized for its usefulness is ZVI. However, ZVI may have its own set of constraints, limitations, and variabilities in successfully meeting remediation goals when deployed at a particular site. In addition, compared with these forms of FeS, ZVI is less chemically efficient (due to passivation) and persistent in the environment than other FeS.

These constraints, limitations, and variability in success when using ZVI are related to many factors, including but not limited to:

The iron source used to manufacture the ZVI itself
Particle sizing of the ZVI
Low reactivity due to its intrinsic passive layer
Narrow working pH
Reactivity loss with time due to the precipitation of metal hydroxides and metal carbonates
Low selectivity for target contaminants (especially under oxic conditions)
Limited efficacy for treatment of some refractory contaminants
Passivity of ZVI arising from certain contaminants
Geochemical variability between sites and even within sites location (Guan, 2015).

To counteract some of these challenges, during the past decade, ZVI reagent providers have begun to sulfidate (sulfonate) their ZVI, chiefly with the intent is to increase the ZVI’s reactivity, selectivity, and longevity for various reductive processes. Although these sulfidated or sulfonated ZVIs (S-ZVI) have become a more commonly used product for both inorganic and organic contaminant reduction applications, consistently meeting a site’s long-term remediation goals has remained elusive.

2. FERROUS SULFIDE CREATION

Multiple university and industry research papers have proven that FeS can be generated abiotically (chemically) or biotically (biogeochemically) (Wang et al., 2024, Mangayayam et al., 2019). While the formation of a stable, highly reactive FeS is possible in both abiotic and biotic scenarios, there are significant performance differences between chemically synthesized FeS (abiotic FeS) and biogeochemical generated FeS (biotic FeS)

Biogeochemically generating ferrous sulfides in-situ for site remediation has become a more prevalent practice in the past decade and a half, primarily based upon the research and evaluation of sulfate-rich aquifers with sulfate-reducing microbes that produced free sulfide (Rickard 2012 and Picard et al., 2018). The introduction of an iron component for oxidation and reaction with this free sulfide produced in these environments completed the FeS formation process. It is interesting to note that this concept traces its roots back to paleo-geochemical environments where biotic FeS was generated in low-temperature, anoxic surface water and groundwater settings by sulfate reducing microorganisms (SRM) (Wacey et al., 2015). In both settings, sulfate is utilized as an electron acceptor by indigenous or imported facultative microbes that produce (hydrogen) sulfide. This reductive metabolic process is known as biosulfidogenesis (Jameson et al., 2010).

This concept of biologically produced sulfide combined with an iron source has evolved over the years into the practice of mixing S-ZVI with microbes to jumpstart this process or provide the necessary components to facilitate the reaction and precipitation of iron sulfides, most notably for reductive dechlorination applications.

More recently, it has become common for environmental practitioners to optimize this biotic formation of FeS by adding additional nutrients and kinetic additives to condition the aquifer and promote more optimal geochemical conditions that improve the speed, efficiency, and quantity of FeS produced biogeochemically. This combined injectate has been referred to as S-ZVI and enhanced reductive dechlorination (ERD), (SZVI+ERD), S-ZVI and enhanced in situ bioremediation (EISB) (S-ZVI+EISB), or S-ZVI and anaerobic bioremediation (AB), (S-ZVI+AB).

Even with these advancements mentioned, one of the greatest challenges to overcome in these types of biogeochemical systems is the amount of time (and timing) required to create the desired environment for successful remediation.

Many chemical and biological processes must occur concurrently and sequentially over a period of months to generate the quantity and type of FeS required. Some of these processes include the transformation and maintenance of the aquifer into a sulfate-reducing environment depleted of dissolved oxygen to promote biosulfidogenesis. This biosulfidogenesis must be coupled with oxidation of the iron source (e.g., ZVI) to produce several iron oxide species plus ferrous iron, and all these processes must be present and maintained for direct microbial interaction and formation of FeS. Additionally, the availability of sulfate (total or mass flux) also has a direct bearing on the formative size, iron morphology, and mineralogy of the iron sulfide; again, influencing the reactivity and mass of FeS generated.

While earlier laboratory studies (Rickard, 1969) inferred that biotic FeS did not physically differ from abiotic FeS, more recent research suggests that this is not necessarily the case. Over the past five decades, more sophisticated laboratory experiments confirmed the issues with verifying the viability of usable biotic FeS and have found that non-reactive species of FeS may be generated (e.g., pyrite, greigite) and not the quantities of the reactive FeS desired.

Using modern laboratory technologies, the physical and chemical characteristics (i.e. crystal size, morphology, texture, solubility) of the minerals formed in the presence of sulfate-reducing microorganisms (SRM) “have not been thoroughly investigated” and were “likely limited by the technology available at time” (Picard et al., 2018). Further, several factors influencing the ability of SRM to biotically form reactive FeS were highly affected by the geochemical setting- mainly influenced by the geological environment and anoxic conditions. Thus, the generation (derivation) and reactivity/utilization (consequence) of these biotic compounds can be more readily predicted in modern experiments where instrumentation is more appropriate for in-depth analysis, but also the equipment can control environmentally germane factors that play a role(s) in biotic FeS formation.

3. STRUCTURAL DIFFERENCES

Iron sulfide mineralization experiments examining the influences of several biogenic parameters on the formation of biotic FeS after one week of incubation and then monthly for one year revealed significant structural differences. These biotically formed FeS particles were compared to abiotically prepared FeS at the same Fe:S ratios (Picard et al., 2016).

Scanning Electron Microscope (SEM) images of biotic (upper row) and abiotic (lower row) iron sulfide precipitates, washed and air-dried in an anaerobic chamber, after one week of incubation. (from Picard et al., 2018)

The Picard, et al., 2018 team concluded the following:

Despite having similar Fe:S ratios and formed at similar pH, the mineral precipitates formed under biotic and abiotic experiments had visually distinct bulk morphologies.
Biotic precipitates appeared less opaque (i.e. absorbed less light) than abiotic precipitates.
After the minerals settled back to the bottom of the vials, the precipitates formed in biotic Fe experiments formed a sticky aggregate, while abiotic precipitates appeared finer and more homogeneously distributed.
Precipitates in the biotic treatments aggregated more than the abiotic precipitates and thus formed larger particles. Aggregates of biotic particles in solution were much larger (1354 ± 120 nm) than abiotic aggregates (428 ± 148 nm).
The massive aggregation of biogenic iron sulfide minerals is consistent with observations of ‘sticky’ mineral precipitates in the serum vials.
The binding of Fe2+ to microbial compounds before the precipitation of FeS seems to play an important role in determining the final properties and morphology of iron sulfide minerals.
Different mineral morphologies are observed when minerals precipitate in the presence of dead SRM.

Overall, the application and applicability of these “controlled” laboratory experiments to actual remediation applications assumes the ability to efficiently create biotic FeS in an “uncontrolled” environment. This means that:

Since the increased surface area (smaller sized particles) and uniformity within the structure has a direct impact on reactivity in-situ, and
The distribution and reactivity of the biotically formed FeS in-situ is hampered by agglomeration and massing, abiotically formed FeS would be favored.

4. IMMEDIATE REMEDIATION

Deploying an abiotically, manufactured (chemically synthesized) FeS presents several advantages and resolutions to the limitations of the biogeochemically generated version. An FeS synthesized with an excess of sulfide (S-FeS) exhibits a larger interlayer spacing and unit cell volume that contains an interlayer of polysulfides which is structured is a wave pattern that has a greater surface area for contaminant reduction, degradation, and/or removal (Wang, et al., 2024).

Abiotically produced FeS (e.g., S-FeS) is not dependent on biogeochemical processes.
Pyrite and greigite are not formed or introduced to the system, a conversion process which depletes the reductive setting.
Phosphate in the geochemical setting does not retard or inhibit the formation of these types of abiotically produced FeS (or S-FeS) – the phosphate mineral complex (vivanite) is not a chemically available form of FeS.
Extracellular materials, byproducts of microbial respiration, do not aggregate and produce irregular or outsized FeS particles.
Agglomerated FeS particles are not present, which may reduce aquifer porosity.
Multi-metal contaminants, or commingled inorganic and organic contaminants, settings do not shift the production or reactivity of the abiotically produced FeS which may occur during biotic FeS formation.

5. CONCLUSIONS

Biogeochemically generated FeS has gained acceptance in the environmental remediation industry for groundwater remediation of inorganic and organic contaminants. The introduction of bioremediation components with S-ZVI to generate FeS in situ is a demonstrated technology. A chemically manufactured version (S-FeS) has also been utilized with prevalence in recent years in similar deployments. It has proven to be effective immediately and demonstrate subsurface persistence.

The differences in these two FeS materials, outside of performance and timeframe, are also realized in project cost and timeline. The intent of proponents of biotic FeS is to reduce the cost of the injectate on a per pound basis. Yet, because of many in situ factors, it is difficult to estimate the total mass of FeS that will be generated, even if conditions remain constant and optimal, which is difficult to control longer than weeks or months in most cases. The agglomerate structure is also not conducive to high-capacity reduction or degradation. With S-FeS, the weight of available irons and sulfides is straightforward to calculate and evaluate on a stoichiometric and cost basis.

References

Guan X, Sun Y, Qin H, Li J, Lo IM, He D, Dong H. The limitations of applying zero-valent iron technology in contaminants sequestration and the corresponding countermeasures: the development in zero-valent iron technology in the last two decades (1994-2014). Water Res. 2015 May 15; 75:224-48. Epub 2015 Feb 28.

Jameson, E., O.F. Rowe, K.B. Hallberg, and D.B. Johnson. Sulfidogenesis and selective precipitation of metals at low pH mediated by Acidithiobacillus spp. and acidophilic sulfate-reducing bacteria. Hydrometallurgy, Volume 104, Issues 3–4, 2010, Pages 488-493.

Mangayayam, M., J.P.H. Perez, K. Dideriksen, H. Freeman, N. Bovet, L.G. Benning, and D. Tobler. 2019. Structural transformation of sulfidated zero valent iron and its impact on long-term reactivity. Environmental Science. Nano. (00):1-9.

Picard, Aude, Amy Gartman, and Peter R. Girguis. "What do we really know about the role of microorganisms in iron sulfide mineral formation?" Frontiers in Earth Science 4 (2016): 68.

Picard, Aude, Amy Gartman, David R. Clarke, Peter R. Girguis. Sulfate-reducing bacteria influence the nucleation and growth of mackinawite and greigite. Geochimica et Cosmochimica Acta, Volume 220, 2018, Pages 367-384.

Rickard, David. Chapter 8 - Microbial Sulfate Reduction in Sediments, Developments in Sedimentology, Elsevier, Volume 65, 2012, Pages 319-351.

Wacey, David, Matt R. Kilburn, Martin Saunders, John B. Cliff, Charlie Kong, Alexander G. Liu, Jack J. Matthews, and Martin D. Brasier. "Uncovering framboidal pyrite biogenicity using nano-scale CNorg mapping." Geology 43, no. 1 (2015): 27-30.

Wang, Chunli, et al. A novel Iron Sulfide Phase with Remarkable Hydroxylradical Generation Capability for Contaminants Degradation. Water Research 251 (2024): 121166.

Conflict of Interest Statement

Derek Pizarro declares no conflicts of interest. Thomas McCullough and Gary Meyer are the owners of Redox Solutions, LLC, which owns the intellectual property and manufacturing facility for a commercialized mackinawite structured iron product (FerroBlack®).

¹AST Environmental, Inc. Freehold, New Jersey, USA.

²Redox Solutions, LLC. Carmel, Indiana, USA.

The Author:

Derek Pizarro is a Senior Product Manager at AST Environmental, Inc. and a Certified Professional Geologist. He has 22 years of experience in environmental remediation, specifically contaminant transport studies, fractured bedrock characterization and injection, and reagent bench-scale testing and design for environmental sites and industrial process waste streams. Before joining AST, Derek was a Product Director and GM for an environmental chemical manufacturer, with previous experience in environmental consulting and bedrock services. He received a Bachelor of Science in Geology and Environmental Geosciences from Lafayette College.

AST Environmental, Inc. (Freehold, NJ) is an internationally recognized leader in injection and environmental construction services, specifically known for groundwater remediation and in situ injection using proprietary subsurface distribution techniques. As a privately held small business, AST thrives as an integral, specialized part ofproject teams, focusing on supporting consultants, responsible parties, and stakeholders dealing with challenging environmental impacts in overburden, transition zones, and fractured bedrock. www.astenv.com

Coming March 1, 2026: Connecticut's New Requirements to Clean Up Polluted Properties

Mon, 19 Jan 2026 15:54:50 GMT

by Adam Henry, P.G., LEP, GZA GeoEnvironmental

On March 1, 2026, the Connecticut Transfer Act, which has been one of the primary drivers of environmental cleanup of polluted properties for more than 40 years, will sunset. After March 1, 2026, requirements for cleanups will no longer be triggered as a result of the transfer of an “establishment” and responsible parties will no longer be required to conduct site-wide investigations to “prove the negative.” However, responsible parties that already have Transfer Act obligations will still be required to complete them.

Starting March 1, 2026, the new Connecticut Release Based Cleanup Regulations (RBCRs) will require cleanup of pollution when it is discovered, similar to what is currently required in most other states. Discovery can occur when soil or groundwater samples collected March 1st or after identify pollution. Discovery can also occur when “multiple lines of evidence” are observed, including soil staining, odors, or urban fill material or information is available regarding historical testing data (however, a “filing cabinet exemption” exists for environmental reports/data issued prior to March 1, 2026).

When pollution is discovered, the RBCRs require the responsible party to complete cleanup of the polluted area within 120 days or report the pollution to the Connecticut Department of Energy and Environmental Protection (CTDEEP), or sooner if pollution is significant. If compliance with the RBCRs is not achieved within one year, the polluted area must be assigned to a “cleanup tier”, annual fees are required depending on the severity of the condition and deadlines for cleanup are applicable.

The transition from the Transfer Act, which regulates a relatively narrow subset of properties, to the RBCRs, which will apply to pollution discovered at all properties, represents a sea change in how environmental cleanups in Connecticut are completed and will have significant implications for how due diligence is conducted, construction projects are planned, and environmental information is managed.

The Author:

Adam Henry, P.G., LEP

Mr. Henry, an Associate Principal of GZA GeoEnvironmental, Inc., leads the firm’s Buildings and Real Estate Development sector. He has over 20 years of experience managing site assessments, investigations, and remediation projects. He also works closely with lenders, developers, business owners and attorneys to complete their environmental due diligence during real estate acquisitions, divestiture and refinancing. If you have questions about how the new regulations may impact your business or property, please contact him at Adam.Henry@GZA.com or 860-858-3166.

Redevelopment Institute Webinar RECAP: “Carpe Diem: Why Redevelop Brownfields Now?”

Mon, 05 Jan 2026 20:02:55 GMT

by Sarah Sieloff, Haley & Aldrich

On December 12th, EPA-funded technical assistance provider the Redevelopment Institute hosted a webinar about US manufacturing, lack of land, and brownfield redevelopment. The following post provides a summary with links to resources. A recording of the webinar is available here.

After decades of decline, US manufacturing investment is on the upswing, and manufacturing investments worth tens of millions to hundreds of billions of dollars are landing across the nation. Often, that’s happening in smaller and mid-sized communities. The reasons are complex and span federal incentives, shifting geopolitics and lessons learned following the global pandemic. For example, on December 10th, Eli Lilly announced a $6 billion pharmaceutical manufacturing investment in Huntsville, Alabama, and similar commitments are coming to many communities from companies ranging from Toyota and Hyundai to yogurt producer Chobani.

But there’s a hitch: the US lacks the development-ready land necessary to accommodate this investment. According to the 2025 State of Site Selection Report, 49% of site selectors identified the availability of development-ready sites as a limiting factor. For Michael Taylor, brownfields redeveloper, president of Vita Nuova, and webinar speaker, this indicates that now is the time for local governments and private investors to coordinate planning to facilitate future investment, as site selectors—one of whom referred to a “manufacturing renaissance”— describe new levels of demand for project-ready sites.

Each major manufacturing investment needs land, and so does its infrastructure, suppliers with warehouses and logistical requirements, workers, and workforce housing. Mark Williams, author of Corporate Site Selection and Economic Development, estimates that an investment anticipated to create 4,000 manufacturing jobs will generate 11,600 supplier jobs. Anticipating each supplier job requires 1,200 square feet of space, that adds up to 1,065 acres (1.66 square miles) needed to accommodate the original manufacturing facility and the ecosystem that surrounds it.

Critically, those 1,065 acres don’t need to come in the form of a megasite. In the 2025 State of Site Selection Report, site selectors emphasize the need for sites of varying size, from 5 acres to 150 acres, with utilities and clear development timelines.

Whether urban or rural, few places in the US have enough development-ready land today, but brownfield redevelopment could change that. With the final year of historically large EPA Brownfields grants upon us, and applications due January 28 of 2026, now is the time for local governments to think hard about how land reuse can improve their readiness to receive manufacturing investment.

Brownfield redevelopment fueled by EPA grants can provide an answer

EPA is currently accepting applications for $255.7 million in Brownfields grants, which can support environmental assessment, cleanup, planning and community engagement. Most public and nonprofit entities are eligible to apply, and although private sector entities can’t directly receive this funding, they can still benefit from Brownfields grants by partnering with public and nonprofit applicants.

This year is significant because it is the final year in which funding from the 2021 Bipartisan Infrastructure Law (BIL) will make historically large Brownfields grants possible. The BIL effectively tripled available EPA Brownfields funding by investing $1.5 billion over five years (FY22-FY26). However, all BIL funds must be obligated by September 30, 2026, after which Brownfields grants will reduce in number and size.

While we often talk about Brownfields as an environmental program, Brownfields grants are really about redevelopment. They support planning activities that generate reduce uncertainty and generate redevelopment momentum, from market feasibility studies to infrastructure assessments and fiscal and economic impact estimates. Done well, planning under a Brownfields grant can start conversations about public-private partnerships, and help articulate a pathway to redevelopment. Table 1 shows examples of planning activities that can be funded by EPA Brownfields grants. For more information about specific Brownfields-support planning activities, check out these factsheets from EPA.

Table 1. How can you plan under an EPA Brownfields grant?

EPA values planning so highly that it evaluates assessment grantees on whether they allocate at least 30% of their proposed grant budgets to planning activities. Planning facilitates redevelopment because it clarifies local preferences and expectations, and can mitigate project opposition, which can cause costly delays.

EPA Brownfields grant applications are due January 28, 2026, and it’s not too late to start.

The Author:

Sarah Sieloff, Planner, Haley & Aldrich

Sarah Sieloff is a planner with Haley & Aldrich, an integrated, multidisciplinary consulting firm. Based in Bellingham, Washington, Sarah helps public and private sector clients around the US build more sustainable, livable futures by navigating and effectively addressing brownfield redevelopment, climate resilience, environmental justice concerns and state and federal funding.

Transforming South Norwalk: A Model for Brownfield Redevelopment and Community Renewal

Tue, 23 Dec 2025 14:53:46 GMT

Sarah DeStefano, ENV SP

The redevelopment of Ryan Park and Soundview Landing in South Norwalk, Connecticut (“SoNo”) transformed nearly seven acres of environmentally impaired and flood-prone land into a climate-resilient public park and a vibrant mixed-income housing community. Once home to Connecticut’s oldest public housing development and the only recreational public space in SoNo – which was closed in 2016 due to elevated PCB levels - the area has been reimagined as a sustainable neighborhood anchor that now offers safe housing, green space, climate resiliency, and economic opportunity.

Historical maps of SoNo show the area was originally mud flats and marshland near Norwalk Harbor that were filled and developed into a mixed industrial and residential neighborhood in the late 1800s. Its low-lying geography, however, made it vulnerable to flooding and contributed to decades of disinvestment in this historically distressed and disadvantaged neighborhood.

By 1940, a portion of the area was cleared for what would become Washington Village (since renamed Soundview Landing), a city-owned residential complex of 11 buildings. Over time, surrounding areas were converted into storefronts and office space, most of which were demolished by the late 1950s. The neighborhood suffered from reoccurring flooding, including severe damage from Hurricane Irene in 2011 and Superstorm Sandy in 2012, prompting the Norwalk Redevelopment Agency to secure a 2014 HUD Choice Neighborhood Grant to help address these concerns.

The vision for SoNo emerged from an 18-month community planning process supported by the Choice Neighborhood Grant. Residents, businesses, and elected officials collaborated to shape a roadmap for neighborhood improvement, focusing on environmental justice, housing equity, and economic opportunity. The Norwalk Redevelopment Agency subsequently secured a U.S. EPA Community Wide Brownfields Grant to assess contamination and plan a fair and equitable cleanup and revitalization process. In addition, multiple cleanup grants totaling $5.7 million were obtained from the Connecticut Department of Economic Community Development (CTDECD) to address contamination at both the Ryan Park and Washington Village project locations.

Remediation and design strategies included:

Removal of over 30,000 tons of contaminated soil
Construction of engineered soil caps
Petroleum recovery and underground infrastructure upgrades
Elevation of streets and greenspace by 2–6 feet above the 500-year floodplain, exceeding FEMA standards

Ryan Park was restored and elevated to provide dry egress during storm events and now features modern recreation facilities, walking paths, and flood protection, along with new playgrounds and landscaping. Adjacent to the park, the new Soundview Landing development was raised by more than eight feet above the flood zone. The regulatory closure of Ryan Park was documented through state and federal approvals, while Soundview Landing was enrolled in the Connecticut Voluntary Remediation Program, with environmental land use restrictions and Site Verification Reports confirming compliance with the state’s Remediation Standard Regulations

All 136 affordable housing units were preserved and 137 additional moderate-income and market-rate units were added, promoting income diversity and expanding access to better health, education, and employment outcomes. The redevelopment was one of the first in Connecticut to blend 9% and 4% Low Income Housing Tax Credits, creating a replicable financing model for future projects.

Additionally, the project was driven by robust partnerships across local, state, and federal agencies, catalyzing over $1 billion in additional neighborhood investment. It increased the local tax base, created hundreds of construction and permanent follow-on jobs, and earned sustainability certifications including LEED-ND Silver.

This multi-year, multi-partner initiative stands as one of Connecticut’s most impactful brownfield-to-community asset transformations. The revitalized Ryan Park and Soundview Landing now draw residents and visitors to the growing SoNo neighborhood, demonstrating how environmental stewardship and inclusive design can help communities thrive.

In recognition of its innovation, impact, and community-centered approach, the Ryan Park and Soundview Landing redevelopment was honored at the 2025 National Brownfields Conference in Chicago with a Phoenix Award, one of the nation’s highest accolades for excellence in brownfield redevelopment. In addition, the project won the Brownfield Coalition of the Northeast’s (BCONE’s) Brownfield Sustainable Communities Redevelopment Project Award of Excellence.

It took many years and required the resources and partnerships of many individuals to provide a roadmap to move SoNo forward. The Ryan Park and Soundview Landing redevelopment exemplifies the best of brownfield revitalization:

public/private partnerships,
creative funding stacks,
innovative engineering and design,
environmental stewardship, and
meaningful community impact.

By integrating regulatory requirements with climate resilience strategies and community aspirations, the Ryan Park and Soundview Landing redevelopment has become a model for transformative brownfield revitalization across the Northeast.

The Author:

Sarah DeStefano, ENV SP, Weston & Sampson

Sarah is the Environmental Practice Leader at Weston & Sampson. She can be reached at destefanos@wseinc.com.

Battery Energy Storage System (BESS) Facility Development—Fast Track to Success in Siting, Permitting, and Construction

Tue, 11 Nov 2025 18:21:20 GMT

By Gene Bove, INCE, GZA

Battery Energy Storage Systems (BESS) are being deployed at megawatt- to gigawatt-hour scales to help balance supply and demand, maximize renewable energy utilization, and provide grid stability.

To ensure stable energy delivery to residents, many states have instituted policies and incentives to encourage BESS development. Once a power purchase agreement is in place, most BESS developers start with two considerations when identifying potential sites: 1. Is there a need for the facility, either to provide backup power or to store energy from renewable resources? and 2. How smoothly can the BESS be connected to the local utility grid?

Once potential sites have been screened for these considerations, developers can select the best possible site by performing some additional evaluations to minimize the risk of encountering costly surprises during design and construction.

When selecting a site for development, conducting a Phase I Environmental Site Assessment (ESA) is a critical step in environmental due diligence. If you are purchasing the property, the ESA provides vital protection against future Superfund or state toxic waste liability claims. Conversely, if you are leasing the site, the ESA establishes an essential environmental baseline, so you are not held responsible for pre-existing contamination. Regardless of ownership, the Phase I ESA can uncover unresolved environmental issues that could impact project development, a concern amplified for multi-state entities dealing with varied and complex environmental regulations and associated liabilities. “In addition, environmental due diligence can be an important step in project financing,” advises GZA’s Steve Kline. “A Phase I ESA can identify the environmental challenges and benefits of developing potential BESS facilities on either ‘Brownfield’ or ‘Greenfield’ properties.”
For BESS site selection, understanding and mitigating noise impact is essential for community acceptance and regulatory compliance. BESS units generate moderate noise; typically a low hum from cooling systems (high-speed fans and cooling systems), power conversion systems (inverters), and electric transformers. This sound, while generally quieter than diesel generators, can add sufficient noise that may violate local noise ordinances, particularly near residential areas. To prevent this, it is crucial to obtain accurate data on existing background noise levels and perform acoustic modeling of the proposed BESS before design, permitting, and installation. “Furthermore, developers must be aware of how local fire codes may limit noise reduction options. For example, fire codes may prohibit noise baffling enclosures, which reinforces the importance of addressing noise compliance requirements and maintain your standing as a ‘good neighbor,’” says GZA’s Ethan Wagner.
Evaluating subsurface conditions for geotechnical design of foundations is vital when selecting a BESS site, given that these units can weigh many thousands of pounds, requiring robust foundation support. As GZA’s Dharmil Patel explains, "getting a clear picture of what’s underground helps you design appropriate foundations to support the BESS, including whether you need to improve the soil, remove rock, or carry loads through soft soils down to firm soils to keep the BESS safe and stable." Understanding these subsurface conditions is paramount for engineering an appropriate and economical foundation. Furthermore, the proximity of abutters must also be factored in, as nearby property lines can significantly complicate foundation and site-preparation requirements.
“Environmental Permitting requirements can determine the feasibility of constructing a BESS site,” says GZA’s Julia Braunmueller. “We will typically review available municipal regulations, zoning, and environmental resource data to identify potential issues, such as wetland restrictions, FEMA 100-year flood plains, rare and endangered species habitat, etc., that may result in time delays or significant additional expense. Our approach is to summarize the key attributes of existing conditions, and identify potential issues, listing relevant local, state, and federal environmental and siting permits that are identified during the review for the BESS developer’s consideration. Based on this review, we will often develop a “permit matrix” of requirements that may be necessary for the development of a BESS facility. The permit matrix will list the responsible agencies, expected permit timeframes, and additional information that may be useful in determining the viability of a site.”

U.S. battery energy storage capacity jumped 66 percent in 2024, according to the U.S. Department of Energy, with projections indicating even faster growth in the coming years. The value proposition is compelling for all stakeholders, from individual building owners to utilities, offering a more resilient power grid and substantial cost savings through arbitrage—storing energy during low-price hours and deploying it to cover peak demands during high-price hours. However, it is a technology where the fast track “no surprises” approach to site selection safeguards against major operational and financial risks. Careful and early evaluation of BESS sites’ environmental, geotechnical, noise, and permitting requirements can make all the difference in fast tracking to project success.

The Author:

Gene Bove, INCE, Sr. Project Mgr., GZA

Gene Bove, INCE, is a Senior Project Manager at GZA and a leader in the firm’s acoustic and noise analysis practice. He has been involved in siting and development of BESS sites around the country, including more than 100 in New York State.

Brownfields 2025 State of the Union - Navigating a New Regulatory Landscape

Mon, 13 Oct 2025 17:09:03 GMT

By Chris Gdak and Derek Street, Montrose Environmental

The state of brownfields and environmental justice (EJ) in the U.S. has undergone significant changes as of 2025. Following a new administration, the EPA has shifted its focus, impacting communities, developers, and local governments across the Northeast. Here’s an overview of the evolving landscape and what it means for brownfield redevelopment.

Key Historical Context

Established in the mid-1990s, the EPA’s Brownfields Program has been instrumental in revitalizing contaminated sites through funding initiatives like MARC grants. Concurrently, the EJ Program has sought to empower marginalized communities facing pollution. Significant investments were made in recent years, with the Bipartisan Infrastructure Law allocating $1.5 billion for brownfields and the Inflation Reduction Act establishing numerous EJ initiatives.

Recent Policy Changes

As of January 2025, the new administration paused IRA and Bipartisan Infrastructure Law funding, resulting in crucial restructuring within the EPA:

Major reductions in grants and staff dedicated to EJ.
Dissolution of the Office of Environmental Justice.
Significant cuts to the EPA budget.
However, the funding for brownfields has remained intact, creating opportunities for communities ready to act swiftly.

Support for the Brownfields Reauthorization Act in February 2025 has provided some optimism with increased grant caps and allocations focusing on rural and small communities.

Implications for Funding and Future Projects

The 2025 grant cycle still offers potential for significant funding, emphasizing no-match cleanup grants and increased limits on assessments and cleanups. However, projects targeting Environmental Justice may need to align with broader economic narratives to secure funding.

Looking forward, unless future legislation reverses the current trends, the projected post-Bipartisan Infrastructure Law funding for brownfields is expected to revert to significantly lower levels, estimated between $65 million and $85 million annually. Under these new conditions, grant caps are likely to be around $1 million, and there may be a 10% matching requirement for applicants. The likely focus of future funding will be on economic development, rural areas, and regions facing persistent poverty. Stakeholders will need to align their projects with these priorities to enhance their chances of securing funding in this evolving landscape.

Final Thoughts

For stakeholders in the Northeast, including communities, governments, and nonprofits, the present moment is crucial. Those with EJ priorities should leverage existing funding opportunities wherever possible, even as they prepare for a more challenging future.

The Authors:

Derek Street - Principal Geologist, Brownfields & Community Revitalization Practice, Montrose Environmental

Derek Street is an environmental professional with deep experience in site assessments, brownfield redevelopment, and regulatory compliance. He has worked both in the private sector and at the USEPA, where he reviewed and enforced AAI standards for federal brownfield funding.

Chris Gdak - Practice Leader for Brownfields & Community Revitalization, Montrose Environmental

Chris brings 22 years of environmental consulting and brownfield redevelopment experience to his role as Montrose’s Brownfields & Community Revitalization Practice Leader. Chris focuses on assisting municipal, tribal and community-based organizations with building successful programs to achieve their goals. He has assisted clients in over 20 states and has enjoyed learning about each community’s needs and opportunities, developing relationships with local stakeholders, and contributing to the restoration and revitalization of distressed areas.

Investing in Quality: Why Reliable PFAS Data Matters for Brownfield Assessment and Cleanup

Thu, 02 Oct 2025 17:53:11 GMT

by Linda Cook, Jill Ready, PG, Steve LaRosa with Weston & Sampson

“An ounce of prevention is worth a pound of cure.” This well-known statement by Benjamin Franklin, originally penned in the Pennsylvania Gazette in the 1730s to highlight the importance of fire prevention, holds great significance for data quality control in environmental site investigations today. As the science surrounding per- and polyfluoroalkyl substances (PFAS) has grown and evolved, so too has the importance of adequate PFAS data quality control. While the environmental and health risks of PFAS are widely discussed, cost-benefit analyses for poor versus high-quality PFAS data have received limited attention. For brownfield sites in particular, where site assessment and cleanup activities are often being completed with limited United States Environmental Protection Agency (EPA) Brownfields grant funding, data quality can deeply impact grantees’ abilities to achieve their goals for sites undergoing assessment and cleanup. This article will evaluate the total cost of quality in PFAS analyses, emphasizing the strategies necessary to generate the best data for your projects and clients.

The Cost of (Poor) Quality

In his 1956 Harvard Business Review essay “Total Quality Control,” Armand Feigenbaum introduced “The Cost of Quality” concept for industrial manufacturing businesses. The concept introduced four categories of quality-related costs: prevention, appraisal, internal failure, and external failure (Figure 1). Today, the Cost of Quality concept is applicable to PFAS testing, where poor data can lead to costly missteps and far-reaching consequences (Table 1). The costs of poor-quality PFAS data are also often unpredictable, making them impossible to anticipate, schedule, or budget.

Figure 1. Illustration of the four quality cost categories as introduced by Armand Feigenbaum in "The Cost of Quality."

Table 1: The costs of poor-quality PFAS data can be significant and far reaching and are often unpredictable.

If data are determined to be of such poor quality that they are unsuitable for their intended use, additional sampling and analysis may be required to address data gaps. In the most serious of cases, field investigations may need to be completely re-performed, resulting in a loss of previously invested resources, reducing the availability of Cooperative Agreement funds for use on other priority sites, and impacting public trust.

Inaccurate data can also lead to costly and more unnecessary and aggressive approaches for treating and managing PFAS-impacted resources. For instance, if a laboratory produces results that are consistently biased high, it may prompt remedial actions that are more extensive and expensive than required.

Financial penalties for exceeding regulatory thresholds are another potential cost consequence of inaccurate PFAS data. Inaccurate PFAS results can lead to non-compliance with regulatory PFAS standards, which may result in fines and/or enforcement actions.

Beyond financial implications, poor quality data can also impact project timelines, have social and emotional consequences, and damage brand reputations. For brownfield sites undergoing assessment and cleanup with funding provided by EPA Brownfields grants, delayed project timelines can result in projects not being completed before the end of the grant performance period, necessitating the use of funds for grant extension requests that may or may not be approved.

Why PFAS Testing Is So Challenging

PFAS testing involves specialty analytical methods that are particularly difficult to perform accurately for several reasons, including their ubiquitous presence, regulatory requirements, method complexity, and a growing selection of ancillary methods. In particular, the common presence of PFAS in lab equipment, field supplies, and consumer products increases the potential for cross-contamination during both sample collection and analysis. Testing methods demand ultra-low detection limits (often in the parts-per-trillion range), advanced instrumentation, and rigorous controls. Not all labs are up to the task, yet many have rushed to meet surging demand without the experience or infrastructure to deliver reliable results.

Complicating matters further, standard methods only detect a fraction of the estimated 10,000+ PFAS compounds. Newer techniques like Total Oxidizable Precursors Assay (TOPA), Adsorbable Organic Fluorine (AOF), and Extractable Organofluorine (EOF) attempt to estimate total PFAS content, but vary in accuracy, comparability, and validation. Without standardized reporting protocols, reviewing data from different labs becomes both time consuming and error prone.

Building a Foundation of Quality

Investing in high quality data saves money, reduces risk, and improves outcomes. A robust PFAS sampling and testing program aimed at generating high-quality data involves two core strategies: prevention and assessment.

Prevention Strategies:

Define Objectives Early: Align project teams, regulators, and labs on compounds of concern, detection limits, and intended data use.
Use Qualified Labs: Vet your proposed laboratories carefully for PFAS-specific experience. Avoid selecting based on lowest price alone.
Develop a detailed Site-Specific Quality Assurance Project Plan (QAPP): The QAPP should address PFAS-specific requirements and outline Data Quality Objectives.
Train Sampling Teams: Use PFAS-free materials and emphasize the importance of documentation and adherence to protocols.
Implement a Quality Management System: Oversee and maintain data quality throughout any sampling and analysis program, evaluating for areas of improvement and ensuring data integrity.
Include Quality Control Samples: Standard reference materials and blind quality control samples help track laboratory performance and catch anomalies early.

Assessment Strategies:

Field Oversight: Document and review field practices to ensure adherence to protocols.
Laboratory Oversight: Review laboratory protocols and practices to monitor performance.
Data Review: Perform independent data validation and usability assessments throughout the project to evaluate data reliability. Incorporate reviews of comprehensive data packages including all supporting documentation and raw data (known as a Level 4 data report). This review will ensure that data used for project decisions are accurate, complete, and defensible.

For Brownfield Sites, Data Quality Is Non-Negotiable

Brownfield sites often have complex histories and liability considerations. Introducing unreliable PFAS data to brownfield site assessment and cleanup projects can lead to financial, legal, and environmental consequences for environmental professionals, grantees, municipalities, and the public. However, investing in high-quality data can simplify decision-making, reduce risks, and improve project outcomes.

While rigorous testing and oversight may increase upfront costs, those expenses are far less than the cost of poor-quality data. As the demand for PFAS testing grows and regulatory standards evolve, robust approaches to data quality will be increasingly necessary.

For brownfield sites with limited time and funding for assessment and cleanup, high-quality PFAS data are invaluable, enabling informed decisions, improving stakeholder confidence, and helping maximize the use of grant funds. Investing in prevention and rigorous quality assessment from day one is the surest way to protect people, budgets, and reputations.

(A longer version of this article was originally published in the June 2025 issue of the Journal of the New England Water Works Association, Inc.)

The Authors:

Linda Cook is a Senior Technical Leader with Weston & Sampson in their Reading, MA office. She can be reached at cook.linda@wseinc.com.

Jill Ready, PG, is a Project Manager with Weston & Sampson in their Manchester, NH office. She can be reached at ready.jill@wseinc.com.

Steve LaRosa is a Senior Technical Leader with Weston & Sampson in their Waterbury, VT office. He can be reached at larosas@wseinc.com.

Addressing Vapor Intrusion: The Role of Sub-Slab Depressurization Systems

Thu, 02 Oct 2025 17:45:31 GMT

by James P. Cinelli, P.E., P.G., BCEE, Liberty Environmental

Vapor intrusion is a growing concern in environmental health, specifically in highly developed urban areas where soil gases or contaminated groundwater can migrate into buildings. Vapor intrusion occurs when volatile organic compounds (VOCs) and other harmful contaminants seep through cracks or other openings in a building’s foundation and it can potentially pose significant health risks to occupants. To combat this issue, Sub-Slab Depressurization Systems (SSDS) have emerged as an effective solution.

Understanding Vapor Intrusion

Vapor intrusion occurs when hazardous vapors from contaminated groundwater or soil migrate into indoor spaces. This typically takes place through small cracks and other openings in the foundation of a building. There are significant health risks posed to occupants of a building who experience long-term exposure to these contaminants ranging from respiratory issues to more severe conditions, including cancer.

What are Sub-Slab Depressurization Systems?

Sub-Slab Depressurization Systems are an engineered solution designed to reduce indoor vapor concentrations. These systems create a vacuum beneath a building’s foundation, drawing vapors away from the sub-slab area and preventing their entry into the indoor environment. The primary components of an SSDS (Sub-Slab Depressurization System) include:

1. Suction Points: These are pits or perforated pipes installed beneath a building’s slab foundation that collect vapors.

2. A Fan: Air circulation from a fan or blower creates negative pressure (depressurization) beneath a slab foundation.

3. Vent Stack: This directs collected vapors beneath a foundation safely outside and away from windows and air intakes to ensure they do not re-enter a building.

Implementation Process

The implementation of an SSDS begins with a thorough site assessment to identify the source and concentration of contaminants. Engineers can then design a tailored SSDS system to address specific building and site conditions. Once designed, installation typically brings minimal disruption, as it can often be completed without significant alterations to an existing structure.

After installation, an SSDS system does require regular monitoring and maintenance to ensure its effectiveness. This includes inspecting suction points for blockages, checking the fan for operation, and conducting air quality tests to verify that vapor concentrations remain at safe levels.

Liberty Environmental’s talented team of remediation experts has proven experience addressing vapor intrusion and assisting in the process of integrating sub-slab depressurization systems. Contact us at info@libertyenviro.com to schedule a site assessment or speak with a member of our team to learn more.

The Author:

James P. Cinelli is an environmental engineer and the president of Liberty Environmental, Inc., an environmental consulting firm which he co-founded in 2004. The company has 35 employees with offices in Philadelphia, Lancaster, PA, Reading, PA, New York City, and Lebanon, NJ. The company’s clients include local, regional and international companies, and include banks, real estate developers, oil & gas companies, and large manufacturing firms.

Brownfield Redevelopment: The Playbook

Thu, 02 Oct 2025 17:36:33 GMT

by Vincent Carbone, Senior Geologist, HDR, Inc.

Over the years, the redevelopment of brownfields has matured. In fact, in some cases the process of acquiring funding, characterizing sites, remediating and finally redeveloping them has become somewhat routine. For those fortunate enough to have received funding from federal or state agencies and through economic incentives, redevelopment has been a success. In most cases, these communities had the ability and organization to assist them in the planning, development, and rehabilitation of properties. With the assistance of economic development corporations and supportive communities willing to develop their most pressing redevelopment needs, the properties were easy to prioritize and redevelop.

Now more than ever the need is fixed on those communities that do not have the means or the expertise to manage a portfolio of smaller properties impacting a community. Perhaps the issue is a highway corridor providing entrance into a key demographic or community. Perhaps it is an old commercial strip mall that fronts an old industrial complex. For certain it’s not the 1,500 acres of Bethlehem Steel or any one of that prime brownfield’s redevelopment successes, but rather a project with a diverse demographic with little or no vision as how to go about redevelopment from an economic, environmental, or power perspective.

The Need for a Playbook

It’s time to move to another level of maturity, to make brownfield redevelopment accessible to this less equipped type of community. But they need help. They need vision. They need a Brownfields Redevelopment Playbook, which provides a holistic summary of the three key factors that make for successful property community redevelopment: Economics, Power/ Infrastructure, and Environmental Stewardship. This is the first step to helping communities with limited resources prioritize their diverse and unique blend of many properties into a workable vision and plan.

Economics

Economics is the lifeblood of community redevelopment, but what types of business are appropriate for the community? Will the community demographics be better suited for one industry or another? What are the current and future economic trends for the locality or region? What investments should be made to support those trends? The playbook should provide a framework of the economic drivers for the community and provide both short-term, mid and long-term goals for revitalization to meet those needs. What industry “fits” with the community that will bring benefits and job creation to the locality and region.

Power and Infrastructure

With redevelopment comes the need for infrastructure upgrades and efficiency to support new industry or just an aging utility network. With the development of data centers and battery energy storage facilities, the need for power, water and infrastructure (water, sewer, natural gas, fiberoptics/broadband and power) is immense and poses several questions. Can the power and utility infrastructure of the community support the proposed redevelopment? What types of power generation are available for that area? Is the water supply or wastewater treatment sufficient to address the proposed redevelopment? Can renewable energy supplement in design the more traditional forms of generation? Short term, mid and long-term needs reflect the economic incentives. The Playbook can identify infrastructure needs to support proposed economic development and attract business, provide renewable energy resources to the region, and can be integrated with redevelopment on brownfields that have limited options to redevelopment.

Environmental

Environmental stewardship is the protection of human health and the environment. But it also encompasses the risk and enhancement of natural features such as wetlands or other sensitive habitats. It also includes a community’s culture and providing enough green and recreational space for the community to enjoy the redevelopment and to enhance the life of occupants of the area. Together with the economics section, the playbook can identify federal and state brownfields or economic development funds that can be pursued to make the vision a reality. The playbook should also feature timelines for redevelopment, which can help set realistic goals and demonstrate phased approaches to redevelopment and community engagement.

Comprehensive and Considerate

Looking at each of the elements individually – economics, power/infrastructure, and environmental—and holistically, playbooks can provide a Highest and Best Use (HABU) or what is considered the best fit for the community. The Playbook can be used to support grant funding, community outreach, help plan for infrastructure upgrades and goes a long way toward demonstrating a comprehensive and considerate evaluation of improvement in brownfield redevelopment.

The Author:

Vincent “Vinny” Carbone is a Professional Associate and Senior Geologist with HDR Engineering. Vinny has been performing brownfields redevelopment services for over 33 years. During his career he has brought his redevelopment experience to multiple market sectors including transportation, water, architecture, and power redevelopment. Working in HDR’s Bethlehem PA office, he has been redeveloping Bethlehem Steel, and the Lehigh Valley for over 25 years. He currently is working on several playbooks supporting redevelopment of former coal power plants and former nuclear facilities including several industrial properties across the country. He is experienced in property redevelopment with USEPA Brownfields grants and is and has been a Qualified Environmental Professional for several Cleanup Grants and Revolving Loan Funds.

Vapor Intrusion Evaluation for Residential Redevelopment

Tue, 02 Sep 2025 17:22:57 GMT

by Liberty Environmental

Redeveloping former industrial sites for residential use requires careful evaluation of vapor intrusion risks. There is a risk that volatile organic compounds (VOCs) were released into the subsurface at sites where dry cleaners were located, gas stations were operating, or where other industrial activity previously occurred. These prior uses pose significant potential health risks to future residents. Additionally, properties adjacent to sites that were once gas stations or utilized for industrial purposes may be impacted by migration of vapors from these sources, necessitating a thorough investigation before redevelopment.

What is Vapor Intrusion & How Can it Be Detected?

Vapor intrusion occurs when VOCs migrate from contaminated soil or groundwater into indoor air spaces. This pathway can expose residents to harmful chemicals, making it critical for redevelopers to perform due diligence. A comprehensive environmental site assessment should be conducted prior to any redevelopment to identify potential sources of contamination, including investigation into historical land use and neighboring properties with known releases. When a vapor intrusion risk is identified, sampling and analysis of soil gas and indoor air is performed to confirm the presence or absence of a vapor intrusion condition.

How Is Vapor Intrusion Mitigated?

If vapor intrusion is suspected, a detailed evaluation plan should be implemented. This includes soil gas sampling and indoor air testing to assess the extent of vapor migration. Based on the findings, appropriate mitigation strategies must be incorporated into the redevelopment design. These may include vapor barriers, sub-slab depressurization systems, and enhanced ventilation to prevent VOCs from entering living spaces.

State regulatory agencies provide guidance and oversight for vapor intrusion assessments and mitigation. Engaging environmental professionals and coordinating with state agencies ensures compliance and protects public health.

Why is Addressing Vapor Intrusion Important?

Addressing vapor intrusion is a vital component of residential redevelopment on or near former industrial sites. Proactive evaluation and mitigation not only safeguard future occupants but also facilitate successful and sustainable redevelopment projects.

Liberty Environmental’s talented team of professional engineers, geologists and licensed remediation professionals have proven experience testing for VOCs and implementing remediation for redevelopment projects. Contact us at info@libertyenviro.com to schedule a site assessment or speak with a member of our team to learn more.

Technologically Enhanced Contamination: A Secondary Effect of Remediation Technology

Mon, 04 Aug 2025 15:46:36 GMT

by Joel Kane, Sr Associate, Fleming Lee Shue

Advancements in in-situ remediation technologies have enabled practitioners to aggressively target even the most persistent environmental contaminants. However, it is critical for environmental professionals to recognize that these technologies may unintentionally alter subsurface geochemistry and mobilize or concentrate non-target compounds. This phenomenon—referred to as Technologically Enhanced Contamination—can present unforeseen challenges during long-term monitoring, site closure, and waste management.

TENORM

One of the clearest examples of this phenomenon involves the concentration of Naturally Occurring Radioactive Materials (NORM)—such as isotopes of uranium, thorium, and radium—which are present in trace amounts in soil and groundwater. When groundwater is extracted and treated in large volumes, trace levels of NORM can accumulate in scale deposits, filter media, and sludge within treatment systems. Over time, these accumulations may exceed background levels and surpass regulatory thresholds, transitioning into Technologically Enhanced Naturally Occurring Radioactive Material (TENORM)¹.

This process is well-documented in oil and gas operations, where radium-rich scale forms during initial crude separation. Similarly, coal—a common carrier of radioactive isotopes—can produce TENORM when combusted, with radionuclides concentrating in the resulting coal ash. When such ash is later used as fill material, as historically was the case in much of New York City, a remedial system (such as a pump-and-treat well or recovery trench) can unintentionally accumulate TENORM within filters and piping.²

Although certainly not a concern at every site, properties with specific risk factors — such as historic coal ash fill or long-term groundwater extraction systems — may benefit from evaluation of potential TENORM accumulation within treatment infrastructure. Monitoring of scale, filters, and sediments, and proper waste characterization prior to disposal, may be important steps for mitigating radiological health and safety risks.

ERH and Secondary Contaminant Mobilization

The combined use of Electric Resistance Heating (ERH) and Soil Vapor Extraction (SVE) can significantly enhance the removal of volatile and semi-volatile organic compounds. ERH increases subsurface temperatures, volatilizing contaminants and improving mass transfer to the vapor phase, where they are captured by SVE systems.

However, superheating the subsurface can also inadvertently increase the mobility of otherwise immobile contaminants—such as Polychlorinated Biphenyls (PCBs). Though PCBs have low volatility under ambient conditions, elevated temperatures enhance their partitioning to the vapor phase.³ When combined with the strong advective forces of an SVE system, low-level PCB concentrations can migrate toward extraction points, and potentially concentrate in knock-out drums, vapor treatment vessels, and even within localized areas of the subsurface if not fully extracted by the SVE.

Several studies and post-operation evaluations have identified unexpectedly high PCB concentrations in vapor-phase effluent and condensate, requiring specialized waste handling and disposal.⁴ While ERH remains a powerful tool, practitioners must anticipate the possibility of mobilizing compounds not originally targeted in the remedial design.

ISCO and Metal Mobilization

In Situ Chemical Oxidation (ISCO) is another widely used remedial technology, wherein strong oxidants—such as sodium persulfate, permanganate—are injected into the subsurface to destroy organic contaminants.

However, these oxidants can often significantly alter the geochemical balance of the aquifer. They may lower pH, increase redox potential, and raise ionic strength—conditions that favor the dissolution of naturally occurring metals previously bound to soil minerals. Following ISCO treatment, it is not uncommon to observe elevated concentrations of iron, manganese, arsenic, and lead within the groundwater monitoring programs.⁵

Though these metals are not typically the focus of remediation, their mobilization can complicate site closure or regulatory compliance, particularly if they were previously below detection limits. For sites considering ISCO, baseline groundwater chemistry should be evaluated in advance, and post-treatment monitoring should include metals to assess for geochemically driven mobilization.

ERH-Induced Geochemical Shifts and Metals

In addition to contaminant volatilization, ERH can cause broader geochemical shifts within the local affected aquifer. When highly chlorinated solvents—such as PCE or TCE—are thermally degraded, the reaction often generates free chloride ions, which can acidify the groundwater and increase its ionic strength.⁶

This shift enhances the solubility of subsurface metals, which may then appear in monitoring data as elevated concentrations of iron, manganese, arsenic, or lead. While often transient, these metals spikes can delay regulatory closure or complicate long-term monitoring, especially when concentrations exceed site-specific cleanup criteria.

As with ISCO, pre-treatment geochemical profiling and careful interpretation of post-treatment data are critical for managing unintended consequences.

Implications for Remedial Design and Site Management Monitoring

Modern remedial technologies offer powerful tools to achieve cleanup goals, but it is important to be aware that they may also trigger secondary effects that are not immediately apparent during remedy design. Subsurface heating, oxidation, and even pump & treat can all change the behavior of metals, radionuclides, and semi-volatile organics in ways that can influence both short and long-term outcomes.

To help best anticipate and manage Technologically Enhanced Contamination, environmental professionals may opt to:

Conduct thorough baseline investigations of groundwater chemistry and geologic conditions
Develop a robust conceptual site model that considers geochemical responses
Monitor non-target compounds throughout and after system operation
Coordinate with regulators early to plan for temporary and/or unexpected byproducts or secondary contaminant mobilization/spikes.

Understanding these site-specific interactions is critical for managing costs, ensuring regulatory compliance, and achieving sustainable site closure.

U.S. EPA (2022). TENORM in Oil and Gas Production. https://www.epa.gov/radiation/tenorm-oil-and-gas-production-wastes
NYC Department of Environmental Protection. Historical Fill and Ash Use in NYC.
Johnson, G. et al. (2009). PCB Behavior in Subsurface Thermal Remediation. Environmental Science & Technology.
Heron, G., Van Zutphen, M., & Carroll, S. (2009). “Design and performance of an in situ thermal remediation at a former manufacturing facility.” Remediation Journal, 19(3), 5–21. Rogers, R.D., et al. (1999). “Application of electric resistance heating to PCB-contaminated soils.” Journal of Hazardous Materials, 68(3), 235–256.
Interstate Technology & Regulatory Council (2005). In Situ Chemical Oxidation Guidance Document.
Lee, T.Y., et al. (2015). Impact of Thermal Remediation on Groundwater Geochemistry. Environmental Science: Processes & Impacts.

The Author:

Joel Kane is a Senior Associate at Fleming Lee Shue, where he oversees the firm’s technical operations and manages a diverse portfolio of remediation projects across the greater New York Metropolitan Area. He specializes in complex remediation sites and his experience spans both the public and private sectors. Joel works closely with developers, agencies, real estate firms, and legal teams to navigate environmental regulations across local, state, and federal programs—including NEPA, CERCLA, the Brownfield Cleanup Program, E-Designations, petroleum spills, and CEQR/SEQR.

Land-Use Considerations Evaluating PFAS in Brownfield Sites

Mon, 04 Aug 2025 15:39:51 GMT

By Michelle Onofrio, National PFAS Technical Manager, ALS USA Environmental

Per- and polyfluoroalkyl substances (PFAS) are hazardous compounds that have been used heavily in manufacturing since the 1950s. While their usefulness is derived from their chemical structure, the strong carbon-fluorine (C-F) bonds present in these compounds render them resistant to degradation. PFAS are well-known to be persistent and ubiquitous in the environment and have been found in environmental samples around the globe, but the distribution and concentrations of these contaminants vary across the USA.

The wide array of brownfield redevelopment sites presents a multitude of potential contamination sources. When considering the potential for high levels of PFAS contamination, it is important to consider the history of land use at a particular site and the site’s proximity to certain areas. In this article, we discuss how to consider historical land use to anticipate whether PFAS are likely to be contaminants of concern.

Manufacturing and chemical sites

Obvious sources of PFAS contamination include manufacturing facilities that developed PFAS or used PFAS heavily in manufacturing processes. Industrial use of PFAS is highly concentrated in the Northeastern USA, especially along the I-95 corridor.

Regions with historical manufacturing of chemicals, paints and coatings, urethane and foam, textiles and carpeting, paper and food packaging, plastics and resins, metal plating, and other industrial processes are likely to contain high levels of PFAS in the surrounding environment.

Manufacturing processes that typically do not involve PFAS are less likely to have PFAS contamination as a major concern. These include bricks and ceramics manufacturing, lumber milling and woodworking, blacksmithing and metal forging, and glassmaking.

The age of a manufacturing facility can also be an indicator of whether PFAS contamination is present; areas that were only used for manufacturing before the 1950s are unlikely to pose a risk for PFAS contamination.

Airports and firefighting training areas

Aqueous film-forming foam (AFFF) is used to combat specific fires, including aviation fires. AFFF typically contains very high concentrations of PFAS, so airports and firefighting training locations may be source locations for significant PFAS contamination. Until recently, AFFF was typically not treated as hazardous waste after use.

Instead, it was generally washed away with water, introducing high concentrations of PFAS to soil, groundwater or surface water in the surrounding environment. AFFF storage tanks and systems may still contain PFAS, even if the systems are no longer in use.

Municipal and industrial waste landfills

Before health risks associated with PFAS were known, PFAS were used in many common household items including nonstick cookware, food packaging materials, personal care products, cleaning products, electronics, and clothing and carpeting manufactured to be water-resistant, stain-resistant and/or fire-resistant.

Once discarded, these items introduce PFAS into municipal landfills. Landfills that have accepted industrial waste from PFAS-heavy manufacturing facilities are also likely to contain increased concentrations of PFAS.

Wastewater treatment plants and land-applied sewage sludge and biosolids

Sewage sludge refers to untreated residual material produced by wastewater treatment plants, while biosolids indicate a sludge that has received some level of treatment. Sewage sludge and biosolids have been used for land applications since the early 1900s. The standards for wastewater treatment established by the Clean Water Act in 1972 resulted in an increase in the generation of biosolids, and subsequently land application throughout the country.

Sewage sludge treatment does not specifically target PFAS, so even treated biosolids can contain these contaminants. Wastewater treatment plant discharge and land-applied biosolids, especially if produced near highly contaminated areas, are likely sources of PFAS contamination in the environment.

Analytical considerations for highly contaminated sites

Samples originating from the areas described may contain PFAS at concentrations of orders of magnitude higher than other typical samples. When considering a laboratory partner for analysis of these types of samples, it is beneficial to ensure the laboratory employs mitigation strategies to overcome the challenges of processing high-concentration PFAS samples.

Communication throughout the course of your site testing and analysis project is crucial; it is encouraged to discuss site history with your project manager, and you should expect timely updates regarding any challenges that may arise.

High-quality data and rapid turnaround times are achievable with these types of projects, especially when using a laboratory experienced in analyzing highly contaminated samples for PFAS.

The Author:

Michelle Onofrio is the National PFAS Technical Manager for ALS USA Environmental. Michelle provides technical support on workflow optimization and new method development, prioritizing quality and consistent, reliable service. Michelle works closely with the company's PFAS laboratories throughout the country in New York, New Jersey, Pennsylvania, Michigan, Texas, and Washington.

Passive Air Sampling for VOCs: What Brownfield Professionals Need to Know

Fri, 27 Jun 2025 14:34:02 GMT

By Bill Allgeier, Laboratory Manager, ALS USA Environmental

When it comes to monitoring Volatile Organic Compounds (VOCs) at brownfield sites, especially those in remote or power-limited locations, passive air sampling offers an accessible, reliable option. Unlike active sampling—which requires power sources and calibrated pumps—passive techniques rely on diffusion to collect samples over time.

These low-maintenance approaches are growing in popularity across site remediation, health and safety, and fenceline monitoring projects. This article covers the different passive VOC sampling tools available, their strengths, and how to choose the right one for your site.

Cost Effective, Field-Friendly

Passive air sampling collects airborne contaminants without pumps or powered devices. Instead, compounds are captured as they naturally diffuse through the air and into the sampling media. It’s a cost-effective and field-friendly method, ideal for long-duration monitoring or projects where access is limited. Common applications include indoor air testing, ambient outdoor air, personal exposure monitoring, and soil vapor investigations.

Passive VOC Sampling Tools

There are four key passive sampling options for VOCs. Each tool fits different field conditions, project goals, and regulatory contexts.

Silonite Canisters are ideal for “whole air” sampling. The canisters are filled over 24 hours using a flow regulator – they require no pump and allow for analysis of 60+ VOCs. Additional methods like reduced sulfur compounds and fixed gases can be analyzed from the same canister, removing the need to deploy multiple sampling techniques. They're highly versatile and suitable for indoor, outdoor, and soil vapor applications.
Passive TD Tubes are used for long-term sampling (up to 14 days, depending on the compound), especially for low-level VOC monitoring. They're small, rugged, and comply with EPA Method 325. Great for fenceline, LDAR, and indoor use. However, typically they have a limited number of analytes that can be reported.
VOC Badges are the go-to option for personal exposure monitoring. Workers wear the badge for up to 8 hours to assess individual VOC exposure levels. These are compliant with occupational health standards.
Radiello Samplers are flexible samplers with a 7-day deployment window, ideal for industrial or mining sites. They measure up to 31 VOCs and can also support non-VOC testing (e.g., formaldehyde, NO2).

Need to ship your samples fast? Canisters and TD tubes don’t require refrigeration and ship easily with commercial couriers.

Choosing the Right Tool for the Job

Selecting the best method depends on your project objectives, site conditions, and regulatory requirements. Consider:

•Sampling duration – Canisters (any duration up to 7 days), TD tubes (up to 14 days, depending on the compound), badges (8 hours), and Radiello (7 days).
Target VOCs – Do you need a wide panel (e.g., over 60 compounds)? Go with canisters. Need a focused list? Badges or TD tubes may suffice.
Sampling environment – For personal exposure, use VOC badges. For soil vapor, ambient air or industrial zones, canisters or TD tubes work better.
Accreditation needs – For example, ALS provides NELAP & AIHA accreditation for methods using canisters and TD tubes, ensuring data meets defensibility standards.

Why Passive Sampling Works Well for Brownfield Sites

Passive sampling is often the best fit for brownfield redevelopment projects because it’s simple, scalable, and doesn’t require power or bulky equipment. It can support key project stages, including baseline air quality assessments, post-remediation verification, and long-term monitoring. And since these methods are non-intrusive, they’re ideal in community-sensitive areas.

Whether you’re assessing indoor air, monitoring an industrial fenceline, or verifying cleanup at a brownfield site, passive VOC sampling is a proven and practical approach that ensures your sampling campaign is efficient, accurate, and compliant.

The Author:

Bill Allgeier is Laboratory Manager of the ALS USA Environmental full-service laboratory in Rochester, NY. Bill has been with the ALS environmental team for 26 years as an Analyst, Operations Manager and Lab Manager, and oversees a 24,000 sq ft. facility where the team processes over 290,000 air, soil, water, drinking water and waste sample tests annually.

Email: bill.allgeier@alsgobal.com

A Pennsylvanian Case Study in Preservation, Remediation, and Community-Driven Land Reuse

Tue, 24 Jun 2025 14:59:46 GMT

by Christopher D. Valligny, LSRP, Montrose Environmental

Embreeville Park in West Bradford Township, Pennsylvania, is a testament to what’s possible when environmental remediation, historical stewardship, and community planning converge. Once home to a psychiatric hospital complex dating back to the 19th century—and later, a brownfield marked by contamination and deteriorating infrastructure—the 200-acre property has been reimagined into preserved open space through a collaborative effort grounded in sustainable redevelopment.

In 2019, facing a proposal for more than 1,100 residential units, residents rallied to chart a new course for the site. With community backing, the Township acquired the property for $22.5 million, halting the proposed high-density development and committing to the site's long-term ecological and historical value.

Tackling Environmental Liability with Strategic Funding and Compliance

Redeveloping a property of this scale—and complexity—demanded not just public support but also a robust financial and technical roadmap. Montrose’s brownfield experts helped secure a $1.5 million grant through the Land and Water Conservation Fund and assembled a layered funding portfolio with state and local partners. That financing enabled critical assessment, remediation, and early redevelopment work.

Milestones included:

Phase I & II ESAs to characterize environmental conditions and target contamination.
Act 2 Program compliance, resulting in a Release of Liability and setting the legal foundation for future recreational reuse.
Hazardous and universal waste removal, paired with geotechnical efforts that allowed on-site demolition debris to be safely reused for land stabilization.

Historic Preservation and Community Cohesion

The park’s transformation wasn’t limited to environmental cleanup. Guided by archaeologists, the project protected Native American cultural resources—preserving local heritage while restoring the land’s public utility. As of 2024, 185 acres have been designated for passive recreation and conservation. Planned improvements include walking trails, ball fields, and interpretive signage to showcase both natural and cultural history.

Lessons for the Northeast Brownfield Community

Embreeville Park offers replicable insights for BCONE members and other Northeast stakeholders:

Community-Driven Outcomes: The pivot away from dense redevelopment exemplifies how public input can shift brownfield narratives toward long-term, non-commercial value.
Creative Reuse: On-site material recovery for stabilization cut costs and reduced waste—an essential approach for municipalities with limited redevelopment budgets.
Integrated Partnerships: Success hinged on tight collaboration between municipal leaders, environmental consultants, legal experts, and funding agencies.

The Author:

Christopher D. Valligny, LSRP, Senior Scientist II, Montrose Environmental

Chris is a Senior Scientist with over 15 years of experience in environmental consulting, ecological research, and policy implementation. Licensed as a NJDEP Licensed Site Remediation Professional and UST Closure/Subsurface Evaluator, he also holds OSHA 40-Hour HAZWOPER certification. Chris manages complex brownfield investigation and remediation projects—including Phase I/II Environmental Site Assessments—throughout New Jersey, Pennsylvania, and Delaware. His interdisciplinary approach supports a diverse client base of insurers, municipalities, developers, nonprofits, and legal teams.

Beyond CERCLA: What to Look for in Data Center Brownfield Site Assessments

Mon, 23 Jun 2025 15:14:01 GMT

by Abraham Cullom, PhD, Pace® Director of Water Safety & Management

Brownfield redevelopment is often an attractive option for data center site selection. Data centers benefit from existing infrastructure, shortening construction time, and allowing the data center to reach full operability faster. Modern data centers can also transform under-utilized or abandoned industrial and commercial sites and boost local economies by creating jobs and stimulating demand for local services.

However attractive they may be, brownfield development projects always carry risks. Before investing, developers often perform an Environmental Site Assessment (ESA) to identify and mitigate these potential risks, ensuring the site is safe for future use and protecting data center owners from unforeseen liabilities.

Contaminants listed as “Hazardous Substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) are a frequent target of investigation as CERCLA gives the EPA the authority to hold property owners liable for cleanup costs even if they were not responsible for the original contamination. However, CERCLA Hazardous Substances are not the only contaminants that can impact building safety and future liabilities. In this article, we highlight three areas that may not be automatically included in a data center site assessment but perhaps should be.

Asbestos

“Friable” asbestos, meaning asbestos in a form or in materials that can easily be crumbled by hand, is a CERCLA hazardous substance. Therefore, environmental site assessments should include this substance, particularly if the building was constructed prior to the 1980s.

Nevertheless, stockpiles of asbestos-containing building materials were used for many years after the U.S. EPA prohibited most forms of asbestos in construction. Furthermore, even if the site has a history of asbestos abatement projects, decades-old records may not be entirely reliable. Some areas of the country have naturally occurring asbestos that could also present a problem, especially during construction or soil excavation.

Although Phase I ESAs do not typically include testing, to protect the investment, the site assessment team may want to consider working with a laboratory to analyze the presence of asbestos in accumulated dust during this phase. A simple “scrape and scoop” sample of settled dust can be analyzed using Polarized Light Microscopy (PLM) or Transmission Electron Microscopy (TEM). However, keep in mind that this method is not designed for precise quantification of asbestos fibers and is not suitable for regulatory compliance or legal purposes. More advanced sampling and analytical techniques can be used to validate and further quantify asbestos fibers in settled dust in late-phase ESAs.

Waterborne Pathogens and Microbially Influenced Corrosion (MIC)

Brownfield sites that have existing, operational HVAC systems can offer redevelopment advantages. However, if the building has been unoccupied for any length of time, checking water systems for signs of microbial activity may be warranted. Microbes thrive in the warm, stagnant water that pools inside unused pipes, equipment, HVAC systems, and more. For the data center operator, this can create a couple of major issues.

The first challenge is the potential for dangerous pathogens, such as Legionella, to colonize the biofilm that often forms inside older or unused water systems. When the water is turned on, the increased pressure can dislodge these bacteria and release them into the water system. The primary way Legionellosis, the disease caused by the bacterium Legionella, is contracted is through breathing aerosolized droplets containing the bacteria. This exact scenario can be created through cooling systems used by data centers. In fact, CDC research found cooling towers to be the second largest source of Legionellosis outbreaks. (An outbreak is defined as two or more people getting sick.)

The second challenge is microbially influenced corrosion, or MIC. MIC is also associated with the presence of biofilms. As colonies form and grow inside water systems, they can affect the electrochemical environment of a material's surface and accelerate corrosion. MIC is a significant concern in industrial settings, and the damage caused by MIC can amount to billions of dollars annually in increased maintenance and replacement costs as well as damage to systems and property.

In addition, MIC has been shown to reduce cooling system thermal efficiency. As corrosion worsens, the uneven surface inside the pipes and equipment creates even more pockets for biofilms to form. The resulting biofilm can foul heat exchangers, impeding heat transfer and reducing the efficiency of the cooling system.

There are several types of tests available to detect and identify dangerous pathogens in water systems. Due to the dangers presented by Legionella in particular, regular testing of cooling systems for the presence of Legionella is recommended. In addition, a Biological Activity Reaction Test (BART) can be used to detect and monitor specific types of microbial activity in water systems. For instance, BART can be tailored to look for broad groups of bacteria, such as those involved in sulfur cycling (sulfate-reducing bacteria, sulfide-oxidizing bacteria), iron-related bacteria (iron-oxidizing and iron-reducing bacteria), slime-forming bacteria, and heterotrophic bacteria.

Lead-Lined and Galvanized Steel Pipes

Despite ongoing efforts to replace lead and galvanized steel pipes, the U.S. EPA estimates more than 9 million lead-based water service lines are still in use across the country. Lead-lined water service lines are more susceptible to corrosion from factors such as dissolved oxygen, low pH, and low mineral content in water. Not only can this corrosion release lead into the water systems, but it also creates pockets for biofilms to form, further accelerating the corrosion and the release of even more lead into the water system. Clearly, this is an issue if the lead service lines feed the building’s potable water systems. In addition, as discussed in the preceding section, the resultant biofilms can also negatively impact thermal efficiency.

Galvanized steel service lines were also commonly installed in the U.S. during the first half of the 20th century. These pipes have a zinc coating designed to prevent rusting. While galvanized pipes themselves do not contain lead, lead particles can accumulate within the corrosive buildup in these pipes if they are or have ever been connected to downstream lead pipes. When water flows through galvanized pipes, it can release the built-up lead particles, leading to water contamination.

Under the U.S. EPA’s Lead and Copper Rule, efforts are being made to identify and replace lead and galvanized steel service lines. However, a significant portion of service lines have yet to be characterized thanks to incomplete record keeping when these lines were installed. Testing for lead in the water system can help determine if lead or galvanized steel service lines are in use and may need to be replaced.

Exploring the Risks for Greater Rewards

Brownfield sites hold immense potential for data center development, offering existing infrastructure, cost-efficiency, and opportunities for economic revitalization. However, these opportunities come with an inherent need for thorough due diligence. While CERCLA hazardous substances are a primary concern, developers should broaden their scope during ESAs to consider additional risks that may not be immediately apparent.

Potential issues such as residual asbestos, waterborne pathogens, and legacy piping materials like lead-lined or galvanized steel can pose significant operational, financial, and health challenges if overlooked. Assessments that leverage advanced sampling techniques and testing methods can significantly reduce liabilities and ensure the long-term safety and efficiency of the facility.

The Author:

Abraham Cullom, Ph.D., Director of Water Safety and Management, Pace® Building Sciences

Dr. Cullom is the Director of Water Safety and Management at Pace®. He holds a B.S. from the University of Pittsburgh and a Ph.D. from Virginia Tech in Civil and Environmental Engineering, where he published multiple peer-reviewed papers demonstrating the impact of in-building plumbing environments on important opportunistic pathogens, antibiotic resistance, and microbial ecology. A cross-disciplinary expert, Dr. Cullom translates insights from engineering, microbiology, and chemistry into practical solutions to mitigate disease risks in water systems and help end Legionnaire’s disease.

Artificial Intelligence and Machine Learning as Tools for Groundwater Modeling

Wed, 11 Jun 2025 15:46:20 GMT

By Matthew J. Gozdor, Quantitative Hydrogeologist/Senior Technical Specialist at GZA GeoEnvironmental, Inc.

With artificial intelligence (AI), scientists and engineers are faced with a familiar question: The tools are impressive on their own, but how do we use them to provide effective, reproducible results? Our recent work for a client to develop a groundwater model that was as accurate as traditional modeling but with fewer data points and lower cost helps illustrate the way forward.

For this project, we focused on machine learning (ML), which is a subset of AI. ML uses algorithms and statistical models to analyze data for patterns, draw inferences from those patterns, and learn from the patterns without being issued explicit instructions. In this instance, we needed to demonstrate to regulators that impacted groundwater was discharging to a nearby stream and not flowing underneath the stream.

Traditional modeling to meet our objective required obtaining a significant amount of information through complex field work and gathering historical information, LIDAR data, geological data, etc. The information needs for our ML model were significantly less and limited to weather information from a nearby weather station, river elevation data, and groundwater levels. Our AI-assisted model used Python, a common programming language popular in the ML community, and an open source “package” named Pastas developed for groundwater scientists and engineers to analyze hydrogeological time series. Pastas uses a transfer function noise model to show how the groundwater system will respond to a stressor (e.g., precipitation) while also incorporating random noise on the output to better reflect the complexity of a hydrogeological system.

To test the model, we used it to predict future groundwater elevations which were compared to actual measured values over time. Using the Normalized Root Mean Square Error (NRMSE), which compares the predicted values against the observed values while normalizing them by the standard deviation of the observed data, we found that our ML model’s values came within 2% of real-world observations.

Our approach has the potential to be used in a wide range of groundwater scenarios, from estimating snowmelt effects to controlling groundwater in tunneling operations. Core to going forward, however, will be ensuring that the model reflects the real-world data, and that the data reflects the risks: In other words, trust, but verify.

Scientists and clients are understandably concerned about how to use these tools and where they fit into our work. By developing ML models that can be checked against real-world results, and carefully choosing what data a model is built on, clients and contractors alike can make better-informed decisions, while saving time and money.

The Author:

Matthew J. Gozdor is a Quantitative Hydrogeologist and a Senior Technical Specialist at GZA GeoEnvironmental, Inc. With 25 years of experience, his focus is on groundwater flow modeling, fate & transport modeling, aquifer testing design and evaluation, and hydrologic evaluations.

www.gza.com, matthew.gozdor@gza.com

Ten Pro Tips to Cut Environmental Remediation O&M Costs

Wed, 07 May 2025 18:23:01 GMT

by Tony Finding,CHMM, Brownfield Science & Technology, Inc. (BSTI)

When your in-situ environmental remediation system goes live, it might feel like the hard part is over. The installation is complete, the contractors have cleared out, and regulators are off your back. But a quiet site doesn't mean it's time to take your eye off the ball—especially when it comes to operations and maintenance (O&M) costs.

Based on over three decades of designing, building, and operating remediation systems, here are ten professional strategies to ensure your O&M dollars are working hard—every year of your project.

1. Know Your Endgame Before You Start

Don't just focus on cleaning up contamination—consider whether you need to clean it up at all. Regulatory endpoints based on risk assessments can allow for scaled-back remediation if human or environmental risks are minimal. Even with an active system, a fresh look at your endpoints might reveal you're closer to closure than you think.

2. Design with O&M in Mind

System designers often over-engineer for peak contamination. But as mass removal rates decline, you're left operating an oversized system at full cost. Request cost projections for both early and steady-state phases, and push for lifecycle budgeting that highlights long-term expenses. Design choices—like centralized monitoring points—can significantly reduce site time and improve data quality.

3. Use the Right Tool for the Right Job

Remediation often starts with aggressive “hammer” solutions. But as contaminant levels drop, those systems can become excessive and inefficient. Adaptive site management lets you switch to more targeted “Q-tip” solutions later on, potentially saving thousands without compromising outcomes.

4. Choose Skilled Operators, Not Just Warm Bodies

An experienced system operator does more than read meters—they monitor trends, anticipate problems, and fine-tune performance. If your system experiences frequent downtime or surprise repair costs, you might have a “meter reader” instead of a true O&M professional.

5. Beware of the “Lowest Cost” Trap

Competitive bidding can drive down hourly rates, but if each new contractor delivers diminishing returns, the long-term cost may be higher. Operators who lack incentive to close out a site might prolong a project indefinitely. Invest in quality service, not just low rates.

6. Follow the Money: Understand Your Spending

Dissect your budget. Are your dollars going to energy-hungry systems with minimal output? Are you collecting redundant data? Is fouling causing frequent failures? Understanding cost drivers helps you prioritize solutions and streamline your program.

7. Match Technology to the Phase

Early on, robust renewable technologies (like thermal oxidizers or soil vapor extraction) are efficient. But as contaminant levels drop, consumables like activated carbon might be cheaper. The key is knowing when to switch. A good operator can help optimize timing based on treatment cost per mass removed.

8. Embrace Telemetry and Remote Monitoring

Simple telemetry systems offer huge savings. They alert you to faults in real time and reduce the need for routine site visits. They also allow techs to show up prepared, cutting down on costly return trips. Smart monitoring prevents unnoticed downtime—days, even weeks—that delay progress and inflate costs.

9. Don’t Get Distracted by “Bells and Whistles”

Not every automation is worth the price tag. While some features are essential (like remote valve control for high-risk sites), others add cost without value—and sometimes even create new maintenance burdens. Evaluate your system needs critically to avoid over-engineering.

10. Schedule Annual Optimization Reviews

No system performs exactly as designed. Conditions change—water tables shift, surface cover alters, infrastructure evolves. An annual review with your operator ensures you adapt to these changes. It’s a powerful opportunity to reassess system performance and capture savings year over year.

The Author:

Tony Finding, CHMM, serves as Vice President and Director of Remediation Technologies at Brownfield Science & Technology, Inc. (BSTI). With over 25 years of experience in environmental consulting, Tony is a Certified Hazardous Materials Manager and a leading expert in environmental remediation system design, implementation, and optimization. He has directed the successful completion of more than 300 remedial projects across the Mid-Atlantic region, bringing deep expertise in technologies such as in-situ chemical oxidation, bioremediation, and advanced groundwater treatment. Tony is also a recognized leader in the assessment and remediation of PFAS and other emerging contaminants, and has contributed to national technical guidance through the Interstate Technology and Regulatory Council (ITRC).

Contact:

Tony Finding, V.P., Director of Remediation Technologies

Email: tfinding@bstiweb.com

Phone: (610) 593-5500

Website: www.bstiweb.com

PFAS Analytical Toolbox for Brownfield Redevelopment

Thu, 24 Apr 2025 12:30:16 GMT

by Lindsay Boone, M. Sc., Pace Analytical Services

The reclamation and redevelopment of brownfield sites represent a critical opportunity to breathe new life into underutilized spaces. However, a thorough site assessment is essential to understanding a site’s past usage and the potential it presents for future liabilities. Furthermore, the designation of PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) has made PFAS a critical component of any site redevelopment assessment.

In this article, we discuss the primary test methods used to analyze PFAS in environmental matrices with the goal of arming readers with the insights they need to chart a clear path forward.

Test Methods for Brownfields Analysis

For the purposes of brownfield redevelopment, an environmental analysis can cover a variety of matrices, such as groundwater, surface water, stormwater runoff, soil and more. In 2024, the U.S. EPA finalized EPA 1633, providing the industry with a standardized, validated method for analyzing targeted PFAS compounds in non-potable aqueous and solid matrices.

We are seeing the EPA as well as state agencies utilize 1633 in programs in National Pollutant Discharge Elimination System (NPDES) permitting. The Department of Defense (DOD) has also relied heavily on EPA 1633 for PFAS remediation projects when analyzing non potable matrices. Yet, while EPA 1633 may be used for brownfield site assessments, these projects do not always involve direct EPA or DOD oversight. This allows project managers in some cases to leverage other test methods for analyzing PFAS in environmental matrices.

An alternative method, ASTM D8421, was developed by the American Society for Testing and Materials to provide the industry with a quick, easy, and robust method for PFAS in non-potable aqueous matrices. This method was validated using reagent water and tested with difficult matrices including landfill leachate, metal finisher wastewater, Publicly Owned Treatment Work (POTW) influent and effluent, and other non-potable water.

The ASTM D8421-22 documentation describes the method this way: This test method covers the determination of per- and polyfluoroalkyl substances (PFASs) in aqueous matrices using liquid chromatography (LC) and detection with tandem mass spectrometry (MS/MS). These analytes are co-solvated by a 1+1 ratio of sample and methanol then qualitatively and quantitatively determined by this test method. Quantitation is by selected reaction monitoring (SRM) or sometimes referred to as multiple reaction monitoring (MRM).

ASTM D8421 provides several advantages over EPA 1633:

Turnaround time (TAT) is typically faster than more procedurally complex methods like EPA 1633.
ASTM D8421 is typically a less expensive test to perform than EPA 1633.
ASTM D8421 is a low-volume test, requiring only three containers of 5 ml each. This makes sample collection and shipping easier and less expensive.
ASTM D8421 has been validated for 44 PFAS. This includes the 40 PFAS quantifiable by EPA 1633 plus PFPrA, a short chain PFAS, and TFSI, a compound of interest in DOD projects.
Technically similar to EPA 8327, either method can be cited.
ASTM D8535 is technically similar to ASTM D8421. Pace® has validated this method for analyzing PFAS in soil and other solids.

ASTM D8421 is a “performance-based” method, meaning it can be adapted or optimized for specific projects or analytical goals. Pace® added isotope dilution which is also used for quantification in EPA 1633.

Is ASTM D8421 a Screening Method?

The short answer to this question is no. However, “screening method” is a user-defined term without a universal understanding or definition. At its essence, ASTM D8421 is a definitive method. There is some confusion regarding the capabilities and ability of ASTM D8421 to meet specific Data Quality Objectives (DQO). To clarify, it is essential to understand the difference between a “screening method” and a “definitive method.”

Definitive test methods deliver data suitable for final decision-making (of the appropriate level of sensitivity, precision, and accuracy) and legally defensible. These methods are typically developed in accordance with rigorous scientific standards to ensure they provide consistent, reproducible results that accurately reflect the presence and concentration of PFAS compounds. Definitive test methods require a precision and bias statement.

Screening methods produce data that can support an intermediate or preliminary decision but should eventually be supported by definitive data. For example, EPA 1621 is defined by the EPA as a screening method as it only “estimates” the concentration of AOF (adsorbable organic fluorine) in a sample. ASTM D8421 can certainly be used by various stakeholders to meet screening-level DQOs; but at its essence, ASTM D8421 is a definitive method.

Interesting Developments Are on the Horizon

Interestingly, the landscape for PFAS test methods can change even faster than the regulations, and there are some interesting developments in the works. As expected, the EPA has proposed adding EPA 1633 to 40 under Methods Update Rule 22, further cementing the use of these methods in EPA regulatory actions.

Just as importantly, MUR 22 also proposes incorporating ASTM D8421 by reference. “By reference” simply means that the Congressional Federal Record (CFR) will link out to documents authored by the standards body that developed the method instead of including all details in the CFR. This relieves at least some of the documentation burden for the agency. Once ASTM D8421 has been incorporated as a “Part 136” test method, the EPA can incorporate it into other Clean Water Act (CWA) regulatory programs if it so chooses.

The Author:

Lindsay Boone, M.Sc. is a PFAS Technical Specialist at Pace® Analytical Services and frequent speaker on PFAS-related issues including treatability and remediation studies.

New Ground Water Quality Standards: What do they mean for your site in New Jersey?

Thu, 06 Mar 2025 19:05:39 GMT

These standards may apply to sites undergoing remediation as well as sites that have been closed

By Kristen English and Mindy Sayres, PG, LSRP, GZA GeoEnvironmental, Inc.

If you’re wondering what the New Jersey Department of Environmental Protection’s (NJDEP’s) updated Ground Water Quality Standards (GWQS) mean for you as an environmental consultant, site owner, or prospective site owner, here are some key points to consider.

Background

NJDEP amendments to the GWQS changed the criteria for 73 compounds, including 50 that were made more stringent. Of those, the GWQS of seven compounds have been decreased by an Order of Magnitude (OOM) or more. Effective February 3, 2025, these standards apply to Class II-A groundwater, which is essentially all groundwater in New Jersey. It has been estimated that thousands of sites, both active and closed, will be impacted.

What are the Order of Magnitude compounds?

The seven compounds for which standards have been decreased by an OOM or more—at least 10x more stringent—are: 1,1-Biphenyl; Cobalt; Free Cyanide; 1,3-Dichlorobenzene; Heptachlor Epoxide; Methoxychor; and Vinyl Chloride.

How do these new standards change what is required at my site where remediation is underway?

If a remedial action workplan (RAW) or remedial action report (RAR) is submitted by August 3, 2025, the former GWQS remain in effect, except for those seven compounds with OOM changes. It is imperative that an evaluation be completed for those seven compounds to determine if groundwater concentrations remain in compliance and protective of human health and the environment. If they do not meet the new standards, additional investigation and/or remediation may be required.
At sites where the RAW/RAR have not been submitted by August 3, 2025, the new GWQS will apply.

An RAO was issued for my site – will the case be reopened?

There has been much discussion in the environmental community in the short time since the GWQS were published as well as in the comments/responses of the newly published GWQS about potential “reopener” triggers for cases that have been closed, i.e., have a Response Action Outcome (RAO) or No Further Action (NFA). Indeed, the science of each site varies, and environmental consultants will work closely to advise their clients appropriately as these scenarios are further explained by the NJDEP.

Thus far, in response to multiple comments included in the February 3, 2025 New Jersey Register publication of the new GWQS regarding the potential for cases with a final remediation document to be reopened, the NJDEP response has included the following information:

For sites with a Restricted-Use RAO or Limited Restricted-Use RAO with an approved Groundwater Remedial Action Permit, an OOM evaluation for the seven compounds noted above must be conducted and included with the next Biennial Certification submittal. Depending on the results of that evaluation, additional actions may be required.
If a site has been closed with an unrestricted RAO or an unrestricted NFA, the OOM evaluation would be required if/when the site “re-enters” the NJDEP’s Contaminated Site Remediation and Redevelopment (formerly named the Site Remediation Program), which could be prompted by a property transaction or other triggers.

What are the most common constituents for which standards have been made more stringent?

In addition to Vinyl Chloride (one of the seven compounds for which the standard has decreased by an OOM), three of the 50 compounds for which standards have become more stringent and which are very commonly found on contaminated sites in New Jersey include: Benzene; Tetrachloroethene; and Trichloroethene. These compounds are often present in groundwater at sites in New Jersey impacted by historical uses such as dry cleaners, gas stations/auto repair shops, and industrial and manufacturing facilities that used solvents in their operations, to name a few.

What if the site I am considering purchasing is contaminated?

Environmental due diligence, including a Preliminary Assessment (PA) and, if necessary, a Site Investigation (SI), remains critical for buyers in New Jersey to make informed property transaction decisions. This investigatory process demonstrates that the buyer has conducted “all appropriate inquiry” and entitles the buyer to “innocent purchaser defense” under the Spill Act; this can protect the buyer from responsibility for additional evaluation requirements or costs associated with the new GWQS. Compliance with the new GWQS is the responsibility of the Person Responsible for Conducting Remediation (PRCR), as determined by New Jersey’s Spill Act and/or Brownfield Act.

The Authors:

	Kristen English is a Senior Project Manager at GZA with more than 25 years of experience in the environmental field. Her expertise lies in soil and groundwater remediation at hundreds of sites throughout the Northeast including brownfields and UST closures. Kristen.English@GZA.com
	Mindy Sayres, PG, LSRP is a Senior Vice President of GZA and the District Office Manager of the firm’s Fairfield, NJ office. She has more than 30 years of environmental consulting experience, leading project teams tackling complex geologic, hydrologic and contaminant investigations. Mindy.Sayres@GZA.com

Revitalization Strategies for America’s Abandoned Properties

Mon, 03 Feb 2025 22:37:42 GMT

By Ryan Givens, AICP, Montrose Environmental

The U.S. Government Accountability Office (GAO) reports over 1.5 million abandoned properties across the U.S. – creating voids and a sense of abandonment in our cities and local communities. These sites, including industrial buildings, office parks, and waterfronts, have potential to be reimagined as new community-serving destinations through resolute revitalization planning strategies. A clear vision is crucial for revitalization, involving community members, leaders, and experts to identify opportunities and set a trajectory for change

Key Approaches:

Adaptive reuse involves converting and modernizing existing structures.

Convert old buildings into residential units or commercial spaces.
Challenges include upgrades and compliance with safety standards.

Urban infill entails building new opportunities on vacant urban lots.

Develop new projects on vacant urban lots, integrating with the surrounding area.
Challenges include limited space, parking, and potential environmental issues.

Redevelopment means replacing outdated sites with transformative developments.

Replace outdated structures with new developments.
Examples include transforming vacant shopping centers and industrial plants.

Public realm enhancements include upgrading streets, parks, and public spaces.

Add landscaping along public streets, repair sidewalks and create recreational amenities.
Challenges include funding for enhancements.

Strategy Tips for Successful Revitalization:

Adapt Regulatory Tools: Amend zoning and building codes to accommodate and entice investment.
Identify Infrastructure Upgrades: Assess and upgrade infrastructure to support redevelopment projects and support new tenants.
Resolve Environmental Barriers: Identify and address contamination and hazardous substances to ready sites for redevelopment and reuse.
Secure Funding: Identify funding sources for revitalization projects.
Rebrand and Market: Rebrand areas to attract new investors, residents, and visitors.

By incorporating these strategies, communities can transform abandoned properties and distressed neighborhoods into thriving, sustainable environments.

Tools and Resources

EPA Brownfields Program: FY 2025 Brownfields Job Training Listening Sessions
Case Studies on Urban Revitalization: World Bank Report on Urban Revitalization
Current Vacancy Rates in the U.S.: Census.gov - Housing Vacancies and Homeownership

The Author:

Ryan Givens, AICP, is a dedicated City Planner and Urban Designer with 24 years of experience in community design, master planning, and revitalization strategies. Passionate about urban places, Ryan specializes in land use planning, urban infill, and redevelopment, focusing on transforming neglected properties into vibrant community assets. His expertise in environmental assessments, infrastructure planning, and funding strategies ensures successful project implementation, making him an invaluable partner in revitalizing neighborhoods and commercial districts.

Waste Not, Watt Now: How Niagara’s Landfill Became a Solar Landmark

Thu, 05 Dec 2024 17:13:37 GMT

by Alex Bazeley, AC Power

A closed landfill in Niagara, New York is now powering a brighter future. The Pine Avenue Landfill is bringing clean, affordable energy to over 2,300 homes since two newly constructed solar projects on the site came online in early November. The 13.5 MW-dc development will also generate over half a million dollars in revenue for the town and its school district, bolstering their municipal budget.

While its neighbor, the iconic Niagara Falls, has always symbolized natural power, the solar array on the Pine Avenue Landfill shows how dormant land can be revitalized to advance renewable energy for a community long affected by industrial activity. The success is the result of a collaboration involving AC Power, Calibrant Energy, Montante Solar, and the Town of Niagara, combining their expertise to transform previously contaminated land into a renewable energy resource that benefits the community.

This case study explores the site's history, the development process, the web of permitting and engineering challenges — along with the solutions used to overcome them — and the wide-ranging benefits brought to the Town of Niagara through this project. The milestone not only marks a new chapter for the region, but also stands as a replicable path forward for other municipalities looking to give land a new life and bring the energy transition to its residents.

The Opportunity of Brownfields

Across the United States, there are tens of thousands of brownfield sites — former industrial or commercial properties that may be contaminated and have limited potential for redevelopment. For many years, these sites were seen as liabilities, burdened by their histories and costly remediation. But with growing demand for renewable energy and an increased focus on sustainability, more landowners are recognizing the potential of these properties as prime locations for solar and other renewable energy projects.

Brownfields, including capped landfills, offer a unique opportunity to generate clean energy while revitalizing previously unused land. By converting brownfields into renewable energy assets, municipalities can achieve multiple goals: reducing environmental hazards, generating local economic benefits, and contributing to statewide and national renewable energy targets. Projects like the Pine Avenue Landfill solar installation demonstrate that brownfields are not just a problem to be managed — they are a resource to be harnessed.

A New Chapter for the Pine Avenue Landfill

The Pine Avenue Landfill’s legacy of disposal stretches back more than a century, when in the late 1800s Union Carbide began using the site for the dumping of industrial manufacturing waste. It transitioned into a solid waste management facility in the 1970s, coinciding with Republic Services-Allied Waste’s takeover of the property as owner. The site is part of a 385-acre complex which includes an active solid waste landfill directly to the north of one of the solar projects, seven closed solid waste landfills, and six closed hazardous waste landfills.

In 2022, AC Power began discussions with Republic Services to transform closed portions of the landfill. Leveraging their expertise in repurposing contaminated sites, they identified an opportunity to turn this challenging piece of land into a productive asset — generating renewable energy for the community and delivering economic benefits. But the journey from concept to construction required a deep understanding of environmental compliance, creative engineering, and strategic partnerships.

Initiating the Process

With portions of the landfill capped and others still active, the site presented unique permitting and environmental challenges, including securing access for the installation and operation of the solar facilities, ongoing landfill gas collection and monitoring at the project sites, and interconnection design and siting of electrical equipment on and off the landfill cap. The various levels of environmental regulation throughout the larger landfill complex underscored the creativity required for this project and the urgency with which a forward-thinking solution was needed.

AC Power initiated a Phase I Environmental Site Assessment and critical issues analysis/permitting matrix to verify that the closed and capped sections of the landfill could support the development of the solar projects, while remaining compliant with environmental regulations. Accordingly, the developers proposed two 5-MW-ac solar energy generating facilities on two separate sections of capped and closed landfills.

Navigating Permits and Incentives

Once a lease agreement was secured, attention turned to permitting for the development, which necessitated creative thinking and relentless pursuit of the project. Working with outside land use counsel, the developers coordinated with the Town to obtain a use variance that allowed the project to be sited on the existing landfill sections, in addition to bringing the project through the State Environmental Quality Review and site plan review processes.

The NYSDEC post-closure use modification application required comprehensive stormwater analysis, geotechnical assessments, and operational planning to demonstrate the viability of solar development at the site. Tetra Tech, as an engineering partner on the project, conducted the vital work to meet these requirements, while the developers worked closely with the Town of Niagara to secure zoning approvals and a use variance for siting the solar projects.

The developers leveraged both local and federal clean energy incentives to make the project economics pencil. The project was awarded a community solar incentive through NYSERDA’s NY Sun program, while the IRA’s provisions, which include a base Investment Tax Credit of 30% for solar projects sited on brownfields, were pivotal in financing the project. In addition, the site's classification as an energy community in May 2024, based on updated employment codes and regional unemployment data, enabled the project to access an additional 10% ITC.

By providing fair-paying jobs during the construction phase of the development under the IRA’s prevailing wage requirements, the project underscores the ways in which these projects can benefit local workforces. These jobs not only supported the solar industry but also contributed to skill development in clean energy construction, fostering a workforce prepared for future renewable energy projects.

Innovative Engineering for a Challenging Site

Engineering a solar project on a landfill requires creative solutions to ensure that the integrity of the capped landfill is maintained, and this site was no different. The resulting design involved a ballasted ground-mounted solar system — the industry standard for these types of projects — ensuring that no penetrations were made into the landfill cap and thereby protecting the underlying waste containment systems.

More pressing, though, was the fact that portions of the site remained active, which meant navigating a web of existing infrastructure. The presence of active gas flares, groundwater monitoring wells, and at-grade gas lines required the developers to work diligently to obtain all required permits and approvals and bring the projects to notice to proceed while minimizing disruption.

With the development process successfully navigated, AC Power was ready to sell the project, which would commence construction and lock in a long-term owner-operator. They found just that in Calibrant Energy, who would purchase the project in late 2023, and with Montante Solar on board as the EPC, the team was ready to break ground and get the energy flowing.

Community Benefits

The resulting project will bring renewable, discounted energy to more than 2,300 homes, enabling this community to directly share in the benefits of a decarbonized economy. In accordance with New York’s community solar guidelines, more than half of the project’s subscribers will be Low- to Moderate-Income, further democratizing the energy transition.

The projects’ combined 13.5 MW-dc capacity translates to significant CO2 offset — approximately 3,630 metric tons annually, equivalent to removing 789 cars from the road each year or planting over 93,000 trees. Such impacts directly support New York State’s Climate Leadership and Community Protection Act CLCPA, which aims to achieve 70% renewable energy by 2030 and reduce greenhouse gas emissions by 85% by 2050.

AC Power, along with outside counsel, worked with the town to implement a Payment In Lieu of Taxes agreement, an alternative revenue stream structure that provides municipalities with stable income over the life of the agreement. The PILOT agreement established an annual payment structure that will pay out more than half a million dollars to the Town and the Wheatfield School District over the next 15 years, which can be reinvested into community infrastructure and services. This arrangement ensures a predictable revenue stream for the town and school district, contributing to local services without increasing the tax burden on residents.

Additionally, Niagara County recently introduced a local ordinance, the first of its kind, requiring solar developers to have an end-of-life recycling plan for their projects. In compliance, Solarcycle contributed a decommissioning plan to the project to ensure that when the array has exhausted its abilities — in as soon as 25-30 years — the solar panels will be responsibly recycled. What this means is that Calibrant, as the long-term owner-operator of the project, will work with the Town to keep the panels from simply ending up in another landfill. This initiative sets a precedent for future solar projects and emphasizes the importance of sustainable practices throughout the project's lifecycle.

Lessons for the Future

The Pine Avenue Landfill project serves as a blueprint for how towns across the country can transform underutilized and problematic sites into renewable energy assets. The following key takeaways highlight the lessons learned from this project:

1. Creative Engineering Solutions: Developing solar on capped landfills requires unique engineering approaches that protect the integrity of the site. Ballasted ground-mounted systems and tailored layouts that accommodate existing infrastructure are essential in ensuring the project can be built without disrupting the landfill's containment systems.

2. Community-Centered Development: Projects that bring tangible community benefits — such as consistent revenue through PILOT agreements and clean, affordable energy for residents — are more likely to gain local support. Ensuring that Low- to Moderate-Income households benefit from the energy produced fosters community buy-in and equity in the renewable energy transition.

3. Sustainable Lifecycle Planning: A commitment to sustainability must extend beyond the operational phase of the project. Planning for the end-of-life recycling of solar panels and other components ensures that the project’s environmental benefits are maximized and that future decommissioning does not result in additional environmental burdens.

Conclusion: A Legacy of Resilience and Renewal

With Montante completing construction on the project in late October 2023, the project was ready to come online and start writing a new chapter in the region’s environmental history. The Pine Avenue Landfill solar project is a testament to the power of innovative partnerships and strategic policy support in transforming brownfields into assets. By working with Republic Services and local stakeholders, and by leveraging the opportunities provided by the IRA, the Town of Niagara has turned a site with a complicated past into a source of clean energy, community benefits, and economic opportunity.

The Author:

Alex Bazeley is the Marketing Manager at AC Power LLC. Alex is responsible for developing and executing strategies that enhance AC Power's brand presence and recognition in the brownfield solar redevelopment space. AC Power is a mission-driven, woman-owned solar development company specializing in projects sited on contaminated land, including brownfields, landfills, Superfund sites, and more.

What is water risk? Here’s how to understand and manage it.

Wed, 30 Oct 2024 18:21:35 GMT

by Christopher Dacey, Haley & Aldrich

Our communities, businesses, economies, and natural environment face growing water-related challenges and impacts.

These challenges are diverse and often disruptive, and they sometimes have devastating consequences for lives, livelihoods, and economies. Worldwide, over 90 percent of natural disasters are water- and weather-related, including drought, wildfires, pollution, and floods. In 2023, the National Oceanic and Atmospheric Administration confirmed 28 weather and climate disaster events that affected the United States, with losses exceeding $1 billion each. Since 1980, losses related to such events have exceeded $2.6 trillion.

As demand for water grows, infrastructure ages, and climate change makes water-related challenges more frequent and dynamic, such costs are likely to increase.

Also, there are many water challenges outside of natural disasters that can be disruptive and costly, such as contaminated water supplies, operational inefficiencies and upsets, evolving regulations and costs, environmental liabilities, and water security, that businesses must contend with regularly.

No aspect of our communities, economies, or environment is immune to both the need for water and its inherent challenges. This duality often confounds decision making due to conflicting stakeholder objectives and shifting priorities. From industrial, mining, and agriculture operations to technology, utilities, and energy producers, water security and stewardship are critical and growing concerns. The need for sustainable water management and resource protection is further amplified as water resources become stressed under increasing demands.

What is water risk?

The UN Global Compact’s CEO Water Mandate defines water risk as the possibility of an entity or asset experiencing a water-related challenge. These challenges take many forms:

Water supply accessibility and reliability, driven, for example, by inadequate water storage or treatment systems, groundwater depletion, imperiled surface waters, and competing demands from agriculture, industry, urban areas, and environmental protection.
Water supply quality, which can be degraded by salinity, pollutant discharges, aging infrastructure, and poor waste management.
Flooding, a growing threat as sea levels rise, flood patterns change, and storms intensify with climate change. Flooding often disproportionately affects vulnerable populations.
Infrastructure failure, a potential consequence of extreme weather events.
Droughts, which, due to climate change, may become more intense and increasingly impact geographical areas unaccustomed to drought stress.
Regulatory discharge limits, which may necessitate water treatment, regulatory tracking, and sampling programs for compliance.
Supply chain disruption, which could follow floods or storms and impact transportation networks or vulnerable suppliers at any point in an operation’s supply chain. A common example is food supply disruption due to drought, freezes, and flooding.
Energy-water nexus challenges, because energy is required to withdraw, treat, and distribute water to the point of use, and energy is also consumed as water is used in industrial, manufacturing, agricultural, and cooling processes. Likewise, water resources serve a critical role in the generation of electricity and the production of fuels and can significantly affect the reliability and resilience of energy systems.
Regulatory uncertainty driven by changing administrations, policies, permitting requirements, regulations, legal challenges, and interpretations.
Knowledge management due to, e.g., employee turnover, reorganization, poor data management, and technology transitions.

Community opposition to infrastructure modernization or other development projects.

These challenges can evolve slowly — as in the case of a water supply dwindling over years of drought — or occur abruptly, as in the case of flooding caused by a storm. The extent of the risk involved is a function of the likelihood of a specific challenge occurring and the severity of the challenge’s impact, which, in turn, depends on the intensity of the challenge and the vulnerability of the stakeholder or asset. Simultaneous or frequent challenges — such as more frequent and intense storm events — can amplify impacts.

When it comes to water, standard risk management approaches — including avoidance, mitigation, transference, and acceptance — present unique challenges and opportunities. Past risk assumptions may not be appropriate for many locations and industries due to evolving uncertainties and knowledge.

How can you manage water risk and make operations more resilient?

Given that water risk encompasses such a wide, sometimes competing range of challenges, operations need multidisciplinary expertise and a holistic approach to properly integrate best practices for resource and risk management. They also need to ensure that the risk management strategies they adopt today can adapt to the uncertainties of tomorrow.

The following steps can help manage water risk:

Understand your vulnerabilities. We can think about water risk in four major categories: physical, regulatory, reputational, and technological. All four elements are interrelated, but an understanding of each can guide priorities and create a big-picture view of your current risk profile.

Physical risk. As the most visible aspect of water risk, physical risk often manifests as the effects of flooding, drought, landslides, inadequate infrastructure, erosion, water stress, ecosystem vulnerability, and water quality. Familiar examples of risk mitigation measures include engineering structures for flood protection or securing more reliable water supplies.
Regulatory risk. This aspect encompasses concerns such as evolving regulations, rising water costs, regulatory permitting uncertainty, water laws, and water allocation limits. The administration of water rights, laws, and regulations can vary significantly across jurisdictional boundaries, which can contribute to compliance and operational challenges.
Reputational risk. Given water’s centrality to healthy, prosperous communities and the increased public scrutiny of corporate environmental, social, and governance concerns, including environmental justice, projects that impact water supplies can draw intense scrutiny from local communities and other partners. Reputational risk factors include potential community opposition, shareholder concern and litigation, creditworthiness, insurability, and investment community expectations.
Technological risk. This risk area encompasses data governance, decision barriers, knowledge gaps, data quality, technology debt, technology transition, and change management. In other words, does a company have the right technology and practices in place for informed operational, compliance, and safety-related decisions as water challenges arise? Effective decision support solutions require careful assessment and implementation to prove useful and provide value.

Assess your vulnerabilities to find your opportunities. A systematic look at each risk area mentioned above can help operations find where they are most vulnerable, which, in turn, can help prioritize mitigation efforts.

A risk assessment can also help you identify the vulnerability of assets to water stranding, that is, assets that have or could stop producing a return due to a water-related event, such as flooding, inadequate water supply, poor water quality, or regulatory noncompliance. Without proactive actions, stranded assets can evolve into long-term liabilities.

A thorough understanding of your risk can also reveal water-related opportunities: the possibility that you can drive value and positive outcomes through better water management.

What is a water opportunity?

With proper planning, tactics for managing risk can accomplish multiple goals — increasing the efficiency of your current water use, making progress toward internal sustainability commitments, and helping you better mitigate water risk.

Water opportunities can include:

Efficiency gains. These gains include cutting water use by modernizing systems and practices to eliminate leaks and waste, performing regular water audits, and co-optimizing water and energy efficiency.
Recycling, reclamation, and restoration. These opportunities also increase efficiency and can make your site more self-sufficient or protected in the event of a water-related emergency. For example, a restored coastal marsh can mitigate the impacts of storms and flooding.
Opportunities to benefit your community. For example, that same restored coastal marsh could provide your community with recreation and wildlife habitat.
Risk mitigation cost sharing. Federal and nonfederal funding programs, such as EPA brownfields, stormwater, and infrastructure grants, offer cost-sharing opportunities, some of which can pair risk mitigation with conservation efforts. Stakeholder collaboration can also achieve mutually beneficial outcomes.
Nature-based solutions. Green roofs, permeable pavement, bioswales, and other green-design choices can protect water quality and offer side benefits, such as better air quality, wildlife habitat, and aesthetic appeal.
Technology sharing and leveraging. Properly aligned technology can provide cost savings while mitigating water risk — such as a water monitoring program that informs compliance and operational decisions or sharing information with stakeholders for transparency or to inspire innovative solutions.
A chance to employ the best available science and practices. A growing wealth of resources is available to guide risk mitigation and adaptation investment decisions.
Lower insurance costs. Demonstrating proactive water risk reduction measures can lower insurance costs and validate insurability.
Safer operations. Effective water risk mitigation protects people, assets, businesses, and the environment.
Future cost avoidance. By planning today, you can incorporate water risk reductions and sustainability into ongoing improvement plans to reduce future costs or build a water-resilient supply chain to protect future revenues.
Better monitoring of industry and international standards. The Alliance for Water Stewardship, the Global Reporting Initiative, the Sustainability Accounting Standards Board, CEO Water Mandate, and many other bodies offer regulatory and industry guidance related to water risk. Operations increasingly need to account for and disclose their sustainability, water stewardship, and water risk and opportunity initiatives. Tracking those standards and understanding your current state can build a more robust, accurate reporting structure.

The Author:

Christopher Dacey is a Technical Expert, Senior Hydrogeologist with Haley & Aldrich.

Both Urban and Rural Communities can Benefit from Brownfield Redevelopment

Wed, 30 Oct 2024 18:11:16 GMT

By Keith Ziobron, PE and Samantha Miller, PE, CHA Consulting, Inc.

According to the EPA, there are an estimated 450,000 brownfields in the United States. They can be found in both urban and rural communities, and they range in size from small corner filling stations to former locomotive manufacturing facilities covering hundreds or even thousands of acres. These properties have often been vacant and underutilized for decades. Regardless of size, history and location, their common trait is that they could be complicated to reuse or redevelop due to known or perceived environmental conditions.

Urban brownfield sites are often former industrial sites. They frequently sit in the center of our cities but remain dormant due to the presence of contaminated soil or groundwater, asbestos-containing materials, and/or mold infestation. Perhaps there are dilapidated buildings still standing, long-forgotten underground infrastructure, or years of waste and junk that must be removed before a site is ready for redevelopment.

Rural brownfields are present in nearly every downtown main street where the populations have dwindled or are located along defunct railroad tracks or our rivers. These sites are often hidden by decades of untended brush and vegetation that doesn’t entirely cover the remnants of the past.

Urban, rural, or somewhere in between, there’s funding available to communities to help them transform these sites into community assets. While some see insurmountable obstacles to reviving these sites, community leaders with vision see limitless opportunities. Two recent case studies, one from Downtown Syracuse, New York, and one across the country in the City of Chiloquin, Oregon, demonstrate the successes that a community can achieve when visions are harnessed and available resources leveraged.

Syracuse, New York

The City of Syracuse is experiencing a rejuvenation with investment in the local economy and revitalization of its downtown. A big part of this revitalization began with the JMA Wireless Tech Campus, which has been a cornerstone of the efforts to foster economic growth, innovation, community development, and stimulate further economic activity and job growth for the city.

The JMA Wireless Tech Campus was developed at 140 Cortland Avenue, a former brownfield site that has been redeveloped into a state-of-the-art 5G manufacturing facility with modern offices and showrooms. This is just the beginning of what the city hopes will be a national hub for 5G technology.

This brownfield site, a former industrial laundry, required a comprehensive remedial investigation, alternative remedial analysis, and a comprehensive remedial design work plan through the New York State Department of Environmental Conservation Brownfield Cleanup Program. Historical industrial use of the property resulted in soil, groundwater and soil vapor contamination, primarily chlorinated solvents. Site investigation activities included an extensive soil and groundwater investigation and included the removal of six underground storage tanks, source area treatment via deep soil mixing with zero-valent iron for one plume area, and ex-situ chemical oxidation with groundwater extraction and injection system for a second plume area. As the redevelopment construction progressed, a sub-slab vapor mitigation system and soil cover system were installed on the site for long-term controls.

Following site cleanup, the project focused on the design, permitting and construction of a modern 80,000 SF headquarters and manufacturing facility, including the associated infrastructure for water, sewer, gas, electric, telecommunications, and fire. Infrastructure improvements included new traffic signal design, sanitary sewer lining, and reconstruction of existing 8” and 24” water mains for the city.

The JMA project has served as a catalyst for further investment in the city. Syracuse was recently awarded $40 million in federal funding under the CHIPS and Science Act and $8 million from the State of New York to continue to bolster the semiconductor industry in the region. This added investment is a continuation of the revitalization initiated by the JMA Wireless Tech Campus and the vision of community leaders to bring prosperity and jobs to their city.

Chiloquin, Oregon

As a rural community with a population of just under 800, Chiloquin, Oregon, has leveraged a series of state and federal funding sources to access nearly $1.2 million to date to catalyze redevelopment in their blighted downtown area. More specifically, Chiloquin’s brownfield program is cleaning up two key properties centrally located in the city and has assessed 10 additional properties. To date, the City of Chiloquin has been able to leverage an array of state and federal funding, including:

1. A $60,000 Business Oregon Assessment grant for the pre-acquisition due diligence of the former Markwardt Brothers Garage site.

2. A $300,000 EPA Community-wide Assessment grant.

3. A $402,500 EPA Cleanup grant for the former Markwardt Brothers Garage.

4. A $200,000 Business Oregon Cleanup grant for removal of asbestos-containing debris associated with the collapsed Chiloquin Mercantile Building.

5. A $200,000 Business Oregon Cleanup grant to supplement the EPA Cleanup grant for the Markwardt Brothers Garage.

With cleanup complete, the City of Chiloquin has applied for a $15 million EPA Community Change Grant to fund the design and construction of a state-of-the-art community resilience center. Chiloquin is an admirable example of a rural community taking charge of its brownfields and creating something valuable for the future. In fact, the City of Chiloquin was just awarded the 2024 Outstanding Oregon Brownfield Project of the Year at this year’s Oregon Brownfield Conference.

With an eye on the future and the willingness to tap into available resources and brownfield cleanup expertise, other communities, urban like Syracuse or rural like Chiloquin, can realize a better future ahead for their residents.

About the Authors:

Keith Ziobron, PE, is a senior project manager and leads the brownfield program at CHA Consulting, Inc. He has over 38 years of experience in environmental engineering, including brownfield funding, assessment and redevelopment, remediation services, environmental compliance and permitting, and planning/economic development-related services. Keith has been helping secure and manage USEPA Brownfield grant funding since 2001. In all, he has assisted more than 25 communities to establish Brownfield programs and is currently managing four EPA Community-wide Assessment grants, two EPA Brownfield Cleanup grants, and three EPA Revolving Loan Fund grants. You can reach Keith at kziobron@chasolutions.com or 678-787-9576.

Samantha Miller, PE, is a senior engineer at CHA Consulting, Inc. She has 12 years of experience providing engineering services for environmental projects, including performing environmental monitoring, construction observation services, remediation system designs, bulk storage tank inspections, developing site management plans, and regulatory negotiation and coordination. Samantha has worked on various regulated sites, including petroleum and chemical remediation sites, tank cleanup sites, solid waste facility closures, and vapor intrusion mitigation projects. You can reach Samantha at smiller@chasolutions.com or 315-257-7154.

The Authors:

NJ’s Land Use Permit Acquisition Process Complicated by Proposed Reforms to Protection Rules

Thu, 17 Oct 2024 17:49:24 GMT

By Christina Sartorio Ku - Connell Foley

Reforms contained in a rule proposal to modernize land resource protection rules will significantly impact land use developments throughout New Jersey, making the Garden State’s permit acquisition process even more challenging and difficult to navigate than it is now.

The proposed reforms, known as the Resilient Environments and Landscapes (REAL) rules, are intended to better protect New Jersey communities from coastal flooding, sea-level rise, and other public health and safety risks arising from climate change. Announced by Governor Phil Murphy and Commissioner of Environmental Protection Shawn M. LaTourette in May, and published in the New Jersey Register on August 5, 2024, the REAL rules are a result of the New Jersey Protecting Against Climate Threats (NJ PACT) initiative. If enacted, they would amend New Jersey’s existing flood hazard, stormwater, coastal zone, and freshwater wetland regulations statewide to address climate change impacts, improve water quality, increase flood protections, and address issues specifically impacting overburdened communities.

The REAL rules would amend existing law to increase flood protections in several ways, including by:

creating an “Inundation Risk Zone” (IRZ) regulated area within tidal flood hazard areas that would encompass land currently above sea level likely to be inundated during high tides during the life of the proposed development. New or improved developments within the IRZ will need to meet specific standards intended to address the increased flood risk that people and property are exposed to due to expected sea level rise and more intense storm events.
redefining the extent of tidal flood hazard areas and replacing the existing “flood hazard area design flood elevation” with a proposed “climate adjusted flood elevation” that is calculated by adding five feet to FEMA’s 100-year flood elevation in tidal flood hazard areas.
expanding riparian zone buffers and imposing stricter limitations on wetlands and stormwater management, particularly in environmentally sensitive areas. For example, the rule imposes a 3% impervious cover limit in new “Critical Environmental Sites” and enhances the requirements for stormwater management in redevelopment projects.
aligning New Jersey’s floodplain management efforts with the National Flood Insurance Program’s (NFIP’s) minimum standards, as established in the rule or floodplain ordinance for the community where the site is located.

Other proposed changes include replacing the term “permit-by-rule” under the Coastal Zone Management Rules (N.J.A.C. 7:7) with the new term “permit-by-registration,” which requires applicants to submit compliance information to the New Jersey Department of Environmental Protection (NJDEP) for tracking of regulated activities throughout the State. Under the Freshwater Wetlands Protection Act Rules (N.J.A.C. 7:7A), the proposed rules would require applicants to demonstrate why a project necessitates impacting wetlands, regardless of whether all other criteria under the rules are met; the reforms also require that all proposed activities in transition areas be situated at least 25 feet from any freshwater wetlands.

Finally, pursuant to the Flood Hazard Area Control Act rules (N.J.A.C. 7:13), the REAL rules would regulate isolated waters draining less than 50 acres, removing the exception for work located within 25 feet of a bulkhead, retaining wall, or revetment along a tidal or impounded fluvial water.

The NJDEP is accepting public comments to the proposed rules until November 3, 2024. If the NJDEP does not make any substantive changes to the proposed rules upon review of the public comments, these rules may be adopted and effective as early as the spring or summer of 2025. Pursuant to the regulations, any application submitted to the NJDEP after the effective date of the adopted rules, or any application that has not been deemed administratively complete by that date, will be subject to the new rules.

The Author:

A partner in Connell Foley LLP’s Environmental Law Group, Christina Sartorio Ku is an accomplished litigator who leverages her background in biological sciences and environmental regulation to represent parties in complex environmental cases involving CERCLA, the New Jersey Spill Act, the New York Navigation Law, ISRA/ECRA, RCRA, among other laws. A member of BCONE, Christina regularly provides counsel on regulatory enforcement and compliance matters involving site remediation and hazardous waste, and advises clients involved in federal and state cost-recovery and contribution claims. She works with private clients as well as state and federal regulators to resolve land use issues, including matters related to permits, waterfront development and public access easements. Christina can be reached at CSartorio@ConnellFoley.com

Connell Foley LLP's Environmental Law practice is fluent in all federal, state and local environmental regulations. The firm’s Environmental Law team brings decades of experience to bear on behalf of clients grappling with regulatory compliance, intricate litigation, brownfield redevelopment and transactional due diligence issues, as well as spills and other environmental matters. You can learn more about the group here: https://www.connellfoley.com/practices-environmental-law

Chicopee’s Willimansett Brownfields Area-Wide Plan: How Brownfields Can Become Catalysts for Neighborhood Reinvestment

Thu, 17 Oct 2024 17:38:35 GMT

by Cassie Bethoney - Weston & Sampson

Like many mill towns in the region, the neighborhood of Willimansett in Chicopee, Massachusetts followed a pattern of urban development and had been one of the area’s most thriving industrial centers for over a century. During that time, the neighborhood was almost entirely built out with few land parcels left undeveloped. However, during the mid-20thcentury, businesses began closing, leaving these industrial facilities and structures empty and unused. This situation has continued to impact the neighborhood’s traffic patterns and demographics, which was exacerbated by its bounds - major highways and infrastructure to the north, east, and south and the Connecticut River to the west. Many original settlers in the area moved away, and the neighborhood evolved into a home for a new wave of immigrants from Caribbean and Latin American nations.

This story is not new. Industry evolves. The demographics of a neighborhood change over time, yet so much potential is tied up in these foundational ‘bones’ of developed land. What some might see as blight – brownfields – are actually opportunities in disguise. The Willimansett Brownfields Area-Wide Plan (AWP) positions five brownfield sites as catalysts for reinvestment in a way that both honors the neighborhood’s industrial past and those who live there today.

While Willimansett may be challenged in some respects, it has much to offer, from fantastic open spaces, walkability, and a connected commercial corridor, to a shifting demographic just waiting for their culture to be expressed in their surroundings. A younger population means more families, more working age adults, and more community activity, which can provide the energy and entrepreneurism to fuel future growth and prosperity in Willimansett and throughout Chicopee. Housing, jobs, community goods, and services – these things can thrive in the underutilized buildings and vacant brownfields of the neighborhood and are the critical elements of any vibrant neighborhood. This ambitious project is seen as a vital step toward creating a vibrant, connected, and thriving community in Chicopee.

The Willimansett Brownfields AWP, funded by a $300,000 U.S. EPA Community Wide Assessment Grant, presents a strategic roadmap to assess, clean up, and/or repurpose the catalyst brownfield sites for new housing, commercial development, approachable streetscapes, and green spaces. The five key takeaways from the plan are summarized below:

1. Community-Led Approach: One of the most notable aspects of the plan is its foundation in neighborhood voices. Business owners and local residents, especially those typically hard to reach, shaped the redevelopment strategy to ensure that any transformation set for the neighborhood aligns with the needs of those who live and work there. “We see this as an opportunity to not only clean up these sites but also to foster a new sense of community,” said Mayor John Vieau.

Engagement was challenging during the planning process. Early on, the project team realized that the standard methods of engagement wouldn’t work in a high renter neighborhood where English is often not the main language spoken at home. A pivot toward strategically aligning with existing community events and asking quick and simple questions (alongside beautiful graphics) was the key to success. By the end of the planning process, the team made just under 2,000 connections.

2. Boosting Economic and Social Vitality: Both public and private investment are leveraged in this plan, which will create job opportunities, increase affordable housing, and revitalize the local business scene. Five key brownfield sites have been identified as catalysts for change, with redevelopment plans that include residential units, commercial spaces, recreational facilities, and artful expression of neighborhood culture. These sites have the greatest immediate potential for reuse and their redevelopment would be transformative for Willimansett. Some of the key potential benefits to redevelopment identified across the five sites are the following:

Many sites are in well-known and visible locations, offering the potential to stimulate additional investment and revitalization in the area, including the sustainable reuse of already developed land.
For sites near the Connecticut RiverWalk and Bikeway, this frontage provides opportunities to create visual and physical connections to the waterfront. This offers unique opportunities for dining, and small businesses would benefit from proximity to the RiverWalk and Bikeway.
Redevelopment of these sites allows for mixed-uses, including both residential and commercial. This contributes to job creation, shopping and dining options, and addresses the city’s existing housing demand.
Residential development could be higher density than single-family. The reuse of these sites also provides an opportunity for affordable housing and home ownership.
Improved streetscape and landscape features like tree plantings, bike amenities, and concessions can improve aesthetics and attract businesses and tenants.
Improved streetscapes can also enhance bicycle and pedestrian safety.

These projects are expected to draw more residents and visitors to the area, fueling local economic growth.

3. Environmental and Public Health Gains: Cleaning up hazardous brownfield sites also promises significant environmental and public health benefits. The plan will reduce contamination risks and transform neglected properties into safe, usable spaces for the community.

4. A Focus on Connectivity: Improving infrastructure and neighborhood connectivity is a core component of the plan. Enhanced pedestrian pathways, bike lanes, and public transportation routes are proposed to better integrate Willimansett with the rest of Chicopee. The Connecticut RiverWalk and Bikeway, which runs along the neighborhood, will become even more of an asset than it already is by offering residents easier access to a network of recreational opportunities.

5. Cultural and Social Revitalization: In addition to economic and environmental goals, the plan emphasizes the importance of preserving Willimansett’s cultural heritage and finding creative ways to express the cultures of those currently living in the neighborhood. People invest in a place when it reflects their values. Public art installations, community events, and green spaces are part of the strategy to celebrate the neighborhood’s diverse population while fostering a strong sense of social cohesion. As the community becomes more diverse, it is essential to acknowledge Willimansett's industrial past while embracing new cultural identities. This balance will breathe new life into the neighborhood.

Looking ahead, the plan sets a precedent for urban redevelopment projects across the region. Willimansett’s transformation will not happen overnight, but this plan is a call to action. It is about creating a future where this neighborhood can thrive economically, environmentally, and socially. With a clear vision in place, the Willimansett Brownfields AWP represents a bold step toward a brighter future for one of Chicopee’s most historically rich neighborhoods and can be a model for other cities faced with similar challenges.

For more information about the Willimansett Brownfields Area-Wide Plan, visit the City of Chicopee’s website or contact the Department of Planning and Development at https://chicopeema.gov/365/Planning-Department.

The Author:

Cassie Bethoney, RLA, is a Registered Landscape Architect and Project Manager with Weston & Sampson. She can be reached at bethoneyc@wseinc.com.

How-to Guide: Prepare Funding Applications for the 2025 EPA Brownfield Grant Competition

Thu, 17 Oct 2024 17:30:05 GMT

by Andrea Pedersen - Montrose Environmental

Brownfield Grants provide a unique opportunity to transform contaminated and underutilized properties into vibrant community assets. By understanding the various types of grants available and leveraging expert assistance, your community can effectively navigate the upcoming Brownfield Grant competition and maximize your chances of securing funding!

The EPA’s annual Brownfield Grant competition takes place in the fall. The Notice of Funding Opportunity (NOFO) is usually released between August and October, with applications due 8-10 weeks afterward.

Starting your preparations for the FY2025 Brownfield Grant competition well ahead of the deadline significantly boosts your chances of success. Early preparation allows ample time for comprehensive planning, engaging with the community and stakeholders, and crafting a compelling and thoughtful narrative. Continue reading to learn the best steps to take while preparing your application!

Identify key elements of your application.

Crafting a successful Brownfield Grant application requires strategic planning and the expertise of experienced grant writers. One of the first steps is to clearly define the project boundary and objectives. Presenting a well-defined target area and setting realistic goals for your project helps reviewers understand the scope and intent of your proposal. Additionally, providing compelling data to demonstrate the community’s need for the project is crucial. This could include statistics, case studies, or other relevant information that highlights the importance of the redevelopment.

Describing the key outcomes of the project and the benefits it will bring to the community is another essential element. This could include economic growth, environmental improvements, or social benefits. Equally important is outlining your strategies for engaging key stakeholders and educating community members about the benefits of brownfield redevelopment. Involving a diverse group of voices on the project steering committee ensures broad support and strengthens your application.

A comprehensive project plan and detailed budget are also vital. Detail the steps involved in the assessment, cleanup, and redevelopment process, and provide a realistic budget that aligns with the proposed activities. Highlighting your past successes in managing other state or federal grants demonstrates your capability and reliability to potential funders. Finally, crafting a thoughtful narrative that includes a consistent theme throughout each section of the grant application will keep the attention of reviewers and help you score maximum points.

Find the right tools and resources to prepare your application.

To assist in the preparation process, the EPA’s Brownfields Program website offers guidelines, FAQs, and examples of successful applications, providing a wealth of information to help you get started. Grant writing workshops are another valuable resource, offering training on how to write compelling proposals with tips and best practices from experienced grant writers. Additionally, the EPA has dedicated Technical Assistance providers in each region who can connect you with grant writing services and review your draft application prior to submission.

Explore other EPA funding opportunities.

The EPA has introduced several new funding opportunities and program enhancements for FY2024 and FY2025. Up to $20 million per project is available to support redevelopment in historically marginalized communities affected by legacy pollution and climate change. Over $20 million is allocated for Tribes and Alaska Native Corporations to assess and clean up contamination on lands conveyed under the Alaska Native Claims Settlement Act. Additional funding is available for training residents in environmental remediation and green jobs. Enhanced support is also provided for communities needing help with grant applications and project planning.

Now you have it! The steps to take while preparing for your funding application. Be sure to reach out to the Montrose Brownfields team if you are ready to engage expert funding consultants. Brownfield Redevelopment Service & Consultants | Montrose Environmental (montrose-env.com)

The Author:

Andrea Pedersen is a distinguished Principal Environmental Professional and Brownfield and Community Revitalization Specialist with over 18 years of experience. Throughout her career, she has successfully assisted with over 50 EPA Brownfield Grant applications, securing over $72 million for communities across Hawaii, Alaska, Washington, California, Utah, Colorado, Texas, Pennsylvania, West Virginia, Virginia, Delaware, New York, and Vermont. Andrea thrives in diverse roles and responsibilities, including project and grant management, grant writing, business development, and program coordination. Andrea has cultivated strong relationships with repeat clients who trust her expertise in securing and effectively utilizing various federal, state, and local funding resources. Her work is instrumental in helping these communities build programs and achieve their restoration and revitalization goals. In addition to her prowess in grant management, Andrea delivers a wide array of technical services related to brownfield assessment and cleanup projects. She excels in developing work plans, Quality Assurance Project Plans, and Sampling and Analysis Plans. Andrea also oversees grant management and compliance reporting, community engagement, site inventory and prioritization, Phase I/II Environmental Site Assessments, cleanup and reuse planning, and area-wide planning activities.

What the New Jersey Inland Flood Protection Rule means for property owners and developers

Thu, 17 Oct 2024 17:24:02 GMT

by Dr. Daniele Spirandelli - Haley & Aldrich

The New Jersey Department of Environmental Protection (NJDEP) in July 2023 adopted a new rule aimed at enhancing inland flood protection measures in the state (New Jersey Administrative Code [NJAC] 7:8 and 7:13). The rule is intended to mitigate the effects of increased extreme precipitation events due to climate change, such as Tropical Storm Ida, which, in September 2021, caused widespread damage to communities and infrastructure in fluvial flood areas (areas where rising waters in lakes, rivers, or streams cause flooding).

The NJDEP Inland Flood Protection Rule has significant implications for owners and developers of manufacturing, commercial, and industrial properties, who need to understand how the rule may impact their operations. In this article, we will discuss the key aspects of the rule and its potential effects on real estate owners and developers.

Key aspects of the New Jersey Inland Flood Protection Rule

The NJDEP Inland Flood Protection Rule outlines requirements and standards for new construction projects, as well as for the modification of existing buildings in flood-prone areas. The rule would not apply to new construction and certain renovation projects that:

Would require and have received approval for flood hazard area (FHA) applications submitted prior to the effective date of the rule.
Have received all federal, state, and local approvals required for construction.
Have commenced construction activities prior to the effective date of the rules.
Were not considered part of a regulated FHA prior to the effective date of the rules.

Key aspects of the rule include the following:

The rule sets the required design flood elevation for occupiable building space and critical equipment to include a 2-foot factor of safety above 100-year fluvial base flood elevations mapped by NJDEP, (there is currently no elevation increase required), and a 3-foot factor of safety above 100-year fluvial base flood elevations mapped by the U.S. Federal Emergency Management Agency (up from the 1-foot elevation increase required currently). Tidal flooding requirements remain unchanged as part of this rule.
As under current requirements, the design flood elevation can also be determined by a licensed engineer. The rule would require the licensed engineer to also adjust for future precipitation depth using projected future rainfall to calculate the 100-year peak flow rate, plus a factor of safety, as part of a hydraulic analysis. The future rainfall would be calculated using future precipitation depth adjustment factors published for each county by NJDEP to account for climate change impacts.
Stormwater best management practices (BMPs) will be required to manage runoff from increased current design storms (i.e., hypothetical storm events) as well as future design storms, using current and future precipitation depth adjustment factors published for each county by NJDEP.
Stormwater runoff can no longer be calculated using the rational or modified rational methods.
Permits-by-rule, general permit, individual permit, or general permit-by-certification will be required to comply with applicable construction standards of the Uniform Construction Code (NJAC 5:23) and federal flood reduction standards (44 Code of Federal Regulations Part 60).

Impacts for property owners and developers

The NJDEP Inland Flood Protection Rule will likely have significant impacts on commercial, manufacturing, and industrial property owners and developers. These effects could include:

Higher construction costs. Compliance with the new flood protection standards and stormwater BMPs will likely increase construction costs, especially for projects in flood-prone areas. Developers may need to invest in additional engineering, design, and construction measures to meet the new requirements, such as floodproofing or elevating critical equipment and increasing stormwater detention capacity.
Delays in construction. Meeting the new flood protection standards may require additional time for design, approvals, and construction. This could result in delays in project timelines, which can affect project profitability.
Changes in property values. Properties located in flood-prone areas may experience changes in value because of the new flood protection standards. Buyers and sellers may need to factor in the cost of compliance with the new requirements when negotiating deals.
Compliance challenges. Compliance with the new flood protection standards may challenge some real estate owners and developers, especially those with existing buildings in flood-prone areas. Retrofitting existing buildings to meet the new standards may require significant investment, which could be an obstacle to compliance.

How owners and developers can prepare for the New Jersey Inland Flood Protection Rule

The rule represents a significant development for manufacturing, commercial, and industrial properties in the state. Stakeholders should be aware of the new requirements and understand how those requirements could affect their operations. By proactively considering property flood exposure and evaluating stormwater management practices and flood resilience measures, real estate owners and developers can better prepare for compliance and mitigate any potential negative effects on their operations.

Please contact the author of this article for more information on this rule and how to prepare.

The Author:

Daniele Spirandelli, Ph.D., is a strategic, systems-oriented resilience planner at Haley and Aldrich who enjoys working with a diverse range of clients and stakeholders to address their concerns about climate change. She has worked with a variety of communities and institutions, including utility companies, real-estate developers, county planners, and community-based organizations, and she is a member of the ASTM International subcommittee focused on standard guidance for property resilience assessments. With over a decade of experience applying climate science and adaptation considerations across private and public sector operations, assets, and hazard mitigation and planning, Daniele is most passionate about approaching climate resilience holistically.

Environmental Justice Brings a New Dimension to Due Diligence and Risk Mitigation

Mon, 08 Jul 2024 15:19:36 GMT

by Dawn Santoianni, Principal Consultant; Heather Good, Associate, Hydrogeologist; and Sarah Sieloff, Technical Expert - Haley & Aldrich

How are you setting your strategy?

As environmental consultants, we hear questions from many clients about environmental justice (EJ). They’re wondering what the current focus on EJ means for them, whether that focus will continue, and how to create an effective and actionable EJ strategy.

EJ might seem like a new concept, but the term has been around for several decades. In recent years, EJ has risen in prominence at both the state and federal levels. Offices of Environmental Justice have formed within multiple agencies, laws have been passed, policies have changed, and grant guidelines have shifted. With over four decades of combined experience tracking environmental trends and forging constructive stakeholder relationships, we can confidently say that the current policy focus on EJ will not fade.

There are multiple benefits to developing an EJ strategy. Developers who don’t pay attention to the evolving EJ landscape may face permitting, enforcement, reputational, and relationship risks. And on the flip side, a focus on EJ doesn’t have to be a protective maneuver — it can also support your firm’s environmental, social, and governance (ESG) goals, bolster stakeholder relationships, and make meaningful improvements in communities.

With the current and anticipated ongoing focus on EJ, understanding how you can position your organization is more important than ever.

Staying current in an evolving landscape

In practice, EJ will look different for different communities, sites, and development plans. For example, some will focus on risk mitigation or pollution prevention. Others will need to make improvements that address the underlying factors contributing to a community’s EJ concerns — lack of green space, traffic generated by construction or the completed devleopment, or legacy contamination issues.

A key component of determining how your company might engage with EJ is understanding which communities have EJ concerns. EJ concerns in a community are typically characterized by harms and risks. Some communities are disproportionately affected by historical pollution burdens, which, when combined with socioeconomic stressors such as poverty, linguistic isolation, and lower levels of education, can result in more adverse health and economic impacts. However, there is no single definition of EJ, which is evident in the large number and variety of EJ screening tools that are available. Tools like the U.S. Environmental Protection Agency’s EJScreen or the federal government’s Climate and Economic Justice Screening Tool show how environmental and socioeconomic factors intersect across geographies. While these tools can provide data and perspective on community concerns, they don’t reveal everything, such as public sentiment or local data. Nor do these screening tools recommend specific actions or tactics. That’s where an EJ strategy comes in — it provides a roadmap for addressing EJ concerns.

Environmental Justice Mapping/Screening Tools for the BCONE geography

It’s challenging to keep up with and interpret state and federal regulatory, permitting, and funding actions on EJ. This is yet another reason companies can benefit from a proactive — not reactive — EJ strategy.

Working with public sector partners

With the rising prominence of EJ at the state and federal levels, there is an increased focus on EJ in the public sector. By preparing an EJ strategy, you can position yourself to work more productively with public sector partners.

Many federal grants now require applicants to demonstrate how EJ has shaped their application and will inform future projects. This is especially key as legislation like the Bipartisan Infrastructure Law and the Inflation Reduction Act continue to swell agency coffers with grant funding. There are also impacts at the state level, including funding and permitting decisions. As of early 2023, more than 20 states had enacted EJ policies that define EJ or overburdened communities; stood up dedicated EJ task forces, offices, and commissions; established screening tools, impact reports, and scorecards; and mandated community involvement in environmental and land-use decision-making.

Developing an EJ strategy speaks volumes, not only about your firm’s commitment to this issue but also about your knowledge of the wider policy and regulatory landscape. A programmatic or enterprise-level EJ strategy can also help support broader company ESG goals, build constructive relationships with the communities you serve, and maintain brand reputation with business partners, investors, employees, and other stakeholders.

Components of an effective EJ strategy

Your EJ strategy will be unique to your organizational and situational needs, but there are some common approaches and tools that we use when developing an EJ strategy.

Using EJ screening tools to understand local context

How we can think of EJ

Demonstrating care for our communities
Understanding community concerns relating to historical environmental liabilities and cumulative impacts
Informing mitigation and remediation solutions, getting community buy-in
Considerations for permitting new facilities, including renewables
Developing robust community engagement plans
Enhancing stakeholder relationships and reputation
Mitigating risk across our portfolio

The federal government and many states have developed publicly available EJ or equity screening tools that provide access to environmental, demographic, and socioeconomic data. These tools can help companies better understand the communities in which they operate and potential EJ risks.

While EJ screening tools can be a helpful starting point, they have several limitations and challenges. Each tool uses different datasets, and some require an experienced user to navigate them. They provide descriptive results but cannot be the only source of information — local data and public sentiment are also important. To fully understand their EJ risks, companies should conduct site-specific assessments. These assessments typically consider results from screening tools but supplement that information with site-specific factors such as current operations, potential community risks, and historical impacts.

Improving internal alignment

For companies just beginning to develop an EJ strategy, internal education is often an important first step. For example, we recently began helping a client develop its plan to address EJ concerns at sites across the country. In discussions with stakeholders, we learned that workers at those sites didn’t have a unified understanding of what EJ entails or why it matters to their work. We developed training materials and a workshop to facilitate alignment, which in turn has helped the company align goals and internal communications.

Developing a communications strategy

Sustained, responsive communication with community stakeholders and regulators is essential to EJ strategy. Companies could consider how they will prepare for tough questions about their own EJ track records, as well as about environmental and health issues not related to their operations: Communities will often bring all their concerns to the table, and companies need to know how to field questions on those concerns to foster good relationships and build trust.

From ESG to community engagement or permitting decisions, addressing EJ as part of your business strategy or operations is a critical business requirement, and it’s only going to become more essential moving forward. More information is better — for your firm, your community, your reputation, and your relationships.

The Authors:

	Dawn Santoianni, Principal Consultant - Haley & Aldrich
	Heather Good, Associate, Hydrogeologist; - Haley & Aldrich
	Sarah Sieloff, Technical Expert - Haley & Aldrich

The Due Diligence Implications of CERCLA Hazardous Substances Designation of PFOA and PFOS

Mon, 08 Jul 2024 15:08:26 GMT

by Rick Shoyer, LSRP, Montrose Environmental

On April 19, 2024, the U.S. EPA classified perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under CERCLA, also known as Superfund. This designation directly affects the scope of the ASTM E1527-21 Standard Phase I Environmental Site Assessment (ESA), mandating that PFOA and PFAS be included. Here are some key considerations in developing your due diligence strategy:

Know Where to Research Reportable Incidents

Entities must promptly report any new or ongoing releases of PFOA and PFOS exceeding 1 pound. Past releases require reporting only if they remain active. Knowing where to research the reportable incidents can aid in assessing risk.

Identify PFAS Uses

Identifying historical uses of PFOA and PFOS, and other PFAS, presents challenges due to their varied names and structures not always listed on Safety Data Sheets. Conduct thorough reviews of historical records, permits, and facility documentation to uncover past fluorochemical use. Interviews with long-term employees and visual inspections can provide additional insights.

Consider Consequences of Phase II Diligence

Before initiating Phase II investigations, assess contractual and regulatory risks, potential reporting obligations triggered by sampling, and implications for worker exposure and waste disposal.

Review the Regulatory Landscape

Familiarize yourself with TSCA requirements for reporting PFAS production, use, and disposal since 2011, and utilize EPA tools to identify nearby PFAS contamination sources.

As PFOA and PFOS become subject to heightened regulatory scrutiny, gathering and updating property information demands careful attention to new obligations and potential impacts on operations. Understanding these requirements is crucial before committing to further investigative steps.

About the Author:

Rick Shoyer has over 40 years of experience in investigating and remediating organic and inorganic substances, both in-situ and ex-situ. His current focus is on per- and polyfluoroalkyl substances (PFAS), 1,4-Dioxane, PCBs, chlorinated compounds, and hexavalent chromium. He provides technical assistance to a New York State city impacted by PFAS in its drinking water. His PFAS expertise includes surface water characterization, PFAS removal technologies like GAC and anion exchange resins, and fate and transport assessments. He has also researched alternative fluorine-free foams (FFFs) and aqueous film-forming foams (AFFFs). Mr. Shoyer chairs the Emerging Contaminants Treatment and Technology group and has presented at numerous forums. He is a Licensed Site Remediation Professional (LSRP) and N-2 Industrial Operator in New Jersey, with a Bachelor of Science in Engineering from Michigan State University.

You can learn about Montrose's PFAS solutions here: https://montrose-env.com/services/integrated-pfas-solutions/

NJEDA Releases First BRIP Funding Award

Mon, 24 Jun 2024 18:04:28 GMT

by Jeffrey Campbell, Peak Environmental, A Nova Group GBC Company

The New Jersey Economic Development Authority (NJEDA) kicked off the Brownfield Redevelopment Incentive Program (BRIP) in 2023 to provide funding to support redevelopment of under-utilized real estate in New Jersey. In May 2024 the program issued its first funding approval for a project in Elmwood Park, in Bergen County, New Jersey. The award was acknowledged as a great start for the BRIP by NJEDA CEO @Tim Sullivan, NJDEP Commish @Shawn LaTourette, and Bergen County Executive @Jim Tedesco. Also in attendance, @Mayor Robert Colletti confirmed the positive economic impact that the redevelopment will bring.

The Program will award up to $50M per year to fund project tasks from assessment through remediation, including demolition costs. BRIP funds can be stacked with other EDA programs, and the credit is transferable. Eligibility is very broad. The applicant does not need to own the property, but also cannot take title until a Redevelopment Agreement is signed. Successful applicants receive a one-time tax credit issued the year the remediation is complete. Similar to typical real estate projects, interested real estate developers should assemble a team of professionals to guide them through the application process.

The Elmwood Park project was supported by BCONE member companies Chiesa Shahinian & Giantomasi PC (“CSG Law”) and Peak Environmental, A Nova Group, GBC Company (Peak Environmental). CSG Law managed the application through eligibility requirements, environmental liability issues, financial aspects, developer qualifications, and environmental costs and planning. Peak provided due diligence services and conducted site characterization tasks necessary to complete a remediation cost estimate and schedule. Peak Environmental confirmed discharges occurred, provided an LSRP to oversee the project, evaluated possible off-site migration of contaminants, identified building material risks, and developed reasonable remediation costs. With the funding phase of the project complete, CSG and Peak Environmental will work with the developer to complete a remedial investigation, select a final remediation strategy, comply with green remediation requirements, obtain permits needed, and execute the remedial action.

About the Author:

Jeff Campbell is an environmental consultant with over 25 years of experience remediating soil, groundwater and vapor for industrial, commercial, and retail customers. Peak Environmental, A Nova Group GBC Company, provides high-quality, professional, and cost-effective consulting services related to identifying and remediating environmental liabilities. For more on Peak Environmental, please visit their website at: https://peak-environmental.com.

Link to NJEDA BRIP page https://www.njeda.gov/brownfield-redevelopment-incentive/

Link to CSG Blog https://www.csglaw.com/newsroom/csg-law-alert-csg-client-obtains-first-approval-under-the-brownfield-redevelopment-incentive-program/

Link to Peak Blog https://peak-environmental.com/2024/06/12/peak-environmental-supports-first-brip-financing-approval/

Brownfield Redevelopment – Sometimes it’s Not Just about Economic Development

Wed, 19 Jun 2024 15:02:32 GMT

by George Naslas, PG, LSP - Weston & Sampson

The redevelopment of brownfield sites is often associated with the revitalization of a property to bring it back into productive use, generate local tax revenue, and increase local employment. Redevelopment can also be part of a green or open space development, such as a riverwalk, park, or rail trail. Sometimes the conversion of a brownfield site into open space can be the catalyst required to help transform a neighborhood and spur economic development. In other cases, a brownfield site simply needs to be removed or cleaned up because it is a public nuisance and a blight on the neighborhood.

In the Village of Woodsville within the Town of Haverhill in northwestern New Hampshire, a derelict house along a former railroad corridor had been used for many years as a drug lab to manufacture and sell methamphetamines. The town fought to shut down the operation but was hampered by jurisdictional issues with law enforcement. Eventually, operations ended and the building lay dormant, obliging the town to take title. Now, what to do with the property?

When a community inherits a property with potential for legacy issues, the ability to sell it is often challenging. For many communities, this results in the parcel remaining abandoned and at risk for trespassers and arson. These risks put an additional burden on the community due to increased police and/or fire department presence.

For municipalities with limited financial resources, blighted properties like this can become a huge liability. For the Woodsville, the presence of this blighted structure was a blot on the landscape and a barrier to redevelopment along Railroad Street, which parallels Main Street and is highly visible.

Based on these factors, the town chose to demolish the building, but questions remained about the potential impacts to the site from the former drug manufacturing operations, which represented a barrier to the eventual sale of the property. Further complicating the matter, there were rumors of dangerous objects in the building and the possibility of an animal carcass buried in the yard. The town initially spent a significant sum to hire a contractor to decontaminate the building. Plus, there was a fuel tank in the dirt basement and indications of potential releases to the subsurface.

To remedy the situation, the town pursued and secured funds from the New Hampshire Department of Environmental Services (NHDES) Brownfields Program to assess the site for hazardous building materials and demolish the building so the subsurface below the building could be accessed.

Using the NHDES funds, combined with additional funds from the US EPA Brownfield Program, our team developed a sampling plan which was approved by the EPA. Because the building occupied about half the lot and there were other materials dumped at the site, including an abandoned trailer, sequencing of the project was important.

A hazardous building materials inventory was conducted inside the building to evaluate the presence of asbestos-containing materials, lead-based paint, and other wastes that would require removal prior to demolition. Following that, the building was sealed and placed under negative air pressure while asbestos and other materials were abated by a licensed contractor. Once it was demonstrated there was no residual asbestos, the contractor removed remaining materials from the site and demolished the building, filling in and grading the basement to prevent a dangerous condition.

Following demolition and site restoration, we further evaluated the site for the potential of lingering impacts from the drug manufacturing operations, such as volatile organic compounds. We also conducted a ground penetrating radar survey to identify potential buried objects and retained a drilling subcontractor to advance soil borings through the former basement and other locations to evaluate potential impacts to soil. No impacts were found.

Oh, and the rumored animal carcass? We never found one.

Once completed, the clearing and removal of this abandoned property represented a tremendous win for the village and the Town of Haverhill as a whole. By removing the blight and addressing public safety concerns, the town now has an asset that can be either sold for revenue or tied into a proposed nearby rail trail. Sometimes removing blight is the only catalyst that is needed.

(This article was originally published in the November 3, 2023, issue of the New England Real Estate Journal)

About the Author:

George Naslas, PG, LSP, is a Vice President with Weston & Sampson. He can be reached at naslasg@wseinc.com.