ENVIRONMENTALSITE ASSESSMENT & CLEANUP FOR

BROWNFIELD SITES

AK Technical Assistance WorkshopMay 13, 2015

Agenda

1 Introductions

2 CERCLA, All Appropriate

Inquiry (AAI) & ASTM 1527-13

3 Phase I Environmental Site

Assessments (ESAs)

4 Phase II ESAs

5 Cleanup /Reuse Planning

6 Discussion

IntroductionsStantec Consulting Services Inc.

Chris Gdak, Brownfield Specialist• Civil/Environmental Engineer• Environmental Assessment, Cleanup

and Reuse• Project Manager for 10 current EPA

Brownfield Grant clients in Western US• Over $5M in Grants since 2012

Sara Lindberg, Manager of Env. Resources• Anchorage AK Office• Environmental Scientist• Environmental Assessment, Permitting

and Compliance• 85 Multi-Discipline Staff in AK

Goal of BrownfieldsRedevelopmentTransform underutilized brownfield sites from liabilities into assets, restoring them to safe, viable properties that contribute to the well-being of the community.

Requires Assessment Cleanup and Revitalization!

Example: City of Wausau WI Riverfront

31 Acres 100 Years of industrial useDecades of underutilization

Before

$2M of EPA and state grants. Transformed into mixed-use development, public library, trail, and kayak course. $45M of new investment. 840 jobs

After

Example: City of Wausau WI Riverfront

Brownfields and CERCLA Liability• To be eligible for an EPA Brownfield Grant, entities must

demonstrate that they are not liable for the contamination under CERCLA

• CERCLA = Comprehensive Environmental Response, Compensation and Liability Act (1980):

• Addresses abandoned hazardous sites• Establishes liability/funding eligibility

• To claim protection from liability, prospective purchasers/property owners must conduct All Appropriate Inquiry (AAI)

All Appropriate Inquiry (AAI)(40 CFR Part 312)

• A process for the evaluation of a property to identify potential environmental contamination and assess liability

• Must be conducted by an “Qualified Environmental Professional” within one year prior to acquisition of the property

Satisfying AAI can provide liability protection for prospective purchaser’s of impacted properties

All Appropriate Inquiry (AAI)(40 CFR Part 312)

AAI can also:

• Remove unknowns and concerns• Identify current and historic sources of contamination• Inform site selection and acquisition decision-making

(purchase price)• Inform site-specific reuse planning• Satisfy requirements of lenders and other stakeholders

American Society for Testing & Materials (ASTM) E1527-13The standard recognized for conducting Phase I Environmental Site Assessments (ESAs) that satisfies the requirements of AAI

• Published by the American Society for Testing & Materials (ASTM)

• Updated in 2013• Defines Phase I ESA process and criteria in detail!

Phase I ESAs - Logistics • First step in the assessment process

• A detailed, site-specific study aimed at establishing historic use, ownership, and current conditions of a property

•• Costs range from $3,000-$10,000+

• 2-6 Weeks to complete (avg. 4)

• Shelf life = 1 Year*

*Updates for certain components required after 6 months

Phase I ESAs - Logistics • Results in:

• 100’s (sometimes 1000’s) of pages of information!

• The presence (or absence!) of Recognized Environmental Conditions (RECs)

*Updates for certain components required after 6 months

Phase I ESAs – Activities Interviews:

• Current Owner• Past Owners• Occupants/Operators• Adjacent Properties• Regulators

Property records:• Assessors• Recorders (Ownership)• Fire Department• Building Permits• Health Department

Phase I ESAs – Activities Review of historical records:

• Sanborn Fire Ins. Maps – 1870s-1960s• Topo Maps – 1900-Present• Aerial Photographs – 1930s-Present• City Directories – 1800s-Present• Other Archives

Phase I ESAs – Activities Review of historical records:

• Sanborn Fire Ins. Maps – 1870s-1960s• Topo Maps – 1900-Present• Aerial Photographs – 1930s-Present• City Directories – 1800s-Present• Other Archives

Phase I ESAs - Activities Review of regulatory records:

• Federal – EPA (ACRES), NPDES, RCRA, TRI, CERCLIS, etc.• State – ADEC Contaminated Sites Database• Local – Code enforcement, inspections, etc.• Target property + properties within a certain radius• Radius Map Report (All-in-one)!

Phase I ESAs - Activities Review of regulatory records:

• Federal – EPA (ACRES), NPDES, RCRA, TRI, CERCLIS, etc. • State – ADEC Contaminated Sites Database• Local – Code enforcement, inspections, etc.• Target property + properties within a certain radius• Radius Map Report (All-in-one)!

Radius Map Report

Phase I ESAs - Activities Site inspections:

• Site features + Neighboring sites• Historic use • Present use• Use of chemicals • Potential sources/locations of environmental

impacts

Phase I ESAs – Don’t Include* Potential Site Improvement Concerns:

• Hazardous building materials (Hazmat) surveys

• Historic building evaluations

• Mold

• Industrial hygiene

• Indoor air quality

• Geotechnical

• Structural evaluations

* Can be added to the standard scope depending on assessment goals* Requires special expertise

Phase I ESAs – Don’t Include* Other Environmental Concerns:

• Cultural resources

• Ecological/endangered species surveys

• Critical/sensitive habitat/wetland surveys

* Can be added to the standard scope depending on assessment goals

* Requires special expertise

Phase I ESAs – Results

Recognized Environmental Conditions (RECs)

The presence or likely presence of hazardous substances or petroleum products in, on, or at a property:

1. Due to release to the environment; or2. Under conditions indicative of a release; or3. Under conditions that pose a material threat of a

future release to the environment

Phase I ESAs - ResultsExamples of RECs:Target Property:

• Chemical/waste storage areas• Underground/above ground storage tanks (USTs/ASTs)• Evidence of spills• Impacted fill materials

Neighboring Sites: Potential for impacts to migrate to the Target Property via:

• Groundwater (upgradient)• Surface releases (overland flow)• Air emissions (atmospheric deposition)• Vapor (from impacted soil/groundwater

Phase I ESAs - ResultsOther Terms and Conditions:• De Minimis: Minor impacts that generally do not

represent a threat to human health/ the environment or require enforcement or significant response actions.

• Historic REC (HREC): A past release that has been cleaned up to current standards and does not require AULs or require controls.

• Controlled REC (CREC): A release that has been addressed to the satisfaction of the regulatory agency and is subject to the implementation of required controls.

Phase I ESAs - ResultsOther Terms and Conditions:• Vapor Encroachment Condition (VEC; ASTM E2600):

Potential for vapor intrusion (VI) into buildings from impacted areas.

• Activity Use Limitations (AULs): Restrictions on use of a site to reduce potential exposure to contaminants.

• Institutional Controls: Land use/deed/groundwater restrictions.

• Engineering Controls: Caps, fencing, ventilation, monitoring.

Phase I ESA - Outcomes(1.) No RECs:

• Generally satisfies lending/legal/AAI

• Additional assessment/cleanup may not be required

• Other redevelopment related concerns may require action (Hazmat assessment, engineering studies, sensitive environment evaluations, etc.)

Phase I ESA - Outcomes(2.) One or more RECs:

• May raise concerns with lending/legal interests

• Additional assessment work is likely required:• File Reviews• Phase II ESA• Cleanup?

• In some cases could result in significant delays, development complications, prohibitive costs

Phase II ESAs - Logistics • Second step in the assessment

process

• Goals: Evaluate identified RECs

• ASTM E1903-11; can also vary based on location/regulatory agency)

• Involves sampling of potentially impacted media (soil, groundwater, surface water, sediments, air, building/waste materials, etc.)

Phase II ESAs - Logistics

• Costs range from $10,000-$100,000+ [varies widely based on site characteristics, contaminants and risk tolerance of stakeholders]

• ~2 weeks to 6+ months to complete.

• Shelf life = Indefinite (+/-changes in site conditions, sampling methods, regulations, etc.)

Phase II ESAs - Objectives

• Determine whether contaminants of concern (COCs) are present

• Define nature and extent of impacts

• Define physical characteristics of the site

• Development understanding of redevelopment constraints

• Develop reliable cleanup strategies and cost estimates

Phase II ESAs – Site Conceptual Model

Phase II ESAs – Activities

Soil Sampling:• Surface sampling• Test Pits• Soil Borings

Groundwater Sampling:• Monitoring wells

Other Media Sampling:• Drum contents• Waste piles• Surface water• Sediments• Unknown liquids

Phase II ESA - Outcomes

(1.) Sample Results Below Cleanup Levels (Methods 1-2):

• Generally satisfies lending/legal concerns

• Additional assessment/cleanup may not be required

• Proceed with site acquisition and redevelopment!

Phase II ESA - Outcomes(2.) Sample Results Above Cleanup Levels (Methods 1-2):

• Discharge or Release Notification – ADEC (18 AAC 75.300)

• Initial Response Actions – ADEC (18 AAC 75.310-.320)

• Additional work may be required:• Site Characterization – ADEC (18 AAC 75.325-.390)

• Remedial Investigation (RI)• Establish Cleanup Levels (Methods 1-4)

• Proceed to Cleanup

Cleanup - Logistics • Follows assessment process

• Goals:• Eliminate threats to human

health and the environment

• Restoration, reuse & revitalization!

• AK Site Cleanup Rules -18 AAC 75.325-.390

Cleanup - Logistics

• Activities:• Perform analysis of brownfield cleanup alternatives

(ABCA)• Complete Feasibility Study (FS)• Balance cleanup alternatives with reuse plans• Develop Cleanup Work Plan• Perform Cleanup Activities

• Costs range from $10,000-Millions+

• Weeks to several years to complete.

Cleanup - Alternatives• Many Options:

• Natural attenuation (clean-up via natural processes)• Removal actions, source controls and containment,

engineered system treatments• Institutional controls (e.g., land-use controls)

Cleanup - Alternatives• Many Drivers:

• Redevelopment schedule• Regulatory requirements• Costs• Community considerations• Schedule

• Look for opportunity to combine

Cleanup – Soil Alternatives• Removal

• Excavation, transportation,and disposal (Dig & Haul)

• Considerations• Reliable & long term

solution; liability risks?• Can be costly to implement,

but often quicker

Cleanup – Soil Alternatives• Treatment

• In place (in-situ) treatments: Bioremediation, Soil Vapor Extraction (SVE), Stabilization/Fixation, Thermal Treatment

• Excavation and at the surface (ex-situ) treatments: Land farming, Thermal Treatment, Bioremediation

• Contain and Manage in-place• Engineered “cap” or “cover” remedies• Vapor intrusion mitigation systems

Cleanup – GW Alternatives

• Remove (pump) & treat the groundwater• Hydraulic or physical controls• Air Sparging – from liquid to vapor• Dual-Phase Extraction• In-Situ Remediation Technologies

• Biological (typically bacterial) remediation

• Chemical oxidation

In-situ BioremediationCleanup – GW Alternatives

Cleanup – GW AlternativesIn-situ Chemical Oxidation

Cleanup –Outcomes

• Site Closure with Unrestricted Use

• Site Closure with Conditions:• Institutional Controls• Engineering Controls

• Restoration, Reuse, and Revitalization !!!

Our U.S. West team secures EPA brownfield grants with a more than90% success rate.

Site-Specific Reuse Planning• Identify future uses

• Strategies to facilitate infrastructure reuse and identify infrastructure improvements

• Market research

Site-Specific Reuse Planning• Community outreach

activities• Implementation

strategy• Phasing/

prioritizing• Catalyst projects• Financial feasibility• Sync with

remediation strategy

Thank You for Participating!Questions???