The Citadel EHS Happenings Newsletter
The Citadel EHS Happenings Newsletter is a space where Citadel EHS shares a variety of different topics that range from things going on at Citadel to things happening in the industries we support and practice areas and project sites where we work. We are enthusiastic about sharing our experiences and knowledge with you, and we welcome your feedback and suggestions as well. Citadel EHS provides environmental consulting and engineering services across five primary practice areas:
- Building Sciences: The BSci team specializes in hazardous materials management, including asbestos, lead, polychlorinated biphenyls, mercury, universal wastes, and the many environmental services related.
- Engineering and Environmental Services: E&ES focuses on Phase I and II ESAs, subsurface investigation and remediation, site soil management, human health and eco risk assessment, and much more.
- Environmental Compliance: Our EC team helps clients comply with municipal-, state-, and federal-level environmental regulations to avoid fines and penalties. Expertise includes IAQ, SCAQMD rules compliance, dust monitoring, SWPPP, SPCC, hazardous waste management, general auditing procedures, and much more.
- Industrial Hygiene and Safety: Our IH&S expertise ranging from developing overarching IH programs and monitoring strategies, to sampling, to providing cost-effective organization-wide recommendations.
- ESG and Sustainability: Citadel’s ESG&S team supports building owners, managers, and investment teams with actionable and objective ESG advisory services to help set, track, and meet ESG goals.
Our California clients operate within what is widely considered the most challenging framework of environmental regulations in the country. For nearly 30 years, Citadel EHS has been proud to help them efficiently and cost effectively navigate this challenging environmental landscape.
The write-ups that follow in this newsletter feature timely topics of interest and relevance to our practice areas.
Building Sciences: BSci Practice Leader, Kier DeLeo, CHMM, CAC, offers recommendations based on decades of experience supporting clients who manage wide ranging commercial construction projects, public and private sector.
My Building was Built in 1990, I Don’t Need an Asbestos Survey…
Regularly we get calls from property owners and general contractors needing an asbestos survey late in their project process because they didn’t think a hazardous materials survey was required due to the building’s construction date.
Sometimes the calls are frantic- ‘we started demolition three days ago and the project was stopped by a regulator,’ to stressed- ‘we are starting demolition in two days and the demolition contractor won’t start without a hazardous materials survey,’ to frustrated- ‘we went to pull our demolition permit and the City won’t issue it without a survey.’ We always get our clients what they need, but it can add days to their project start, and increased costs over a hazardous materials survey done in advance.
All these issues stem from the common misconception that asbestos has been outlawed in the US, and that after some date of construction (I have heard 1985, 1989, 1990, etc.) there can’t be asbestos in the building and a hazardous materials survey is not required.
While some applications of asbestos, such as fireproofing, pipe insulation, and acoustic sprayed ceiling materials were banned, most building materials with asbestos have not been banned, such as floor tiles, mastics, and roofing, to name a few. US manufacturers of building materials generally stopped intentionally adding asbestos to most of their products by the early 1980’s. However, you can still walk into a hardware store today and buy building materials containing asbestos, most notably roof mastic. We actually have to be careful when purchasing roof mastic to patch our roof sample locations, to make sure we buy the right type of mastic without asbestos. Some brands even have a non-asbestos version and a version that may contain asbestos.
Asbestos is also a non-intentional contaminant of many other building and other product ingredients. Asbestos is a naturally occurring mineral (rock), and it is sometimes present in areas where other minerals are mined, and when this occurs, it can unintentionally be part of that mined ingredient. This is why most baby powders now use cornstarch as the base, not talcum powder. Asbestos veins ran through some areas of talc, which is another naturally occurring mineral that is produced by mining, and when that talc was mined, there was the potential for accidental inclusion of asbestos in the talc.
Additionally, with the increased globalization of trade, building materials may be sourced from other countries with differing regulations on ingredient reporting. So, there is the potential that a building material manufactured outside of the US contains asbestos, even though the material would not contain asbestos if manufactured in the US.
Regulations also require an asbestos survey prior to demolition or renovation of a building or other structure. The EPA through the National Emissions Standard for Hazardous Air Pollutants (NESHAPs) , Cal-OSHA through Section 1529, and the local Air Quality Management District/Air Pollution Control District (for example: South Coast AQMD in Southern California through Rule 1403) all specifically require a hazardous materials survey to be completed prior to disturbing building materials, and none of these set an end date after which a survey is not required. These regulations place the onus of ensuring a survey is done on the building or project owner, but Cal-OSHA also places an additional requirement on the General Contractor to ensure that asbestos is handled appropriately on their projects, and without a hazardous materials survey this requirement cannot be complied with.
To summarize- there is no date after which a building is constructed that automatically means it does not contain asbestos, and the applicable regulations require a survey regardless of date of construction. So even a building built in 2022 will require a survey if it is to be demolished or renovated. Many municipalities also require a survey to have been done to issue a demolition or renovation permit. For some municipalities, it is a simple self-check box on the permit application, and some require submission of the survey.
The risks of not conducting an asbestos survey include the following, in no particular order:
- Schedule Risks- if you don’t have a survey done in advance, and are compelled to by a regulator, municipality, or contractor, this can delay the start of your project. There is the time to identify that the survey is needed, to hire a consultant, and for the consultant to conduct the survey and prepare the report. This delay can range from days to weeks.
- Regulatory Risks- if you start the demolition or renovation without a survey, the project team (contractors and owner) can be cited by a regulator for not following the rules. The most common would be for SCAQMD (or another Air Quality Management District/Air Pollution Control District) to become aware of the project, visit the site, and issue either a Notice to Comply requiring the survey to be completed before resuming work or a Notice of Violation requiring the survey and likely assessing a fine(s). A stop work order is also common to come from a municipality’s building department. Frequently the building department may also notify the AQMD/APCD.
- Health Risks and associated Litigation Risks- If an asbestos containing material is disturbed because a survey wasn’t done, it can present a potential health risk to the people disturbing the material, others in the work area, and in some cases, even the public. No one wants to put anyone’s health at risk. Additionally, this can be the basis for litigation.
- Reputational Risks- the preceding risks all provide the potential to damage the reputation of an owner or contractor, if experienced.
There is no date of construction after which a hazardous materials survey is not needed. A survey is needed prior to renovation or demolition in all cases, and not performing this survey in advance presents a variety of risks to the project and project team.
 40 CFR Part 61, Subpart M, specifically subsection 61.145 (a)
 CCR Title 8 Section 1529, specifically subsection (k)
 South Coast AQMD has further clarified the requirement in their latest Rule 1403 Frequently Asked Questions (FAQ) document updated October 27, 2020), section 3.
 CCR Title 8 Section 1529 subsection (d)(5)
Engineering and Environmental Services: E&ES Senior Project Manager, Scott Grasse, P.G., shares information and perspective on an important topic that is directly relevant to conditions in Southern California.
Oil Well Abandonment:
Considerations for Redevelopment
In Southern California today, we are challenged by an affordable housing crisis, in part due to dwindling developable land which contributes to exorbitant land costs. On top of this, our state has strict, complex environmental regulatory requirements, further exacerbating the problem. Maybe today more than ever, this perfect storm of circumstances is bringing attention to an age-old challenge in Southern California – how can we address the thousands of abandoned oil well properties, and return these sites to productive, developable land for the benefit of the entire community?
According to the California Geologic Energy Management Division (CalGEM), more than 225,000 oil wells have been drilled in California since 1876. There are over 126,000 abandoned wells in California, with nearly 17,000 in Los Angeles County alone. There are over 38,000 wells that are idle and in need of proper abandonment. Many abandoned wells in Los Angeles County were abandoned more than 50 years ago, before the current safety standards were in place. Oil well abandonment is therefore a legitimate concern for property developers.
The presence of an abandoned well on your property can halt redevelopment in its tracks. The mere presence, or believed presence, of a buried oil well can lead to lengthy agency review and project delays. Building over old wells is generally not permitted without regulatory review by CalGEM, and unless it can be demonstrated that the wells have been abandoned properly.
When Does a Well Require Remediation?
A well that is not properly abandoned to current standards, or one in which a methane gas leak has been detected, requires remediation. This can involve repairing the well head and/or wellbore casing to re-abandonment and may include the installation of vent cones that collect and safety vent leaking methane.
The first significant challenge before conducting a methane leak test is often simply finding the well. Wells that were abandoned a century or more earlier can be buried tens of feet or more under the surface. Through document research and use of available GIS information, experienced professionals can find most wells without an expensive survey. We recommend verifying the well’s location as a first step in any project because the results of this search may sometimes indicate that the well location information may be inaccurate.
Safety Risks from Improperly Abandoned Oil Wells
Improperly abandoned wells can be a public safety and nuisance risk when they leak methane (a gas associated with oil wells) that is inhaled or can explode, or when fluids are forced out of the wellbores onto the surface. The good news is that wells that do not meet current abandonment standards may not require expensive remediation. Although requirements vary from county and city jurisdictions, along with the CalGEM review, methane leak testing is often an adequate first step in satisfying local agencies that a well is abandoned so that redevelopment may proceed.
Citadel was recently asked to evaluate the integrity and safety of an abandoned, buried oil well at a site slated for redevelopment into a 500,000 square foot distribution center in Tracy, California and to investigate potential impacts to the environment from previous oil field operations.
Through records review, physical inspection and collaboration with CalGEM, we were able to determine that the well would require re-abandonment measures to elevate the safety and integrity of the abandonment to current regulatory standards.
Our team, consisting of petroleum engineers and geologists and specialty subcontractors, conducted a geophysical survey to locate the buried well. Once located the wellhead was exposed, visually inspected and monitored using a methane sensor to evaluate the air space around the wellhead. Citadel then advanced a series of borings to collect soil and soil vapor samples to test for the presence of methane and analyze the soils for potential oil field related contaminants including heavy metals and petroleum hydrocarbons. Citadel’s well abandonment team, under the guidance of CalGEM, re-abandoned the well to lower the well casing to allow for a portion of the proposed building to be constructed over the oil well.
With 20+ years of in-house oil field expertise, we offer turn-key services that include everything from navigating the complex permitting landscape, finding buried wells, methane testing, wellbore integrity assessment, and full abandonment or re-abandonment services. Our skilled team works collaboratively with regulatory agencies to ensure projects move forward and stay within scope. With so many moving parts to these complex operations, let our expertise effectively manage your oil-field related concerns from methane surveys to oil well location and abandonment. Learn more
Industrial Hygiene and Safety: Indoor air quality is a hot topic, with extensive public interest in recent years. Scott Brehmer, MPH, CIH, CSP, Citadel’s IH&S Practice Leader, offers relevant and timely perspectives in his piece that follows.
Better Indoor Air Quality
Leads to Higher Employee Productivity
indoor air quality (IAQ) and ventilation. But it hasn’t just been Covid that’s driving up interest in these areas. Businesses and organizations have come to recognize that better IAQ is better for business. It equates to more productive workers, less distracted students, protection against adverse health impacts, fewer employee complaints, and overall, a better indoor experience. Five years ago, most of Citadel’s IAQ work was driven by employee complaints.
A worker experiences a headache and sore throat whenever they work in a particular building. Citadel responds and investigates to find the cause of the issue. Although we still conduct these investigations to identify causes of poor IAQ, client requests for IAQ support have broadened. We’re now asked to conduct pre-occupancy IAQ studies, especially after new construction or renovations, to verify that construction debris or building materials won’t have a negative impact on occupants when they move in. It’s a smart move to conduct this sort of study because it not only ensures good IAQ for occupants when they move in, it also sets a baseline for how the building should perform moving forward. If a potential IAQ issue arises in the future, the original baseline survey can be referenced and compared to other investigations.
Of course, we can’t talk about IAQ now without talking about ventilation. Even prior to the pandemic, Citadel made a strategic decision to invest in staff development and equipment (including airflow capture hoods and anemometers) to increase our expertise and capabilities in ventilation. The investment paid off during the pandemic, when clients sought to understand how well their ventilation systems were performing. For example, Citadel assessed ventilation system performance and IAQ for Coast Community College District in 2021 to help bring students back to the classroom. The assessments covered 3 campuses, the District Office, and over 80 buildings in total. Spaces and buildings with subpar IAQ were identified and addressed, giving administrators confidence to bring students back.
ESG and Sustainability: ESG&S Practice Leader, Ravi Bajaj, LEED AP+, WELL AP, shares his knowledge (and passion) on the topic of ESG, and in particular the growing interest in its value, applications, and measurement
The Value of ESG:
SEC’S New Standards Highlight Merits of ESG Programs
ESG (Environmental, Social, Governance) reporting continues to maintain the focus of the investment world, while also being tested by the headwinds of today’s complex world. Specifically, ESG is being tested in regards to the nonuniformity in ESG reporting and accounting, a lack of transparency in materiality assessments, ESG claims vs true action, ESG in light of the war in Ukraine, and finally in the context of SEC’s proposed rulings for climate-related disclosures. Information reported about the value of ESG is quickly sliding into a 2-sided argument – a temptation when we focus on univariate issues for why we should, or should not, continue to prioritize ESG reporting. An alternative solution instead would be to focus on using the reported data and ESG management programs to inform continuous improvement, especially for portfolios of physical assets.
This uncertainty of how to measure and value these metrics is precisely what ESG reporting is trying to address. The world of financial risk is a complex one and requires disclosure and ongoing metrics to evaluate what is most important to an investor, client, or manager. The SEC and FASB have maintained a long-standing legacy of how to consistently report on financial metrics. Creating consistency in the way that climate risks are evaluated, and more importantly requiring disclosure of climate -related risks, will allow stakeholders to better understand the various risks and opportunities that exist for companies and organizations – an expansion of the financial reporting we are already accustomed to, ESG and sustainability reporting isn’t about requiring certain performance metrics, or meeting carbon emissions targets, those are byproducts of the process. It’s really about incorporating a framework for reporting Environmental, Social and Governance strategies that showcases how an organization is incorporating and planning for ESG-related risks.
Why is this important now?
SEC Proposed Ruling Summary
After over a year and a half of notices, the SEC (Securities and Exchange Commission) has released proposed rules for climate-related disclosures (see summary sheet and announcement). This move comes after a flood of open comment submissions, the evolution of a diverse set of reporting and scoring frameworks (such as GRESB, SASB, TCFD, Science-Based Targets, GRI, CDP, MSCI, Sustainanalytics, Integrated Reporting and more), and significant effort to propose standards that provide broad coverage of all industry types publicly reported. As a reminder, these focus on the “E” category of environmental risks. The bullets below represent the CliffsNotes of a 490-page document, and more information can be found via the SEC’s fact sheet or website. The gist of the proposed ruling is a rolling set of requirements to standardize financial reporting’s inclusion of climate-related disclosures:
- A report on climate-related risks, their material impact on business and strategy, and insight into the analysis process
- An outline of the governance structure and risk management processes for climate-related risks
- A hyper-focus on tracking and validating carbon emissions data (scope 1 and 2 first, with a rolling timeline of scope 3 disclosure requirements)
- Any information on performance against disclosed emissions goals or stated transition programs
- Detailed information about any scenario planning, carbon pricing, or other models used in identifying climate-related risks and goal-setting
This means that, if approved, the items summarized above would become material information that has to be disclosed on investor documents such as 10-K or 10-R forms, and ran through the same audit processes as current financial disclosures – a major shift for the accounting world, and something to keep a close watch over to see how ESG reporting evolves for the built environment.
Here’s an example
For the built environment, climate change can have a variety of impacts, some of which might be withstanding new and stronger weather events or accommodating new weather patterns for continued occupancy. Having a plan in place that assesses this risk, helps identify the material impact on building tenants and users and their rents, and helps define an appropriate reaction with a clear plan. This allows an investor or manager to better understand how to deal with this potential future impact. The primary driver in this discussion may fall under the Environmental category, but it quickly overlaps with social practices if a response plan can also address human health risks, accessibility issues, and future usability in the built environment assets covered. The Governance aspects could incorporate a decision-tree for owners and managers, outline board involvement in decision-making, as well as the cadence for ongoing analysis and monitoring, and which stakeholders will be involved in decision-making. This simple example of changing weather patterns, and how those impacts buildings and infrastructure as investment assets, showcases how complex of a world ESG planning and accounting is; and simultaneously illustrates how intimately tied to financial resiliency and investor interests these analyses and programs can be.
In summary, ESG reporting frameworks maturing towards more consistent reporting metrics and risk assessments will help elevate current practices to align with investment-grade information capable of being compared against peers and acted upon methodically. This will be a boon for investors and managers in planning, acting, and receiving recognition for their efforts. A major signal in the US of this pursuit of standardization is the recent SEC proposed ruling for climate-related disclosures.
Citadel Cares: Citadel Cares in an internal committee within Citadel EHS which organizes our volunteer events, Monday Motivations, monthly employee health and fitness initiatives, and company collaboration and celebrations.
Quarterly Volunteer Event a Success!
Citadel EHS Continues Commitment to the Environment.
Citadel EHS has a longstanding program for quarterly companywide volunteer efforts that benefit our communities and our environment. We consider the environment and our communities two of our biggest stakeholders! This is why we make such a commitment to do events and activities as a company that benefit them–both inside and outside of the office. Each quarter we make a commitment to improving our environment and the lives of those in our community by organizing a company volunteer effort. Our past Citadel Cares events have included tree planting, beach cleanups, personal care kits for the homeless, and many more. We ensure that each of our events aligns with our values as a company. We’re committed to reducing our impact on the environment while simultaneously looking out for the clients we serve and the businesses they hold. We practice what we preach, and we lead by example.
On June 25th, Citadelians championed as a team to clean up the Rosie’s Dog Beach in Long Beach California. Citadelians gathered together and picked up as much trash as possible to prevent trash from ending up in the ocean and our waterways—preventing harm to the environment and the animals that reside in it. Friends and family joined our employees in the sunshine as we cleaned the environment. Together 21 bags of trash were cleaned off of the beach, what an accomplishment and a volunteer victory for our waterways!
A Letter from Our CEO…
It has been almost 30 years since I began this journey to create an environmental, health, safety, and sustainability consulting firm that put its mission first and its profits second. In that time, that is exactly what Citadel EHS has emerged to be. Our team was carefully recruited, trained, challenged, and recognized to make sure that all employee owners that make up the Citadel EHS Family are here because they care about what they do. Being a values-based company is ingrained in the Citadel company culture so deeply that we made the decision to be completely employee owned almost two decades ago. When you talk to any employee at Citadel, you are speaking with an owner of the company.
At Citadel, we strive to have a positive social and environmental impact not only through the work we do for clients, but also in how we treat our employees and how we conduct our business. Our culture is the foundation of who we are and how we work, and is shaped by these shared beliefs:
We’re committed to doing the right thing, in the right way, for the right reasons. Honesty and ethics are what build every relationship, and that includes the relationship we have with our clients and work.
We look at every project as a way to build long-lasting, meaningful, and honest relationships with our clients—because we believe in people first, always. Our corporate-client relationships are no different
We maintain high expectations of ourselves as we strive to deliver innovative, comprehensive, sustainable solutions to our clients. We take pride in delivering outstanding results
Corporate profit and societal benefit are not mutually exclusive. We develop solutions that decrease costs, reduce risk exposure, and create shared value for stakeholders, employees (and their families), clients, the environment, and the community at large.
Our commitment to our employees goes beyond a paycheck. We care about their safety, well-being, and success. We nurture a culture that empowers our employees, because they are integral to our success.
We are committed to reducing our impact on the environment while simultaneously looking out for the clients we serve and the businesses they hold. We practice what we preach, and we lead by example.
Our expert team is our biggest strength—we possess an integrative knowledge base of Architecture, Industrial Hygiene, Safety, Geology, Engineering, Environmental Compliance, Construction, Sustainability and more that together ensure comprehensive strategies and solutions. Citadel EHS consultants deliver expert Environmental, Health, Safety, and Sustainability advice and support on a wide range of EHS issues to a diverse and growing base of private and public clients, both large and small. Our talented staff has generally seen it all, and pretty much done it all, at a level of quality that is uncommon. We are dedicated to making exceptional service and results possible.
Employee Owner of the Month
We are happy to announce that Harry Shove has earned the title of Employee Owner Of The Month for the month of July. Here is what some of his fellow teammates have to say about him.
“He is hard working and I admire his motivation and stamina to work on prolonged and long distance projects”
“He has been working in Vegas for multiple days a week, then going home to support his team on other projects, that says a lot about his character and work ethic.”
“He is an absolute pleasure to work with”
Harry, employees like you make the organization what it is today. We all thank you for bringing your best to work every single day!