NC-2009 SSc3: Brownfield Redevelopment

  • NC_CS_SSc3_Type3_Brownfield Diagram
  • Redevelop land or facilities

    The intent of this credit is to reduce the development pressure on undeveloped land by encouraging development of land that has access to existing infrastructure and services. 

    This credit is straightforward. You can earn it if your site has been designated a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) by a state, local or federal agency and if the site is remediated to meet appropriate standards for development. 

    The U.S. Environmental Protection Agency (EPA) defines “brownfields” as “abandoned, idled, or under-used industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived environmental contamination.” 

    Your documentation needs to include brownfield designation, records of testing conducted on the site, and records of the remediation performed.

    Asbestos can qualify, lead may not

    Asbestos and other non-soil contamination in an existing structure may also qualify for brownfield redevelopment, per LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. 5/9/2011 ID#10001. An asbestos plan should be developed by a qualified environmental professional and documented according to EPA and state regulations.

    Having lead paint on walls in the building is not a sufficient threshold to earn this credit. The physical site must have been contaminated and need remediation in some way in order to earn the credit.

    A degraded brownfield site and erosion-prone streambed were restored into an ecologically productive wetland at the Real Goods Solar Living Center. Photo – Alex Wilson

    Benefits to the environment

    Brownfield projects remediate damaged land, creating clean, highly developable properties, often with good access to utility and public infrastructure. Focusing development on brownfields restores vacant lands, reconnecting communities ravaged by industrial waste and abandonment.

    In addition, techniques for remediating brownfields may restore water quality and wildlife habitat on marginal sites—many brownfields are located along urban waterways in need of ecological restorationEcological restoration is the process of assisting in the recovery and management of ecological integrity and includes biodiversity, ecological processes and structures, regional and historical context, and sustainable cultural practices.. Brownfield development can often take advantage of creative financing packages offered by state and local governments that aim to focus economic activity in depressed or abandoned areas. 

    Actual remediation not always necessary

    You can occasionally earn this credit even if no actual remediation is performed, because brownfields are often designated as such simply because of the perception that contamination is present due to a site’s history of use, abandoned or derelict condition, adjacent industrial sites. If investigation finds that contamination is not present despite the brownfield determination, you can still earn the credit.

    What’s the catch?

    If a site’s owner uncovers information that leads to the site being classified as a brownfield in need of remediation, then the owner will need to perform the remediation in order to qualify for the credit. This will require detailed site investigation to understand the nature of contamination and the steps needed for remediation. 

    • Remediation can be expensive, both in terms of cost and time. Begin the Environmental Assessment process early to avoid design and permitting problems in later phases.
    • Weigh the value of the remediated property against cleanup costs to determine whether the site is economically viable for redevelopment.
    • Work with your community as early as possible in the project to communicate the goals of site remediation and eventual use of the property. Good communication will help to prevent misunderstandings and the potential for legal issues. Professional facilitators can be helpful in developing your relationship with the community and building a strong local partnership.
    • Brownfield owners become part of the chain of title, and as such, are partly responsible for environmental liability for the property. However, there are established legal ways to reduce the risk that you will be sued for costs of environmental cleanup or personal injury. Consult an attorney experienced in brownfield real estate law before entering into your purchase.
    • Buyer and seller can work out financial responsibility for liabilities during the sale transaction. 
    • Environmental liability insurance can insure against unknown cleanup costs or cap the policyholder’s liability for cleanup cost overruns.
    • Federal and state governments have devised special programs to encourage brownfield reuse, including special protection from liability.

    Steps to evaluate your site for contamination

    • If you suspect that your project site is contaminated, but it has not been designated a brownfield by a local, state, or federal agency, you will need to conduct a preliminary assessment to establish the likelihood of contamination.Petco Park in San Diego is the centerpiece of a 26-block brownfield redevelopment project in which the City acquired properties through eminent domain. Photo – SCS Engineers
    • This study is a Phase I Environmental Site Assessment (ESA), ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services E1903-11. Phase I looks at prior land use records, including use of adjacent and nearby sites. It does not require special soil tests and must be performed by an environmental professional. 
    • A Phase I ESA is not necessary if the site has a clear indication of contamination from previous development, such as underground storage tanks for hazardous substances, or if the site was historically used for heavy industry. 
    • If the contamination is obvious, or the Phase I study indicates the likelihood of contamination, then further development will require a Phase II ESA (ASTM E1903-11). Phase II requires soil testing to measure the degree of contamination, determine whether remediation is required, and outline proposed steps for remediation.

    Questions to consider before approaching this credit

    • Has the site already been remediated to an appropriate standard for redevelopment?  This may be the case if a previous owner sought to develop the property and performed remediation as a condition of sale. 
    • Are there known or obvious contaminants (eliminates need for Phase I Environmental Site Assessment)?
    • Has a Phase II Environmental Site Assessment been conducted on the site?

    FAQs for SSc3

    Is earning one point for this credit an appropriate reward, given the work involved?

    Given the effort, expense, and risk involved in many brownfield projects, one LEED point is probably not a worthy reward. It would probably be more useful to think of this credit as a token, and to acknowledge that developers aren't likely to choose a brownfield site to earn this point. There is a silver lining, however, in that urban infill sites, which are often brownfields, are typically well-rewarded in LEED's density-related credits.

    Do we have to get testing done even if contamination is obviously present?

    Yes, an environmental professional will need to verify that contamination is located on the site using the specified standards for testing and verification. This helps identify the scope of contamination and thus the scope of remediation that will be required.

    If the remediation work is not part of the LEED project scope, can I still achieve this credit?

    No. If the remediation occurred prior to when the property was purchased, you are no longer developing a contaminated site. SSc3 addresses sites that are subject to corrective action; it doesn't address the past history of the site.

    Are there minimum contamination thresholds that need to be met in order for a site to be classified as a brownfield?

    Brownfield requirements are determined at the federal, state, or local level and vary from one jurisdiction to another. For LEED, there are no minimum thresholds (volume or area) required to meet this credit as long as the site—or a portion of it—is classified as a brownfield.

    Am I eligible to earn the credit if there is ongoing remediation on my project site and remediation is not yet complete?

    Yes, a project team may earn the credit even when remediation is not complete provided there is an approved ongoing remediation plan in place and the applicable regulatory authority has approved the site for its intended use.

Legend

  • Best Practices
  • Gotcha
  • Action Steps
  • Cost Tip

Pre-Design

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  • Brownfield Sites


  • Determine whether your project site has been designated a brownfield by local, state, or federal standards, or has been documented as contaminated through an ASTM-E-1903-97, Phase II, Environmental Site Assessment (ESA) or local voluntary cleanup program. 


  • If you have reason to believe that your project site is contaminated, but it has not yet been designated Petco Park in San Diego is the centerpiece of a 26-block brownfield redevelopment project in which the City acquired properties through eminent domain. Photo – SCS Engineersas such by a local, state, or federal agency, hire a qualified environmental consultant, engineer, or hazardous materials remediation professional to conduct an ASTM-E-1903-97, Phase II, ESA to determine the degree of contamination and whether remediation is required. 


  • A Phase II ESA involves a detailed look at the site. The environmental professional takes samples and tests for contaminants on the grounds and within existing structures. High concentrations of heavy metals, toxic chemicals, or asbestos may require remediation. Petroleum byproducts, pesticides, solvents, and mold may also lead to remediation, depending on the specific chemicals and concentrations. 


  • Research liability issues, financial obligations and incentives, community interest, remediation options, and regulatory requirements. You’ll need to consult with local, state, and federal regulatory agencies to determine much of the information. 


  • It’s important to have the support of the community when remediating a brownfield. Consider holding an open meeting to educate members of the community about the actual and perceived risks of remediating a brownfield, especially in terms of impacts on groundwater and the potential risks associated with the disruption of contaminated soils. 


  • If remediation is required, seek out qualified environmental firms to provide bids to perform the work. 


  • Once hired, this firm will document the process and demonstrate the removal of identified contaminants to meet the appropriate thresholds and credit requirements. 


  • Determine the best strategy for your site, contamination type, and degree of concentrations in collaboration with your environmental professional. Set a timeline within which to determine any impact on your construction schedule. (See Schematic Design, below, for more detail on common remediation options.)


  • Invite several companies to bid on the creation and implementation of a master plan for site remediation. This strategy enables comparison of remediation techniques and costs. Try to contract with an environmental firm early in the project.


  • Cleaning up contaminated sites to appropriate standards for development can be costly due to the time required to determine the level of contamination, analyze various cleanup options, and carry out the remediation. 


  • Work with local, state, and federal regulatory agencies to research available funding for the remediation of your contaminated project site. 


  • International projects can still achieve this credit even if the local government agency has not designated it as a brownfield by pursuing the Option 1 compliance path by conducting your own ASTM E1903-97 Phase II Environmental Site Assessment.


  • Asbestos 


  • If your project building was built prior to the late 1970s, there may be some form of asbestos present in piping insulation, siding, or other materials. If you are undergoing major renovations, it’s likely that some asbestos will need to be removed from the building or remediated. However, not all types need to be remediated. To determine whether you will need to remediate asbestos on your project site, hire a qualified environmental professional to inventory asbestos and document it according to EPA Reg. 40-CFR-763 or similar state or local standard, whichever is most stringent.  


  • Make sure your environmental professional provides a summary of the asbestos inventory and a plan for its remediation. The plan must document the type, amount, and location of the contamination, and create a remediation plan following EPA Reg. 40-CFR-763 and the National Emission Standards for Hazardous Air Pollutants (NESHAP) program. This will serve as your documentation for this credit.  

Schematic Design

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  • Brownfield


  • Hire a qualified environmental engineer or professional to manage the remediation effort according to the master remediation plan. 


  • Each contaminated site requires different remediation efforts. The remediation technique you use should be based on the type, extent, and concentration of contamination, as well as the risk level. Some examples of remediation techniques are: 

    • Pump-and-treat, a process in which contaminated groundwater is brought up from the subsurface for treatment.
    • In situ remediation, which involves placing injection wells in the natural path of groundwater for treatment of contaminants.
    • Phytoremediation, which involves planting the site with plants that uptake and store contamination within the plant tissue.      
    • Haul-away, where the contaminated soil is removed from the site and used as daily cover at the landfill.

  • Depending on the extent and type of remediation required, it is possible that some site features may be affected. For example, it may be less expensive to cap contaminated soils with concrete, leaving no room for landscaping or stormwater infiltration. This can have an effect on other site credits your project is attempting, such as SSc5.1: Protect or Restore Habitat and SSc6.1 and SSc6.2: Stormwater Management.


  • After remediation is completed, your environmental professional should write a letter stating that the site cleanup has been conducted to local, state, or federal standards. This letter should describe the actual remediation steps in detail.


  • Asbestos 


  • Remediate asbestos according to accepted standards, such as NESHAP or comparable state regulations. 

Design Development

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  • Brownfield


  • Prepare the documentation for submission to LEED Online. Documents should include:

    • The brownfield designation by a local, state, or federal agency or a summary of the Phase II ESA, signed by a qualified environmental consultant, that outlines the type and amount of contamination and the remediation required to reduce the contamination to acceptable levels. 
    • A summary of the remediation plan and its implementation, signed by a qualified environmental consultant, that includes final measurements of contamination levels as compared to the initial maximum contaminant thresholds. 

  • Asbestos 


  • Prepare documentation for submission to LEED Online. These documents should include:

    • A summary of the asbestos inventory, signed by an environmental consultant qualified in asbestos investigation.
    • A summary of the remediation plan and its implementation, including reference to compliance with NESHAP or similar standard, signed by a qualified asbestos removal contractor. 

Construction

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  • Prior to issuance of the Certificate of Occupancy, ensure that all remediation efforts have been completed, properly documented, and submitted to the proper authorities.    


  • Verify any ongoing requirements with your regulating agency, as some state and local agencies require a contaminated and remediated site to be retested or monitored on an ongoing basis.

Operations & Maintenance

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  • If required by the remediation plan, monitor the levels of identified chemicals onsite after the remediation is complete to ensure that contamination remains below the maximum thresholds. 

  • USGBC

    Excerpted from LEED 2009 for New Construction and Major Renovations

    SS Credit 3: Brownfield redevelopment

    1 Point

    Intent

    To rehabilitate damaged sites where development is complicated by environmental contamination and to reduce pressure on undeveloped land.

    Requirements

    OPTION 1

    Develop on a site documented as contaminated by means of an ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services E1903-97 Phase II Environmental Site Assessment or a local voluntary cleanup program. Projects outside the U.S. may use a local equivalent to ASTM E1903-97 Phase II Environmental Site Assessment.

    OR

    OPTION 2

    Develop on a site defined as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) by a local, state, tribal or national government agency, whichever is most stringent.

    For projects where asbestos is found and remediated also earn this credit. Testing should be done in accordance with EPA Reg 40CFR part 763, when applicable.

    Potential Technologies & Strategies

    During the site selection process, give preference to brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) sites. Identify tax incentives and property cost savings. Coordinate site development plans with remediation activity, as appropriate. 

    For projects where asbestos is found, prepare executive summary- level content from the investigation’’s report explaining the extent of the contamination and required action as well as documentation indicating an acceptable level of remediation was achieved based on an acceptable standard, such as RCRAThe Resource Conservation and Recovery Act (RCRA) addresses active and future facilities and was enacted in 1976 to give EPA authority to control hazardous wastes from cradle to grave, including generation, transportation, treatment, storage, and disposal. Some nonhazardous wastes are also covered under RCRA. or NESHAPs.

     

Web Tools

U.S. EPA, Sustainable Redevelopment of Brownfields Program

This is a comprehensive website on brownfields that includes projects, initiatives, tools, tax incentives and other resources to address brownfield remediation and redevelopment. For information by phone, contact your regional EPA office.


EPA Reg. 40 CFR 763

This EPA website provides laws and federal regulations relevant to asbestos.


U.S. EPA, Asbestos

This website provides information on the health effects of asbestos, where it is commonly found, and the laws and regulations governing testing of sites containing asbestos.

Publications

NESHAP – demolition practices update

This link outlines the Asbestos Remediation guidelines.

Organizations

Council of Development Finance Agencies

This organization offers options for brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) refinancing.


Environmental Law Institute, Brownfields Center

The Environmental Law Institute’s Brownfields Center provides information on brownfields cleanup and redevelopment with a focus on the concerns and needs of community groups across the country.

Technical Guides

ASTM E1527-05

This document defines good commercial and customary practice in the United States of America for conducting an environmental site assessment of a parcel of commercial real estate with respect to the range of contaminants within the scope of Comprehensive Environmental Response, Compensation and Liability Act.


ASTM E1903-11

This document is intended for use on a voluntary basis by parties who wish to evaluate known releases or likely release areas identified by the user or Phase II assessor.


U.S. EPA, Asbestos

This website provides information on the health effets of asbestos, where it is commonly found, and the laws and regulations governing testing of sites containing asbestos.

Other

LEED Interpretation Ruling for Asbestos

This is a LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. Ruling that spells out the requirements to use asbestos remediation as an alternative compliance path for this credit.

Asbestos Abatement

This is a sample narrative for a project in NYC that is showing that the local regulation for asbestos removal is an acceptable standard.

LEED Online Forms: NC-2009 SS

The following links take you to the public, informational versions of the dynamic LEED Online forms for each NC-2009 SS credit. You'll need to fill out the live versions of these forms on LEED Online for each credit you hope to earn.

Version 4 forms: (newest)

Version 3 forms:

These links are posted by LEEDuser with USGBC's permission. USGBC has certain usage restrictions on these forms; for more information, visit LEED Online and click "Sample Forms Download."

Design Submittal

PencilDocumentation for this credit can be part of a Design Phase submittal.

96 Comments

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Chris Flint Chatto Integrated Designer ZGF Architects
Nov 19 2014
LEEDuser Member
78 Thumbs Up

timing on remediation - done before construction

Hello. I see in the FAQ above that "If the remediation occurred prior to when the property was purchased, you are no longer developing a contaminated site." However, what if the owner already owns the site, and will be preparing (and remediating) the site in advance of the construction of a new facility, as part of a separate contract for site preparation (distinct from the design and construction of a new facility). It would seem to me that this meets the intent of the credit, and that we should advise them to document the remediation efforts, and as the owner, could sign off on this credit. Would you agree? And thanks!

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Sara Zoumbaris Sustainable Design Consulting
Aug 20 2014
LEEDuser Member
187 Thumbs Up

Building that Meets Requirements but ALSO has Lead Paint

Has anyone come across a building that meets the credit requirements for SSc3 but also has Lead paint, of which the owner has chosen to paint over instead of remove (which is legally ok in the state of the project.) My thoughts are that the existence of Lead Paint holds to conflict with this credit at all and that is acceptable.

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Larry Sims Principal, Studio4, LLC Aug 20 2014 LEEDuser Expert 2115 Thumbs Up

Sara, it appears your project has met the intent of the credit, so it's down to the issue of addressing the lead contamination. Even though "having lead paint on walls in the building is not a sufficient threshold to earn this credit", in your instance the authority having jurisdiction (state) approves covering the source of lead with paint. This would also likely protect you in the event any future liability issues arose regarding lead remediation, as you have provided a state approved barrier that encapsulates the contamination.

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Kim H. Lombard Architect AECOM
Jul 29 2014
LEEDuser Member
4 Thumbs Up

Military Base contamination

Our client on a Military base has uncovered asbestos piping underground during construction. They have properly disposed of the contamination as a normal SOPA standard operating procedure (SOP) manual can be used to document routine operations and maintenance practices, and to encourage use of standardized best practices.. The Base (federal agency) is willing to write a memo that the site was deemed a BrownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) due to the piping and is looking for some guidance in sample wording. Does anyone have any resources for such?

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Jul 29 2014 LEEDuser Moderator

Kim, there is a sample of asbestos abatement documentation in our Doc Toolkit above. I think this will give you an idea of the kind of wording you would need.

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Kim H. Lombard Architect, AECOM Jul 30 2014 LEEDuser Member 4 Thumbs Up

Thanks - I didn't realize that would cover us for underground contamination also. I thought it was only for the building asbestos. I see further down in the text that it should.

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Dana Murdoch
May 27 2014
Guest
817 Thumbs Up

Contained Contaminated Soils & non-ASTM E1527-05 Phase II

We have a site with contaminated soils. A Phase II was conducted, but not per ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services E1527-05 as required. We have an independent environmental consultant coordinating our remediation efforts with the state pollution control agency. We are enrolled in the state's Voluntary Investigation and Cleanup (VIC). We are pursuing three separate methods to 'deal with' the contaminants: (1) under-slab vapor remediation, (2) phytoremediation where existing asphalt layers are removed, and (3) keeping existing asphalt layers intact with intent to 'cap' the contaminated soils. All of these methods have been verbally understood by our state pollution control agency.

Assuming the state agrees with our proposal, will this overall plan be acceptable for SSc3? I've noticed others asking about 'partial' remediation. I'm concerned about our portion that will be kept in place with an asphalt 'lid' on it.

Are we okay without an ASTM E1527-05 Phase II if we have an environmental consultant describing the contaminated soils & plan?

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Larry Sims Principal, Studio4, LLC May 27 2014 LEEDuser Expert 2115 Thumbs Up

Dana, imo, you're more than golden on this. First, and foremost, is the fact that contamination must be, at the minimum, isolated from human contact. For instance, asbestos can be left in place if it has a protective coating (i.e. paint). Putting an "asphalt lid on it" does, in fact, keep it away from human contact, and a strategy used time and time again. Without any details from you with regard to "partial" remediation, I can only make a blanket statement that yes, partial remediation is accepted if ongoing testing is done. For instance, underground upstream contamination, or tank leakage, can be difficult to assess and, often, requires periodic monitoring. USGBC usually accepts any reasonable attempt to mitigate brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) sites.

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Megan Bove
Apr 21 2014
LEEDuser Member
228 Thumbs Up

Lead Paint

Hey. I have a quick LEED question. In dealing with Lead paint removal on a project does anything need to happen for LEED in terms of documentation and/or protocol?
I understand that it doesn't qualify for the SS credit, but want to confirm what we need to do if anything.

Thanks!

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Larry Sims Principal, Studio4, LLC Apr 22 2014 LEEDuser Expert 2115 Thumbs Up

Megan, if you are not attempting the SSc3 credit, then there is no LEED obligation for you do anything. However, if you are removing the lead contamination, as a matter of professional prudence I would advice having the extraction process documented. Look at it as layer of protection for both the Owner and you in the event any future liability claim is charged.

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Sahar Abi-Ziki
Feb 05 2014
Guest
57 Thumbs Up

Brown Field redevelopement

Hello,
Due to budget issues, our client wants to decontaminate a portion of the site and not the entire site (only the areas were we are doing interventions). Would it be possible to achieve the credit only by remediateing to a portion of the site? Thank you

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Larry Sims Principal, Studio4, LLC Feb 05 2014 LEEDuser Expert 2115 Thumbs Up

Sahar,

The only way I know where you can bypass remediating an entire project site would be to divide the site into two legal parcels, if possible. Then remediate the parcel where your project is located. The remaining parcel(s) would still be contaminated, but would not be included within the project boundary.

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Sahar Abi-Ziki Feb 06 2014 Guest 57 Thumbs Up

Thank you!

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Eirini Matsouki Atkins
Feb 03 2014
LEEDuser Member
328 Thumbs Up

Hexavalent Chromium on groundwater

Hi all,

Our project is international and is under construction. We are keeping this credit on a stand-by, as during the design submission there was not any evidence of contamination. However, during the drilling of the boreholes that would serve partly for the irrigation of the landscaped areas, the groundwater analysis resulted in hexavalent chromiumA naturally occurring metal used to make chrome, used in some wood treatment compounds, and sometimes used to tan leather. Its usage has been greatly reduced, but it may still be found in some products. Although chromium is an essential nutrient, some chromium compounds are carcinogenic. content. If the project team decides to remediate the water drawn from the boreholes and used only for the project’s needs, can the project earn this credit?

Thank you!!!!

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Feb 03 2014 LEEDuser Moderator

Eirini, you would first have to have the site classified as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) by a relevant jurisdiction.

Secondly, I am skeptical that your approach meets the credit intent, which is "To rehabilitate damaged sites where development is complicated by environmental contamination and to reduce pressure on undeveloped land."

To the extent that using a damaged site reduces pressure on greenfield sites, it's a good fit, but it doesn't sound like you are rehabilitating the site, as much as you are mitigating the site's direct impacts on your project. A solution that got more at the source of the problem and mitigated it more comprehensively, if possible, would seem more appropriate.

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Eirini Matsouki Atkins Feb 04 2014 LEEDuser Member 328 Thumbs Up

Many thanks Tristan for your prompt reply. yes i think you are right, it's more mitigation rather than rehabilitating the site. thank you very much!!!!

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Donald Green Project Manager Sustainable Design Consulting, LLC
Oct 14 2013
LEEDuser Member
1119 Thumbs Up

Contained Material

We have a project whereby hazardous material was found burried in sealed containers and per testing of the surrounding soil it does not apear any of the material has leaked into the soils. The project did have to dispose of the materials and containers in an appropriate manner and there is documentation for how it was handled and what the materials are.

Is this considered a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) under the requirements of this credit?

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Larry Sims Principal, Studio4, LLC Oct 15 2013 LEEDuser Expert 2115 Thumbs Up

Donald,

The project site would be considered a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) if a Phase II ESA confirmed the presence of contamination. Given the fact your description says "... it does not appear any of the materials leaked into the soils", you would need to provide documented soil testing to "confirm" no soils have been contaminated. This should supplement the documentation you already have that identifies the contamination and subsequent removal per recommended practices.

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Donald Green Project Manager, Sustainable Design Consulting, LLC Oct 15 2013 LEEDuser Member 1119 Thumbs Up

There wasn't a Phase II ESA, the material containers were literally discovered during excavation. We have the test results etc. for documentation, however will a narrative explaining how the material was discovered and subsequently tested be sufficient in lieu of a Phase II ESA?

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Larry Sims Principal, Studio4, LLC Oct 28 2013 LEEDuser Expert 2115 Thumbs Up

If the consultant(s) contracted to identify the contamination, test the soils and verify remediation were all done in accordance with accepted standards, you should be okay. GBCI has been somewhat lenient in their brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) reviews as long as the scope of services was done by recognized professionals. A narrative or executive summary listing the type of contamination discovered, soil testing results and remediation efforts would be required.

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Kathleen Gaffney Consigli Construction Co
Aug 19 2013
LEEDuser Member
66 Thumbs Up

Naturally occurring arsenic contamination

Would naturally occurring arsenic contamination (from trees, it appears) be eligible for the brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) credit if documentation is provided? The soil was tested and is being remediated.

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Allison Beer McKenzie Architect, Director of Sustainability, SHP Leading Design Aug 19 2013 LEEDuser Expert 6329 Thumbs Up

Yes- that should definitely qualify. Just make sure you have documentation that the site is now clean and ready for reuse.

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Noriko Yasuhara Woonerf Inc.
May 21 2013
LEEDuser Member
1862 Thumbs Up

Requirements by government agency don't require total cleanup

Hi all,

We're working on a international project, which is designated as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) site by the local government

Is a project still eligible for this credit if it the requirements of the regional government for redevelopment mandate measures for the contamination not to spread, containment measures, and partial contaminant removal?

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Larry Sims Principal, Studio4, LLC May 21 2013 LEEDuser Expert 2115 Thumbs Up

Hi Noriko,

Local equivalent standards can be used in place of U.S. government regulations for SSc3 in addressing sites where development can be complicated by environmental issues. If a regional government has designated this site as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) , there is an implied and undeniable concern with regard to contamination.

This said, there can be several ways to remediate a site without removal of the contamination as long as it no longer poses a threat. Brownfield sites can be difficult to assess proper remediation given the fact there is no one-shoe-fits-all standard. This is why regional authorities are often better qualified to establish recommended remediation requirements. Apparently these are being addressed by the mandated measures you’ve stated, so I don’t see an issue as long as you comply with the authority having jurisdiction.

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Maria Porter Environmental Certification Engineer Skanska Sweden
May 20 2013
LEEDuser Member
2445 Thumbs Up

Major renovation zero-lot line project has oil spillage...

...in the intermediate floors

An old building will undergo a major renovation. Some time back, before it was an office, a newspaper was printed here and the machines spilled oil into the intermediate floors over the years. We will remediate this and wonder if it will qualify the project for this credit?

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Larry Sims Principal, Studio4, LLC May 20 2013 LEEDuser Expert 2115 Thumbs Up

Maria,
Your project should be eligible if you meet the requirements for testing and documenting the contamination. It doesn’t matter how long ago the contamination occurred as long as it exists today.

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Maria Porter Environmental Certification Engineer, Skanska Sweden May 21 2013 LEEDuser Member 2445 Thumbs Up

Thanks Larry! I will look into how this has to be documented.

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Lauren Fakhoury Research Assistant Sustainable Design Consulting, LLC
May 14 2013
Guest
1434 Thumbs Up

Remediation prior to project start date

Does anyone know if LEED defines a project start date for this credit? I am working on a project where there was some ACM identified and abated back in 2009. While this should meet the credit requirements, we are concerned about the timing since it was much prior to the project start date. The owner was the same owner back when the abatement was done. Could this still qualify for the credit? Thank you!

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Larry Sims Principal, Studio4, LLC May 20 2013 LEEDuser Expert 2115 Thumbs Up

Lauren,
The only instances I am aware of that consider credit for past remediation is when the remediation effort required long-term monitoring. Unless you can make an argument that connects the past remediation to this project in some way, I don’t think it would be accepted. However, in LEED terms (i.e. LEED 2009), 2009 is not that long ago. Could it be that the current owner planned a LEED project and went forward with remediation? It may be worth the time to ask USGBC for an interpretation.

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Joseph Celentano Nov 13 2013 LEEDuser Member 181 Thumbs Up

I am wondering if there was any follow up to this question. We are just starting a project, after having it go on hold for a few years. When initial planning started, a building on our site was removed, and it contained ACM's. Documentation was completed on this project at that time, and then everything was put on hold. Now project has started back, and nothing has gone on the land since the old building was cleared away. Can we use this as a BrownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) credit? If we did, would we then have to use the demo building as part of our Construction Waste Management Credit.
Thanks-

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E H Sustainability Architect
Feb 20 2013
LEEDuser Member
3190 Thumbs Up

Contaimination found,but remediation not required per site class

I have a project where some mercury contamination was found, but not enough to require remediation for the intended use as an industrial site.

I assume that in order to achieve this credit some sort of remediation would have to be performed. That seems to be the intent of the credit. Has anybody achieved this credit without remediation?

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Michelle Rosenberger Partner, ArchEcology, LLC Feb 20 2013 LEEDuser Member 5663 Thumbs Up

Hi E.H.,
No, you are correct remediation is necessary. We have achieved this credit with asbestos numerous times and mold once, but always with remediation.

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Gabriel Moreno
Nov 15 2012
Guest
126 Thumbs Up

Points awarded not commensurate with Credit Intent

Just out of curiosity, I wondered if anyone at USGBC could explain why, in regards to LEED certification, would any Owner or Developer would want to go through the trouble of rehabilitating a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) to end up with 1 additional possible point awarded to the project.

It seems to me that the rehabilitation of brownfields is certainly a critical issue to be tackled in our modern society, and I wonder if it would be more appropriate to provide additional incentives on this credit.

How many points do other LEED Users think this credit should achieve (if not 1)?

I feel 4 points might be more appropriate based on the intention of this credit, and the challenges that must be overcome to achieve this goal.

Best regards,

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Larry Sims Principal, Studio4, LLC Nov 16 2012 LEEDuser Expert 2115 Thumbs Up

Gabriel, I can’t speak for USGBC, but I don’t believe, in most instances, additional credits would offer much in the way of an incentive for Owners or Developers to consider BrownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) sites. Brownfield sites are, generally, selected for a variety of reasons (e.g. location, costs, community incentives, etc.). I’ve never worked a site where a Phase I was not performed, and if contamination was discovered, then a risk/reward analysis would be conducted.

Given the potential downsides, Owners or Developers don’t consider Brownfield sites just to pick up credit points. Having investigated and developed several Brownfield sites over the years, the risks can and often do outweigh the rewards by a huge margin, particularly if the EPA is involved. IMO, the EPA is the most arrogant and abusive government agency in existence. There are Brownfield projects where 4 points could not come close to being appropriate considering the investment in both time and money. When you can spend a year and $50k-$75k investigating a Brownfield and working through the bureaucracy of the EPA to obtain clearance just to proceed, you sometimes just take your bruises and give up the battle. Obviously it’s not always the case, but Brownfield sites can be enormously expensive to remediate, not to mention legal entanglements and liability that can be associated with these abandoned sites.

When LEED 2009 was implemented, USGBC introduced Credit Weightings where credits are awarded with more points for strategies that have greater positive impacts on ‘energy efficiency and CO2Carbon dioxide reductions’. As such, Brownfields are still stuck on 1 credit point. I agree with you, and SSc3 has been one of my pet peeves since I began studying for the LEED v2 AP exam back in 2007. It seems disingenuous for USGBC to try and sell the importance of this credit and then award it a minimum credit value.

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Gabriel Moreno Nov 26 2012 Guest 126 Thumbs Up

I appreciate your insight Larry. It clarified all the confusion expressed in my comment. Thanks so much for sharing!

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Michael Archer Principal Engineer HSA Engineering
Oct 12 2012
LEEDuser Member
25 Thumbs Up

Landfill remediation

Under what circumstances does a commercial project need to be remediated to meet residential (unrestricted) use?

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Larry Sims Principal, Studio4, LLC Oct 22 2012 LEEDuser Expert 2115 Thumbs Up

Michael, the volume and concentration of contaminants left on-site, and thus the degree of residual risk at a site, will affect future land use. For example, a remedial alternative may include leaving in place contaminants in soil at concentrations protective for industrial exposures, but not protective for
residential exposures. In this case, institutional controls should be used to ensure that industrial use of the land is maintained and to prevent risks from residential exposures. Conversely, a remedial alternative may result in no waste left in place and allow for unrestricted use (e. g., residential use). If future land use could be in doubt, I would recommend contacting the local EPA to discuss.

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Kendall E Design Partners Inc.
Sep 22 2012
LEEDuser Member
381 Thumbs Up

Limited Asbestos Remediation

If our entire project site has asbestos soil contamination, but due to budget constraints we are only planning to remediate the soil disturbed for our new buildings and not the undisturbed areas in between buildings, can we qualify for this credit?

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Larry Sims Principal, Studio4, LLC Sep 22 2012 LEEDuser Expert 2115 Thumbs Up

Denise, the short answer is no. You must ensure that the asbsetos has been either removed from the project (building or site) or isolated from human contact. For instance, you can place an asphalt layer of isolation if site related, or in the case of piping, encapsulate the asbsestos with a protective layer - or remove the offending contamination.

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emily reese Sustainability Consultant / Facility Planner Jacobs Engineering
Aug 13 2012
LEEDuser Member
488 Thumbs Up

Lead, but not from paint...?

I see from previous comments that the amount of lead present on a site might not matter, however, I thought it wouldn't hurt to pose this question, just in case.
My project has lead contamination, though not from paint. The site has a building being demolished that formerly held a firing range for many decades. The lead is from the artillery used and discarded there. I would believe that this lead content would be much higher than that from paint, though I am not certain at this time.
Would this approach be a worthy effort to make as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) alternative compliance path? Any ideas for what kind of supporting documentation (outside of the brownfield designation, records of testing conducted on the site, and records of the remediation performed) may be of use?

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Donald Green Project Manager, Sustainable Design Consulting, LLC Dec 06 2013 LEEDuser Member 1119 Thumbs Up

It sounds like it may work if you have documentation on the lead and which jurisdiction is noting that it is at a hazardous level, but the only way to know is either submit and see what happens or submit a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide to verify prior to submitting.

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Dec 06 2013 LEEDuser Moderator

Emily, our information on SSc3 (see above) is that lead paint is not sufficient for credit eligibility.

What you describe is quite different though and it seems to me like it falls within the intent of this credit. I don't have any concrete suggestions on documentation, though—seems like you'd want to go the assessment route, but possibly check with GBCI if they would consider you eligible before proceeding.

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emily reese Sustainability Consultant / Facility Planner, Jacobs Engineering Dec 06 2013 LEEDuser Member 488 Thumbs Up

Thanks, guys! It will be a while before submission, but I'll let y'all know if we submit it as a strategy, and how it goes over.

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Larry Sims Principal, Studio4, LLC Dec 17 2013 LEEDuser Expert 2115 Thumbs Up

Emily,

Given the fact that the EPA is trying to ban lead from being used in ammunition (California, for example, has banned lead bullets for hunters, a response to animal-rights groups who claimed the lead was killing condors, and to environmental lobbyists who said the metal was seeping into the water supply), I don't believe GBCI would deny your BrownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) application.

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Lisa Sawin
Jul 13 2012
LEEDuser Member
550 Thumbs Up

Asbestos documentation

Our project site has two buildings that will be demolished to erect our project. Through testing that is compliant with NESHAPS standards it has been determined that both buildings have asbestos. The remediation (removal of asbestos containing items) will be preformed per NESHAPS standards.

Question 1: Does our project comply with the intent of the is credit?

Question 2: If I were to put this information into a narrative and upload it as alternative compliance would that suffice for documentation?

Question 3: Can someone confirm that EPA 40-CRF-763 is related to k-12 schools and would not be relevant to a office building? (disclaimer: I am not up to speed on my the asbestos regulations).

Thanks in advnace for your help!

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Larry Sims Principal, Studio4, LLC Jul 14 2012 LEEDuser Expert 2115 Thumbs Up

Lisa,

Question 1: NESHAPS pertains only to activities involving the processing, handling, and disposal of asbestos-containing material. The finding and subsequent removal of asbestos on site does not in itself comply. According to the credit requirements, projects must either be “documented” as contaminated by means of an ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services E1903-97 Phase II Environmental Site Assessment, or must be classified as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) by a local, state or federal government agency. However, USGBC has permitted asbestos assessments performed in accordance with the Code of Federal Regulations, Chapter 40, Part 763 as equivalent to a Phase II ESA (ASTM E1903-9) for “proving” contamination of sites for the purpose of this credit.

Question 2: Your LEED application must include executive summary-level content from the investigation's report, explaining the extent of contamination and required action.

Question 3: The Asbestos Hazard Emergency Response Act (AHERA) specifically requires local “education agencies” to take actions as defined by Code of Federal Regulations, Chapter 40, Part 763, Subpart E.

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Mark Meaders Sustainable Design Project Manager HDR Architecture, Inc.
Jun 28 2012
LEEDuser Member
910 Thumbs Up

Soil remediation

The definition of remediation as it relates to this credit is the process of cleaning up a contaminated site by physical, chemical, or biological means. Is the physical removal of contaminated soil from a site considered remediation, even if the soil is not "cleaned" after it's removed?

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Larry Sims Principal, Studio4, LLC Jul 06 2012 LEEDuser Expert 2115 Thumbs Up

Mark,

The physical removal of contaminated soil from a site is one method of remediation. However, the EPA established the Land Disposal Restrictions (LDR) program in an effort to protect groundwater from hazardous waste contamination. As such, the LDR standards require all hazardous waste to be treated prior to being placed on the land (i.e., hazardous landfill) for final disposal. Virtually all current wastes now have treatment standards. However, the program is extremely convoluted and difficult to understand. I would suggest contracting with a local hazardous waste handler to do the actual disposal. Hazardous waste handlers are responsible for identifying all applicable listed and characteristic waste codes in each waste stream and ensuring that their wastes meet all appropriate treatment standards, if applicable, before disposal. I say “if applicable” because contrary to the above stated requirements on EPA’s website, there are exemptions/exceptions.

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Tanja Arnesson Skanska Sweden AB
Jun 15 2012
LEEDuser Member
757 Thumbs Up

Polycyclic aromatic hydrocarbons, PAH

Hi,

My project just got back our Design 2 review, just after we sent in the design credits for the second review the project found old telephone poles within the ground at our project. Samples were taken from them when a strong odor was present, test results just came back and showed that they contain a high concentrations of polycyclic aromatic hydrocarbons. Can we send this in for construction now and get the point for contaminated land?

Thanks in advance!
Kind regards

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Emily Catacchio Sustainability Specialist, Wight and Company Jun 22 2012 Guest 7876 Thumbs Up

Tanja,

You can usually add credits to the construction review as you wish by going to the add or remove credits section of LEED-Online. I would suggest including a narrative explaining when these contaminants were discovered.

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Larry Sims Principal, Studio4, LLC Jul 06 2012 LEEDuser Expert 2115 Thumbs Up

Tanja,

Projects can be awarded this credit if contamination is discovered, properly remediated, and documented even after commencement of construction. Emily is correct that you will need to add a narrative, as well as all other required documentation.

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William Wong
Dec 13 2011
Guest
768 Thumbs Up

Reclaimed land near landfill

One of my projects choose to develop on a piece of land that is reclaimed and near an operating landfill and as thought in the design stage land contaminant would very likely to be found. So we did soil and ground water samplings but surprisingly, no contaminant exceeeds thresold and therefore no remediation work is required. Do you think we could earn SSc3 ?

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Larry Sims Principal, Studio4, LLC Dec 13 2011 LEEDuser Expert 2115 Thumbs Up

William,

USGBC has been pretty consistent in addressing sites that contain environmentally hazardous contamination. Documentation is required to be provided that determined the site is contaminated to a level that must be remediated prior to development. In my opinion, you would have a difficult time arguing the development has been complicated by the presence, or potential presence, of contamination.

There are many reasons for redeveloping brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) sites, but I’m hard pressed to see many, if any, reasons for "wanting" to encumber your property as a brownfield. It could come back to haunt you in the future and end up being a terrible price to pay for a single credit point if you are certain that no remediation is, or likely will be, required.

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Eirini Matsouki Atkins
Nov 13 2011
LEEDuser Member
328 Thumbs Up

Brownfield site

Is the site considered BrownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) , if the existing buildings have asbestos roofing? These existing buildings will be demolished as part of the new development in our project.
Does the contamiantion have to be in the site (means soil) or in buildings to be classified as Brownfiel and earn the credit point?

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Larry Sims Principal, Studio4, LLC Nov 13 2011 LEEDuser Expert 2115 Thumbs Up

Eirini,

Asbestos is classified as a hazardous substance and does qualify the project for BrownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) consideration.

If I understand the second question, yes the project, which includes the site (above and below the surface) and/or structures, must must have documented contamination in order to qualify for the project. However, the SOURCE of the contamination does not necessarily have to originate on site. For instance, it can migrate, underground, from a source upstream. This frequently occurs with abandoned underground storage tanks, which is why an ESA will research historical records to uncover any previously documented contamination within certain distances from the project site.

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Eirini Matsouki Atkins Nov 14 2011 LEEDuser Member 328 Thumbs Up

Thanks Larry.
In our case, the buildings have asbestos roofing and no soil contamination found. However, i understand from your response, that we qualify for the credit - Correct?

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Larry Sims Principal, Studio4, LLC Nov 14 2011 LEEDuser Expert 2115 Thumbs Up

Correct.

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Lisa Sawin May 16 2012 LEEDuser Member 550 Thumbs Up

Our project also has two buildings that we are removing that have asbestos. Would you document this as alternate compliance and upload the report? How have others documented this credit for buildings with asbestos?
Thanks in advance for any assistance.

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Tanja Arnesson Skanska Sweden AB
Oct 20 2011
LEEDuser Member
757 Thumbs Up

Project found old diesel tank

Hi,

At the commencement of excavation work the project discovered an old diesel tank that had leaked. This meant that some of the soil was contaminated with diesel. The project took its responsibilities and carried off the diesel tank and dug out the contaminated soil to leave this to the clean-up. Will this be counted toward this credit?

Thanks in advance!

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Larry Sims Principal, Studio4, LLC Oct 20 2011 LEEDuser Expert 2115 Thumbs Up

Tanja, if the soils were tested by an environmental professional and a (simple) remediation plan prepared, your project can achieve the credit when you document and submit the project's remediation efforts.

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Amanda Redmond-Neal
Aug 12 2011
Guest
199 Thumbs Up

is a closed landfill automatically a brownfield?

My project is to be built on top of a landfill that was closed in 1961. I have a very comprehensive "Final Closure and Post-Closure Maintenance Plan" that details required monitoring of the site for excessive methane, etc. I would describe this as the brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) remediation plan. However, I don't have any official document that states "this site is a brownfield." My question is, would a record that the site was used as a landfill for many years serve as sufficient evidence of brownfield status? I mean, what could be more of a brownfield than a landfill?

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Larry Sims Principal, Studio4, LLC Aug 16 2011 LEEDuser Expert 2115 Thumbs Up

Amanda,

Landfills are one of the largest sources of pollution in communities throughout the U.S., so I’m certain as much leeway as possible would be afforded to any project attempting to rehabilitate a landfill site. However, there are certain protocol that should be adhered to. A landfill site meets the definition of a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) if environmental contamination has been identified, or presumed to exist by virtue of the type of materials deposited, such as a municipal solid waste landfill that receives household waste. Absent a site being designated a brownfield by a recognized government agency, the documentation you are required to submit is an acceptable environmental site assessment and remediation plan. I can’t determine if your comprehensive “Final Closure and Post-Closure Maintenance Plan” meets the threshold. If you have any doubt, have an environmental firm review your report. If it doesn't, I would recommend contracting an environmental firm to have one done.

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Ryan McClain President, Pinnacle Energy Services Aug 26 2011 LEEDuser Member 44 Thumbs Up

Also, in case your project happens to be a medical-related facility I think I remember reading that the health care supplement explicitly excludes building on a prior landfill. See SSPr 2. (Again only for healthcare).

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Larry Sims Principal, Studio4, LLC Aug 26 2011 LEEDuser Expert 2115 Thumbs Up

Ryan, you are correct.

LEED 2009 for Healthcare

SSp2 Environmental Site Assessment

"Sites that are contaminated due to the past existence of a landfill on the site are prohibited..."

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Keith Robertson President Solterre Inc.
Aug 02 2011
LEEDuser Member
471 Thumbs Up

Encapsulation of impacted soils

In our jurisdiction, encapsulation of contaminated soils (with a "cap" that contains and prevents leaching) is considered acceptable for remediating a site. Is there precedence in LEED 2009 or 2.2 for this?

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Nov 21 2011 LEEDuser Moderator

Keith, I can't speak to whether this practice has worked for other projects, but LEED seems clear that the remediation standards are up to the relevant jurisdiction.

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Heather Holdridge Sustainability Coordinator Lake/Flato Architects
Jul 13 2011
LEEDuser Member
1343 Thumbs Up

Asbestos Abatement Documentation

We are developing on an existing site that requires asbestos abatement, so we're pursuing this credit under the third option. The demo contractors are saying that there is typically no LEED documentation during the abatement process. I assume they're referring to documentation they would be responsible for though. The only documentation would be the third-party remediation plan, correct?

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Heather Holdridge Sustainability Coordinator, Lake/Flato Architects Jul 13 2011 LEEDuser Member 1343 Thumbs Up

Also, how do I document this on LEED Online since it's neither options 1 nor 2? Is this alternative compliance approach?

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Ellen Mitchell Sustainable Design Manager, HKS, Inc. Jul 13 2011 LEEDuser Expert 3658 Thumbs Up

I have had success with submitting only remediation verification plans/reports in a couple of past projects. Unfortunately they were both v2.2, but I would think that the alternative compliance path is the best way to go for v.3.

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Denise Dauplaise Architect, Berners Schober Apr 17 2012 LEEDuser Member 169 Thumbs Up

I am in a similar situation, and trying to determine how best to fill out the LEED form. Is Option 1 the way to go, since the abatement could be called a "local voluntary cleanup program" ?

I see Larry references Option 2 below, unless it was designated as a brownfieldAbandoned, idled, or under used industrial and commercial facilities/sites who expansion, redevelopment, or reuse is complicated by real or perceived environmental contamination (may include hazardous substances, pollutants, or contaminants). They can be in urban, suburban, or rural areas. EPA's Brownfields initiative helps communities mitigate potential health risks and restore the economic vitality of such areas or properties. (EPA) ahead of time. Does that sound right?

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