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Waiting for the Fish


As I am writing this we are in the early days of April having just wrapped up a Brownfield remediation project with the Town of Plymouth.   This was a marathon project with the goal of getting all earthwork completed by April 1st.  That’s when the fish come in.  All work had to be completed by that date which was no small feat as we combated springtime snow storms, rainfall events and the impending onslaught of herring.

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Historical Topographic Map Showing the Site in 1889

We began environmental investigations at the former Plymco Mill several years ago.  The property sits on the historic Town Brook in Plymouth, Massachusetts.  For well over two hundred years a mill sat at this location making leather goods, snuff, cotton and woolen textiles, metals products, and machinery.  Most recently the mill was used for lumber goods.  The environmental cleanup of the former Plymco Mill is a small part of a larger Town Brook restoration and dam removal project.  The project will remove two failing dams, restore fish passage and habitat, and provide open space and a recreational corridor which will extend from the Plymouth Harbor to the Billington Sea.  The Billington Sea is not a sea but a large pond first sighted in the distance by a young pilgrim named Francis Billington, but I digress. 

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Historical Plan from 1906 showing Mill, Workshops, and other structures

One of the primary goals of the Town Brook restoration project is enhanced fish passage for herring and other spawning fish.  If you remember your elementary school history these are THE fish… the same ones that Samoset, Squanto, and their contemporaries used to show the pilgrims how to plant their corn crops (well maybe the distant cousins of those fish).  The imminent arrival of these fish has been a constant specter looming over all our timeline discussions for the past several months.

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Earthworks at the Plymco with Town Brook in the foreground

 Earlier this year a grant from MassDevelopment ensured that the Plymco Mill remediation portion of this project would become a reality.  Norfolk coordinated the public bidding process on behalf of the Town.  As we surveyed the crowd of potential bidders at the pre-bid meeting on February 6th there were many skeptical looks when we described that the bidding would close, the project would be awarded, and all earthwork would be completed before April 1st.  I tried to convey a sense of overwhelming optimism.  The April 1st deadline is a date after which work in the brook would be prohibited so as to not interfere with the spawning of the herring. 


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Daylighting the channel over Town Brook

 The project was awarded on March 4, 2013 to D&C Construction of Rockland Massachusetts.  Less than four weeks later over 5,000 tons of contaminated soil and over 600 tons of debris has been trucked off-site, clean fill has been trucked on-site to replace the contaminated soil, buildings have been demolished, a portion of the brook that has been underground for over 100 years is now exposed to daylight, and the beginnings of Plymouth’s newest open space has been created.  The only thing left to do is to wait on those historic fish.  We are expecting them any day now.     

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View of newly exposed channel of Town Brook

 Kudos and congratulations to the Town of Plymouth for perseverance in getting this accomplished.  Truly an earth moving experience.

For more information about this project or Brownfields assessment, remediation, and redevelopment in general, please feel free to contact us.

Jonathan D. Kitchen, PG, LSP – (508) 747-7900 x154

Joseph P. Salvetti, LSP – (508) 747-7900 x127

Learn about Norfolk Ram's Brownfields Redevelopment related services here.

Free Download: Brownfields Redevelopment Cleanup Financing Options - Information Kit

Are you getting all the tax breaks you are eligible for?


Many of our clients are surprised to learn that they are eligible to recoup some of the money they have spent cleaning up oil spills and hazardous waste sites via tax breaks.  In Massachusetts, one of significant and often overlooked tax break is the Brownfields Tax Credit.  The Massachusetts Brownfields Tax Credit is, just as the name implies, a true tax credit.  It provides certain taxpayers with a credit for the cleanup of properties in economically distressed areas.  You may, or may not, be surprised to find that huge swaths of the state are considered economically distressed areas, including some communities that most of us would consider fairly affluent.  The lesson here is to check the list.  The credit ranges from 25 to 50% of net response costs.  The credits are both transferable and can be rolled from year to year, so you can obtain a benefit even if you have no taxes due.  In order to qualify for the credit, the taxpayer must not have owned or operated the site at the time of the release or contributed to the release.  Given how common it is for property owners to end up “paying for prior owner’s poor practices”, it is surprising how few claims are made under the Brownfields Tax Credit.    According to the Massachusetts Tax Credit Transparency Report , in 2011 approximately 80 taxpayers took advantage of this credit achieving a combined tax savings of over $40,000,000.  That may seem like a lot, but it is widely believed that this represents only a fraction of those who are eligible. 

A Federal Brownfields Tax Incentive is also available to some taxpayers.  This incentive allows for environmental cleanup costs at eligible properties to be fully deductable in the year incurred, rather than capitalized and spread over a period of years.  In this case, it is possible to claim the incentive even if the taxpayer caused the release/contamination.  In the past this incentive was not available for sites with only petroleum contamination, but in 2006 the rules were changed to include these sites.  Past tax returns can also be amended to include deductions for past cleanup expenditures. 

If you have questions about brownfields tax credits and incentives, Norfolk would be happy to talk with you and point you in the right direction.  Please contact Jon Kitchen at (508) 747-7900 x154 or use our contact form to tell us a little about your situation and someone will be in touch soon.

More information on the Massachusetts Brownfield Tax Credit is available from the Department of Environmental Protection  and Department of Revenue .  More information on the Federal Brownfields Tax Incentive is available from the EPA

Norfolk is an environmental consulting and engineering firm which provides technical advice on the cleanup of hazardous waste sites.  While Norfolk helps clients identify potential tax benefits, we do not provide tax, legal, or financial advice.  Certain restrictions apply to the credits and incentives discussed above.  Please be sure to consult with a tax professional.

 Find out if you qualify for a Brownfield Tax Credit!

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!

Attleboro site slated for remediation through a Superfund Cleanup


A former chromium plating facility in Attleboro has been designated as a superfund site to cleanup the contamination from the former operations.  The 2.7 acre site used to be operated by Walton & Lonsbury, Inc, and for over a 30 year period through 1970, all wastes generated from the facility were discharged into a wetland resource area on the site by an underground pipe.  Now the site contains contaminants such as chromium, hexavalent chromium, lead, and volatile organic compounds.

In order to clean up the site, workers will need to dismantle and remove plating tanks, excavated the foundation and contaminated  soil, clear the wooded wetland area, and treat the contaminated wetland soils.  As part of the remediation process, the contractor will use a dry-soil mixing process to bind existing soil with cement in-situ.  Once the contaminants have been adressed, the land will be turned over for a housing development.

For questions about site remediation or site assessments, please contact Brian V. Moran, P.E. at (508) 747-7900 or check out our remediation page.


Information for this post taken from the July 30, 2012 edition of Engineering News-Record, Page U9.

In Massachusetts, environmental clean-up of 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!

Wirral Waters Brownfield Project


Wirral Waters is an expansive Brownfield redevelopment project near Liverpool of an inland dock area that has fallen on hard times.

This project will take place in the East Float area of a docks complex called the Birkenhead Docks complex. The East Float area provides maritime services. The goal of Wirral Waters project is to create new city neighborhoods with their own role and identity, and a new city waterfront of international stature within the East Float neighborhood.  This project is expected to induce the regeneration of the sites and communities surrounding the dock complex as well.

In details :

  • £4.5-billion (U.S. $ 7.4-billion) project
  • 1.4 million m² of mixed-use space (office, retail, hotel, conference facilities, various amenities)
  • It is the largest project of the kind ever developed in the UK
  • The project will be completed in 30 years

The main aspect of this project and the key of its success as well is the design team, which is composed of urban designers, engineers, architects, and others. They are going to follow the principles of sustainable design, which guide the whole project.  Rainwater collection systems will be featured to conserve energy, and measures will be developed to conserve  water and to recycle. The government of the UK recognized the ‘’national importance’’ of Wirral Waters and this project is eligible for government support.

To ensure the uniqueness of each of the quarters of the East Float neighborhood, they will be designed by different architecture firms.

Three waterfront spaces will also be created.

The project of Wirral Waters will also include extensive water frontage, a series of floating pontoons, and 2 structures of historical importance that will be preserved and renovated – a former grain warehouse complex converted into apartments and a hydraulic accumulation tower damaged during WWII.

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As for the West Float Portion of the site, it will include a new international trade center, part of the Wirral Water development as well, with four buildings. It will be a center for 1,000 businesses all over the world and this will be the largest such facility in Europe.   

The Wirral Waters project consists of a huge construction work and of mitigation work as well.  The docks were bombed during WWII and there is a high level of industrial activity, thus there is a high probability of contaminants at the Site.

The Wirral Waters project also includes transportation improvements: multistory undergrounds and at-grade parking facilities will be designed. The strategy aims at emphasizing walking, cycling, buses and ferries. Roadways will also be constructed to regulate the speed of travel on the streets of Wirral Waters.


Information in this article is taken from July 2011, article ‘'Wirral Water Brownfield Project will be UK’s largest‘’ by Robert R. Leid, in Civil Engineering News. 


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!

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