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:
Listen to the episode on Spotify:
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