Self-Directed Brownfield Remediation in California: A Practical Path to Closing PCE Vapor Sites1/26/2026
Brownfield Braintrust Podcast
Closing brownfield sites in California has become increasingly difficult—especially those impacted by volatile organic compounds (VOCs) like PCE and TCE. In recent years, environmental professionals, developers, and lenders have seen a sharp decline in No Further Action (NFA) letters, even for sites with stable conditions and no demonstrated human health risk.
At the center of the issue is California’s 2023 Vapor Intrusion Guidance, which introduced conservative Environmental Screening Levels (ESLs) that are often being applied as final cleanup goals rather than screening tools. The result is regulatory gridlock, prolonged oversight, and stalled real estate transactions. In an episode of the Brownfield Brain Trust podcast, Matt Winefield, founder of Winefield & Associates, spoke with Don Kellar, MS, REP, PG, Executive Vice President of Fulcrum (A Blew Company), about a strategy gaining traction across the state: self-directed (self-certified) brownfield remediation. This article highlights the key insights from that conversation and explains how self-directed remediation can help responsibly close PCE vapor sites in California.
Why NFAs Are Becoming Rare for PCE Vapor Sites
Historically, regulatory agencies issued NFAs when consultants demonstrated that a site posed no unacceptable risk to human health, groundwater, or off-site receptors. Today, that bar has shifted. According to Don Kellar, many sites remain open cases not because conditions are worsening, but because:
Even sites with clean indoor air and stable subsurface conditions may face years of additional assessment, adding cost without meaningful environmental benefit. What Is Self-Directed (Self-Certified) Remediation? Self-directed remediation is a consultant-led cleanup approach that avoids early regulatory agency notification when data shows that contamination can be managed responsibly without prolonged oversight. This strategy does not eliminate environmental rigor. Instead, it emphasizes:
Typical components include:
When these elements are present, consultants can document remediation progress and risk reduction without triggering multi-year regulatory oversight. ESLs vs. Cleanup Goals: A Key Misinterpretation One of the most critical issues discussed in the podcast is the growing misapplication of Environmental Screening Levels (ESLs). ESLs are intended to answer a single question: Is further evaluation warranted? They were never designed to define final cleanup targets. Yet in practice, consultants are often required to chase ESL numbers—such as 67 µg/m³ for PCE in commercial settings—even when:
Self-directed remediation refocuses cleanup efforts on actual risk, not theoretical thresholds. The Importance of Site-Specific Attenuation Factors Vapor intrusion models rely heavily on attenuation factors, which estimate how much subsurface vapor migrates into indoor air. Default guidance often assumes a 3% migration rate. Real-world data tells a different story. Across hundreds of sites, Don Kellar reports attenuation factors closer to:
Lenders and Risk Tolerance in Brownfield Transactions Not all lenders approach environmental risk the same way. Large institutional banks often require agency-issued closure letters because they plan for potential property ownership scenarios. In contrast, many non-bank and regional lenders are increasingly comfortable with self-certified remediation—provided the data is robust and defensible. This shift has allowed many brownfield transactions to proceed where they might otherwise fail due to regulatory delays. When Self-Directed Remediation Is Not Appropriate Self-directed remediation is not suitable for every site. Regulatory oversight is still necessary when:
A Practical Path Forward for California Brownfields The key takeaway from this discussion is simple: Responsible cleanup does not always require prolonged regulatory oversight. In many cases, removing contaminant mass sooner through targeted remediation does more to protect human health and the environment than years of additional assessment and reporting. Self-directed remediation offers a viable path forward for:
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Brownfield Braintrust Podcast
EPA Grants, Land Recycling, and Community Revitalization Across California, communities are sitting on thousands of underused or contaminated properties—former gas stations, industrial sites, rail yards, and aging commercial parcels. These sites are often seen as liabilities. In reality, they are some of the most valuable redevelopment opportunities in the state. In a recent episode of the Brownfield Braintrust Podcast, I spoke with leaders from The Center for Creative Land Recycling about how brownfield redevelopment works in California, where the funding is right now, and why cities, nonprofits, and developers should be paying close attention.
What Is a Brownfield in California?
In California, a brownfield is a property where redevelopment may be complicated by the presence or potential presence of contamination. That includes sites regulated or reviewed by:
When left untouched, brownfields suppress property values and stall investment. When redeveloped, they become housing, parks, grocery stores, job centers, and tax revenue—exactly what California communities need more of. Why California Has a Unique Opportunity Right Now EPA Brownfields Grants Are at a Historic High—for One More YearFor FY26, more than $250 million is available nationally through EPA Brownfields grants, thanks to the Bipartisan Infrastructure Law. This matters for California because:
After FY26, EPA brownfield funding is expected to drop significantly. If a California city or nonprofit has a site in mind, this is the year to apply. Who Applies—and Who Really Benefits In California, EPA brownfield grants are awarded to:
Developers, environmental consultants, engineers, planners, and construction teams:
As we say often: Brownfield redevelopment is a team sport. The Role of CCLR in California and the West Coast The Center for Creative Land Recycling plays a critical role in California brownfield redevelopment. CCLR is the EPA Technical Assistance to Brownfields (TAB) provider for Regions 9 and 10, covering:
That level of success matters when funding is competitive. California Is Moving Faster Than Most States California has accelerated brownfield reuse through programs like the Equitable Communities Revitalization Grant (ECRG), administered by DTSC. So far, ECRG has:
Real California Brownfield Success Stories Projects discussed on the podcast include:
They are visible, lived-in results across California communities. What If You’re a California Resident, Not a Developer? You still matter. In many California projects, community members:
“Why has this site been vacant for 15 years?” The Bottom Line for California California doesn’t have the luxury of ignoring underused land. Brownfield redevelopment:
If you’re a California city, nonprofit, developer, or consultant, this is the moment to act—not next year. Key Takeaway Brownfield redevelopment is one of California’s most powerful tools for community revitalization—and it works best when everyone is at the table.
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How Citadel EHS Secured Rare NFA Letters for VOC Sites in California: A Practical Path to Closure11/24/2025
Brownfield Braintrust Podcast
California regulators have dramatically reduced the number of No Further Action letters issued for contaminated properties over the past several years. Closures for sites impacted by chlorinated solvents such as PCE, TCE, and benzene have become increasingly difficult, especially under the updated 2023 CalEPA vapor intrusion guidance. In this new episode of the Brownfield Braintrust podcast, Matt Winefield talks with Greg McIver of Citadel EHS, one of the few consultants in California that has successfully obtained No Further Action letters for VOC sites in 2024 and 2025. Their discussion provides rare insight into what still works, what regulators expect, and how a property can realistically move toward closure today. This blog post summarizes the key lessons and case studies from their conversation and includes the embedded episode so readers can listen in full.
Why California Closures Have Declined
Winefield & Associates reviewed statewide NFA data earlier this year and found a 50 percent reduction in closures between 2017 and 2023. Vapor intrusion concerns, expanded screening requirements, and stricter risk evaluations have contributed to this decline. Regulators now require more data, more lines of evidence, and more certainty before approving closure, which prolongs investigation/remediation timelines and increases costs. Many owners and brokers underestimate the effort required to reach closure under today’s rules. This episode explains how closure is still possible when the process is managed strategically from the start. Who Citadel EHS Is and Why Their Success Matters Citadel EHS is a leading environmental consulting firm in California with expertise in vapor intrusion, chlorinated solvent remediation, toxicology, sub slab depressurization, and remedial design. Greg McIver, Principal Scientist and Co Practice Lead, brings 25 years of experience managing complex VOC sites. Citadel received multiple No Further Action letters for VOC impacted properties in 2024 and 2025. These recent closures provide a practical roadmap for others navigating the same challenges. The Most Important Factor: Stakeholder Buy In Greg explains that successful closures start with coordinated involvement from: • The regulatory agency • The environmental consultant • The property owner or developer • The legal and technical team when needed Instead of working in isolation and submitting reports at the end, Citadel collaborates closely with regulators from the outset. They confirm data gaps, agree on next steps, and shape the conceptual site model with the case manager involved. This approach reduces surprises and builds a shared understanding of the path to closure. Using the Low Threat Closure Framework for Solvent Sites Citadel uses the San Francisco Bay Regional Water Board’s 2009 Low Threat Closure Criteria for chlorinated solvents as an internal guide. Even when a regional board does not formally adopt this guidance, the structure helps consultants prepare a logical, evidence-based closure argument. Key criteria include: • Source removal • Delineation of soil vapor and groundwater impacts • Evaluation of sewer pathways • Demonstration of long-term protectiveness • Assurance that groundwater concentrations will reach water quality objectives • Documentation of multiple lines of evidence for vapor intrusion This consistent framework is one of the strongest tools for navigating closure under today’s standards. Case Study 1: Dry Cleaner Site in San Mateo County Citadel obtained a No Further Action letter for this site in October 2025. The property had legacy PCE releases from a former dry cleaning operation. Key achievements include: • Groundwater PCE concentrations decreased to 32.9 micrograms per liter • Soil vapor concentrations decreased from 1950 to 612 micrograms per cubic meter • Indoor air remained below commercial screening levels • Contaminated soil and sewer line impacts were excavated • Zero valent iron was injected to accelerate attenuation • No post NFA long term indoor air monitoring was required • A commercial use land use covenant was recorded This case demonstrated that closure is possible even with soil vapor concentrations above screening values, provided indoor air risk is sufficiently controlled. Case Study 2: Central Valley Dry Cleaner with High VOC Impacts A second No Further Action letter was issued by the Central Valley Regional Water Board in October 2025. This property had two former dry cleaners and much higher chlorinated solvent concentrations than Case Study 1. Key results: • Historical groundwater PCE reached 8,000 micrograms per liter • The highest well PCE concentration at closure measured 88.3 micrograms per liter • All other wells were below the 5 micrograms per liter drinking water standard • Soil vapor dropped from 900,000 to 1.77 micrograms per cubic meter • Vapor extraction, injections, and groundwater treatment had been used previously • Citadel shut down treatment systems that were no longer effective • Multiple lines of evidence supported continued natural attenuation • Post closure groundwater trending was the only requirement This case shows how strategic reassessment and focused sampling can replace years of unnecessary treatment system operations. What These Closures Tell Us About Costs Many brokers and property owners assume a dry cleaner cleanup costs in the neighborhood of $100,000 (“Just dig it out of there.”). The real numbers are far more daunting. VOC sites regularly require: • Several hundred thousand dollars when limited excavation or injections are enough • More than one million dollars when vapor extraction or groundwater treatment is involved • Higher budgets when two or more operators contributed to a comingled release Accurate cost modeling helps reduce uncertainty during brownfield transactions. Citadel uses expected, optimistic, and pessimistic cost scenarios to help clients make informed decisions. Major Lessons from Citadel’s Closure Strategy The episode highlights several takeaways for anyone evaluating or remediating VOC sites: • Collaborative regulators make closure achievable when engaged early • A complete conceptual site model prevents expensive surprises • The low threat closure framework remains one of the best planning tools • Treatment systems should be shut down when they no longer remove mass • Multiple lines of evidence are essential for demonstrating protectiveness • Thorough groundwater data reduces risk premiums for buyers and sellers • Closure is possible even with residual VOCs when indoor air is safe These lessons reflect what is working now across California. Listen to the Full Conversation The full discussion between Matt Winefield and Greg McIver offers detailed explanations, regulatory insights, and a rare look at recent NFA letters for VOC impacted sites. About Citadel EHS Citadel EHS is a market-leading environmental consulting firm specializing in vapor intrusion, toxicology, site assessment, remedial design, and environmental health and safety solutions. Greg McIver Principal Scientist & Practice Leader, Engineering & Environmental Sciences Email: [email protected] Website: https://citadelehs.com LinkedIn: Greg McIver
In this Brownfield Braintrust Podcast episode, our very own Matt Winefield, along with Steve Figgins of EKI Environment & Water, Inc. and Mark Johnson of Offit Kurman, discuss transforming oil production fields and how their remediation may differ from other industrial sites. For oil production think of wells, open fields, collection tanks, production pumps, and oil collection ponds. This topic is of particular interest as the State of California has not been shy about its intent to shut down oil production across the state. What may become a loss for oil production could be a gain for remediation companies, home builders, and commercial developers.
In this Brownfield Braintrust Podcast episode, we discuss environmental vapor sampling with two exceptional experts in the field, Will Rice of Enthalpy Analytical and Kevin Kelly of Langan Engineering. Those of you who are actively involved in brownfields assessment, remediation, and redevelopment have had to come to terms with new vapor intrusion agency guidelines and regulations that have tightened environmental screening. The reduced screening levels have prompted us to analyze more soil and soil vapor samples, so there is a greater need than ever to be efficient in the field and in the laboratory. To that end, we are going to examine one patented solution, VaporDeck™, a tool for soil vapor sampling everywhere. The VaporDeck™ provides a better solution to allow sample crews to simultaneously pull 2 or more samples from different depths, collect actual duplicates, and move from location to location faster, all while maintaining sample integrity and field documentation.
Our two esteemed guests:
The CalEPA State Water Resources Control Board is Issuing Very Few No Further Action Letters!5/2/2024
This podcast episode is a companion discussion for the W&A February 26, 2024, Vapor Intrusion blog, which you can access here: https://www.winefieldinc.com/vi-blog/calepa-swrcb-site-closure-rates-continue-to-decline-likely-due-to-vapor-intrusion-guidance
Matt Winefield discusses the Winefield & Associates GeoTracker data review of No Further Action (NFA) letter issuance rates before and after the CalEPA Vapor Intrusion Guidance (VIG) was promulgated. The data is not pretty. There no longer appears to be a path to closure for remediation projects of sites impacted with volatile organic compounds. Absent the ability to eventually achieve an NFA, brownfield investments throughout California are precarious. Visit Winefield & Associates, Inc. at: https://www.winefieldinc.com/ Find Matt Winefield on LinkedIn at: https://www.linkedin.com/in/mattwinefield/ Calling all commercial and industrial brokers! Matt Winefield had the privilege of taking part in a virtual Q&A session with eXp Commercial. eXp industrial brokers peppered Matt with questions about how to get deals closed when faced with contaminated soil and groundwater. This podcast includes a 15-minute overview of strategies for divesting brownfield properties and transferring environmental liabilities. The remaining 40 minutes are filled with real world solutions to actual transactions in the brokers’ portfolios. We have provided time stamps below the video podcast so you can peruse subjects of interest: Time Stamp - Topic
2:20 - eXp Introduces Matt Winefield 5:30 - Presentation Begins – “Saving a Property Transaction with Recognized Environmental Conditions” 6:00 - Defining a Phase I Environmental Site Assessment 7:44 - Types of Contaminated Properties 8:30 - Typical Remediation Methods 10:00 - General Thoughts on Environmental Price Reductions 13:40 - Third-Party Sources of Environmental Funding 15:00 - Expected Investor Returns for Brownfields 16:00 - Success Story No. 1 – Industrial Cleaner/Launder 17:00 - Success Story No. 2 – Gas Station 18:55 - Pre-Screening Sites for Environmental Problems 20:15 - Conventional Debt Availability for Contaminated Sites 23:25 - Environmental Disaster Story No. 1 – Dry Cleaner 25:00 - Environmental Insurance Polices 26:00 - Environmental Due Diligence Periods 30:40 - Environmental Disaster Story No. 2 – Plating Shop 31:20 - Environmental Grant Resources 33:20 - Older General Liability Insurance Policies and Possible Environmental Coverage 36:40 - Soil Vapor vs. Soil Matrix Sampling 42:00 - Transparent Approach to Negotiating Environmental Cost Reductions with Sellers 44:30 - Auto Shop Environmental Risks 52:00 - Broker Listing Strategies for Environmentally Impacted Properties It was a privilege for Winefield & Associates to be on a panel during the September California Land Recycling Conference. Our founder, Matt Winefield, shared a stage with environmental attorney Allison Torbitt and affordable housing developer Mary Jane Jagodzinski. The topic was Navigating Brownfields from a Developer’s Lense. Attendees included over 150 developers, regulators, consultants, and attorneys. Our brief presentation starts at about minute 12 and Matt's inquiries to the audience about California No Further Action letters begins during minute 41. Much was discussed about remediation funding and how to address brownfield regulatory challenges from both the non-profit and for-profit perspectives. In our current Brownfield Braintrust Podcast, Matt Winefield of Winefield & Associates, Inc. sheds light on Vapor Intrusion Mitigation Systems (VIMS) with the help of Justin Conaway, Vice President and General Manager of Terra-Petra Environmental Engineering. Given evolving soil vapor mitigation standards, VIMS are currently much more prevalent than just three years ago. It is unlikely one can acquire, for example, a former dry cleaner site (with PCE releases), run a vapor extraction system, and then pour your foundation. The lead agency will likely specify a VIMS that operates for the life of the new building. Justin explains the three most common VIMS technologies now utilized. Visit Terra-Petra at: https://terra-petra.com/
Find Justin Conaway on LinkedIn at: https://www.linkedin.com/in/justinconaway/ Visit Winefield & Associates, Inc. at: https://www.winefieldinc.com/ Find Matt Winefield on LinkedIn at: https://www.linkedin.com/in/mattwinefield/ To listen to an audio-only version of this podcast episode, click here. In this episode of the Brownfield Braintrust Podcast, Matt Winefield switched roles. He was a guest on “Straight Talk Schools,” a commercial real estate YouTube broadcast sponsored by Dusty Bates, broker extraordinaire of EXP Commercial. Dusty interviewed Matt in a discussion that could be entitled either “The Basics of Brownfields Investments” or “How to Save a Commercial Transaction When You Have a Bad Phase I.” For all of those new to sites with contaminated soils and groundwater, here are some guidelines on assessing environmental risks/costs as well as strategies to close your property sale or purchase. |
