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Financing Environmental Cleanup



More often than not, environmental cleanups pose a significant financial challenge for clients.  At Norfolk, we have found it helpful to meet with clients and stakeholders to help them identify and pursue the best financing options available.  From state brownfields tax credits  and federal tax deductions to UST reimbursement funds and insurance policies, Norfolk can help you find the funding best suited to you and your project.  If a loan is what you need, Norfolk can help explain the situation to your financier to take some of the uncertainty out of lending.

Some examples of how we work with our clients include;

    • Norfolk recently helped the owner of a former gasoline station petition for reinstatement of eligibility for 1.5 million dollars in reimbursement funds.

    • We have helped  municipalities identify, pursue, and receive millions of dollars in grants.

    • An elderly homeowner was faced with cleaning up a serious home heating oil spill.  She had exhausted all funding options but was ineligible for "financial inability" status from the state and had been denied a bank loan.  Norfolk worked with her bank to quantify the financial risks and structure the cleanup project such that she could tap the equity in her home to clean up the property. 

Several of our clients who have financed their cleanups "out of pocket" have been pleasantly surprised to find that they could recover 25 to 50% of their cleanup costs through tax credits.

When a client had a leak from a gasoline tank, their insurance carrier initially denied coverage.  Norfolk worked with the client, insurance agent, and attorney to provide supporting justification for the claim, such that the insurance carrier agreed to provide coverage, saving the client nearly $100,000.

If you have questions about how to pay for your environmental cleanup or if you have already paid for an environmental cleanup and would like to find out if you might be eligible for a tax credit, please contact Jon Kitchen at (508) 747-7900 x154. 

You can also read more about our site remediation and brownfield redevelopment services by following the links.

Norfolk is an environmental consulting and engineering firm which provides technical advice on the cleanup of hazardous waste sites.  While Norfolk helps clients identify funding we do not provide tax, legal, or financial advice.

Find out if you qualify for a Brownfields Tax Credit!

EPA Proposing Regulatory Changes for Coal Combustion Residuals


On May 4, 2010 EPA released for public comment a proposed rule for regulating coal combustion residuals (CCR) generated by the combustion of coal at electric utilities and independent power producers. The 90 day public comment period was extended through November 19, 2010; however, a final decision is not expected immediately. Two regulatory options have been proposed; under the first proposal CCR would be listed as special waste subject to regulation under Subtitle C of RCRA when designed for disposal in landfill and other surface impoundments, however, under the second proposal, all CCR would be regulated under Subtitle D of RCRA. EPA defines CCR as fly ash, bottom ash, and boiler slag.


Of concern to the environmental consulting community are the potential costs associated with changes in the regulatory status of CCR as a hazardous waste as it relates to landfill and disposal of this material. Although the proposed EPA rule is presently applicable only to electric utilities and independent power producers, CCR is often present in significant quantity in urban fill. EPA changes in the regulatory status of CCR as either a non-hazardous or hazardous waste can be expected to eventually impact the decisions made regarding the cleanup of Brownfield sites in Massachusetts and other states.


To learn more follow this link to EPA’s website for additional information on CCR’s:, or contact Charles Young at

Massachusetts DEP Issues “Technical Update” Regarding RCRA Land Disposal Restrictions and Contained-In Determinations


Last March we blogged about the need for careful soil management at redevelopment sites, including the pitfalls of dealing with RCRA wastes.  This month the Massachusetts DEP has released written guidance relative to one aspect of the management of RCRA waste; the state management of the federal “contained-in” policy.  This policy allows for certain low concentrations of RCRA “listed” waste to be treated as non-hazardous under very specific circumstance.  It is a tool that has the potential to achieve substantial savings at sites where management of RCRA waste is required (e.g. dry cleaners and former plating or jewelry manufacturing facilities).  A link to the DEP Technical Update is provided here

If you have questions regarding soil management or brownfields redevelopment please contact Jon Kitchen at (508) 747-7900 x154

In Massachusetts, environmental clean-up of some brownfields sites can receive as much as a 50% refund in the form of a tax credit.  Learn about the Brownfields Tax Credit and find out if you qualify!

Property Redevelopment News - Soil Management


Property Redevelopment News - EPA Penalties Remind All of Us of the Importance of Careful Soil Management

Recently EPA ordered a real estate developer to pay $227,500 in fines for violating the Resource Conservation and Recovery Act (RCRA) during the redevelopment of a former jewelry manufacturing facility in North Attleboro, Massachusetts.  The fine related to the failure to identify 212 tons of waste as hazardous.  The waste, which apparently consisted of sludge cake and soil, was disposed at a facility that did not have a license or permit to accept hazardous waste. 

This recent fine highlights the importance of careful soil management during redevelopment projects.  Properties with certain past uses (e.g. jewelry manufactures) require special attention with regard to the potential applicability of certain RCRA regulations.  Developers should be aware that, at these types of properties, even very low concentrations of contaminants can result in a soil being classified as a "listed" hazardous waste under RCRA.  Sloppy handling can result in an increase in the total soil volume requiring disposal due to RCRA rules relating to mixing.  Even if you are working on a property that has achieved regulatory closure with EPA and/or a state environmental agency, these RCRA disposal requirements will still apply.  It is important to work with an environmental consultant who will identify early on in the project if any soils on-site could be classified as a RCRA waste.  Given the disposal cost of RCRA waste, this information may cause you to rethink your entire development strategy. 

State regulations may also come into play at a broader range of sites.  For example, in Massachusetts soil from properties that have achieved regulatory closure under the Massachusetts Contingency Plan are still subject to disposal restrictions.  These restrictions are easier to work with than those applicable to RCRA waste but they still require a level of awareness on behalf of the developer and/or their environmental consultant.  Given the common use of risk-based regulatory closure for disposal sites in Massachusetts, it is not uncommon for properties to contain contaminants in soil at significant concentrations even after achieving regulatory closure.  Massachusetts regulations commonly called the "anti-degradation" provisions must be considered when reusing this soil on-site or off-site.

Soil management at the location of a release of oil or hazardous material is complex, regardless of whether or not regulatory closure has been achieved.  Soil management should be considered early on in the site development process.  Norfolk Ram Group staff is always available to provide input regarding your soil management needs.  If you have an immediate concern regarding soil management, please contact your Norfolk project manager or Jon Kitchen at (508) 747-7900 x154     

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