The Confluence of Brownfields Remediation and Sustainability
August Mack has been involved with remediation projects since the start of the company in 1988. Moreover, our founders, Geoff Glanders and Bryan Petriko (the company is named after their grandfathers), were involved in remediation since the early 1980s when State and Federal environmental laws and cleanup programs (e.g., underground storage tank rules, RCRA, and CERCLA) were in their infancy. As such, we can bear witness to the evolution of remediation strategies for brownfield and industrial properties over the last several decades. What we are seeing with current remedial strategies, and with increasing approval by regulatory authorities, is a melding of remediation, brownfields redevelopment, and sustainability. This is an exciting development and one that provides overall greater flexibility to clean up of sites and re-use of Brownfield properties. In the following paragraphs, I will provide some context to the above statements and include a few examples.
Remediation of soil and groundwater has come a long way over the last 40 years since the introduction of the State and Federal cleanup programs. In the 1980s, most soil and groundwater remediation was performed by excavating soil, capping or encapsulating wastes on-site, and pumping & treating groundwater. In the 1990s, more “in situ” approaches were utilized for the treatment of soil and groundwater including soil vapor extraction and thermal treatments for soils, air sparging, dual-phase extraction, and injection of various treatment agents in groundwater to increase the natural degradation of compounds.
Over the past 20 years, more sophisticated in situ cleanup approaches have been developed and implemented for soil and groundwater cleanup, and there was increased focus on soil gas and vapor intrusion from impacted soil and groundwater. However, another significant development in the remedial approaches has been an increased focus on managing exposure pathways and receptors with the goal of “property re-use” – whatever that re-use might be (e.g., commercial, residential, recreational, etc.). In fact, most remedies over the last 20 years have utilized elements of traditional cleanup approach (such as “hotspot” soil removal, and in situ groundwater remediation), coupled institutional controls, such as deed restrictions, to facilitate site redevelopment. These trends are borne out in U.S. EPA’s recent Superfund Remedy Report, 17th Edition (January 2023).
Brownfields and Sustainability
Sustainability is essentially long-term stewardship of our resources. Many of the “sustainability” concepts that we talk about in 2023 are not necessarily new ones. A new commercial, industrial, or mixed-use development on a brownfield site is an example of sustainability since we are re-using contaminated land and not developing a “greenfield”. Similarly, the goals of the Resource Conservation & Recovery Act (RCRA), which was passed by Congress in 1976, were to:
- Protect human health and the environment from the potential hazards of waste disposal.
- Conserve energy and natural resources.
- Reduce the amount of waste generated.
- Ensure that wastes are managed in an environmentally-sound manner.
Beginning in the 2010s, U.S. EPA and states were talking about “green remediation” as an alternative to traditional approaches. The aim of green remediation is to reduce the overall environmental footprint of the site and remediation effort. More specifically, evaluating remedies from the perspective of reducing energy use; reducing water consumption and preserving water quality; reducing air pollutants and emissions; conserving material resources; and protecting land and ecosystems (U.S. EPA Memo “Consideration of Greener Cleanup Activities in the Superfund Cleanup Process, August 2016). In practice, green remediation attempts to balance remediating a site with the environmental footprint of that remediation. For example, excavating and trucking a large volume of contaminated soils many miles to a landfill reduces the volume of waste at the Site, but also results in significant use of natural resources – fuel for the excavators, dozers, trucks and material handling equipment at a landfill), as well as the air emissions from burning those fuels. The overarching theme is the old adage…”the cure should not be worse than the disease.”
What we have seen over the last approximately 10-15 years is the increase in sustainability initiatives into the Brownfield remediation. More specifically, the use of wind and solar energy generation either as part of the remedy, or as a practical re-use alternative following the remedy. Here are a few examples.
Superfund Site with Solar Farm
August Mack has been involved in Superfund cleanup effort at a number of sites across the country. One of those facilities in the Midwest ultimately opted to consider the placement of a solar farm on top of one of the landfills that was created as part of the Superfund remedial efforts in the 1990s. August Mack assisted in coordinating with the municipality, local utility, U.S. EPA, and state agencies, as well as supporting the engineering efforts for installation of the panels on the landfill. The solar development took approximately one year and was operational by 2014. It was the nation’s first utility-scale solar farm on a Superfund site. Today that solar farm generates over 10 MW of electricity, and is re-using land that otherwise could not be used for other purposes.
Corrective Action site in the Midwest
August Mack is working with a client in the Midwest to remediate the property through RCRA Corrective Action. August Mack identified a portion of the facility that contained impacts from past operations, but was not suitable for redevelopment. As such, that area was evaluated with the respect to the client’s Corporate sustainability initiatives and was a candidate for a potential solar project. August Mack worked closely with the regulatory agency to fast-track the remedy evaluation process. At this time, the remedy would include targeted soil excavations, risk assessment, cover, and use of approximately 10 acres of Brownfield as a solar farm to off-set carbon emissions and assist with facility and Corporate sustainability goals. The project is set for 2023-2024.
Wind and Solar Projects on former Brownfields, Abandoned Mine Land, and other Under-Utilized Land
August Mack is assisting several wind and solar developers to re-use abandoned mine lands, brownfields, and other impacted properties that are currently sitting vacant. We have conducted Phase I Environmental Site Assessments and follow-up projects on over 600,000 acres of land for the purpose of siting renewable energy. In many cases, traditional developers shy away from these properties, and most have been empty brownfields for years. By assessing the sites for re-use for solar and or wind farm development, we are putting some of this land into productive use.
Solar Panels to Run Remediation Equipment
August Mack has had several opportunities to utilize solar panels to create electricity to run remediation equipment to cleanup soil and groundwater. We have installed solar panels on several small oil-recovery systems. These systems contain rooftop solar panels on the remediation buildings and do not require outside electricity to operate.
These examples provide some insight as to the willingness of regulatory agencies, responsible parties, and other stakeholders to embrace brownfields redevelopment and sustainability initiatives. This is an exciting nexus of our environmental practices, and we believe this will continue to evolve.