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Environmental Site Assessments

Environmental Site Assessments. AN Introduction to brownfield redevelopment October 1, 2014 Rothman & Associates Erin K. Rothman, President www.rothmanassociatesllc.com. Introduction. All Appropriate Inquiries (40 CFR Part 312).

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Environmental Site Assessments

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  1. Environmental Site Assessments AN Introduction to brownfield redevelopment October 1, 2014 Rothman & AssociatesErin K. Rothman, Presidentwww.rothmanassociatesllc.com

  2. Introduction

  3. All Appropriate Inquiries (40 CFR Part 312) "All Appropriate Inquiries," or AAI, is the assessment or evaluation of a property to identify potential environmental contamination and assess potential liability for any contamination present at the property.

  4. ASTM E 1527-13 • Only American Society for Testing and Materials (ASTM) E1527-13 standards are recognized by the U.S. EPA as compliant with AAI. • In other words, only a Phase I ESA conducted in accordance with ASTM E1527-13 fulfills the requirements of AAI.

  5. Phase I Environmental Site Assessments • To comply with AAI, Phase I ESAsmust include a lot of specific types of information specified by ASTM. For example: • Interviews with past and current owners/occupants of the property. • Historical records for a property regarding previous owners and uses • Regulatory records • Site reconnaissance • And be written or supervised by an environmental professional

  6. Phase I Environmental Site Assessments • In addition, Phase I ESAsmust identify: • Vapor Intrusion Pathways • Recognized Environmental Conditions (RECs), Controlled Recognized Environmental Conditions (CRECs), and Historical Recognized Environmental Conditions (HRECs).

  7. Phase I Environmental Site Assessments • A REC is defined as “...the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to a release to the environment, (2) under conditions indicative of a release to the environment, or (3) under conditions that pose a material threat of a future release to the environment. De minimis conditions are not considered to be RECs.”

  8. Phase I Environmental Site Assessments • An HREC is defined as “…a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls.”

  9. Phase I Environmental Site Assessments • A CRECis defined as “…a recognized environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority, with hazardous materials or petroleum products allowed to remain in place subject to the implementation of required controls.” Landau 2012

  10. Phase II Environmental Site Assessments • Phase II ESAs are conducted in accordance with ASTM E1903-11 • Conducted to evaluate the RECs identified in the Phase I ESA • Often determined based on risk tolerance of the buyer/investor: Low Risk VS. High Risk

  11. What Happens Next? • Generally, two potential outcomes: • The results of the Phase II ESA are clean! • OR….

  12. What Happens Next? • (2) Soil, groundwater, soil vapor, or indoor air are contaminated… • …and you either lose interest (i.e., the risk is too high) or you move forward to evaluate cost and timing (i.e., perhaps the risk can be mitigated).

  13. Ecology Process - VCP • Ideal outcomes of participating in the Voluntary Cleanup Program • No Further Action Likely • Property-Specific No Further Action • Site-Wide No Further Action See Ecology’s Guidelines for Property Cleanups (2008) for more information

  14. Ecology Process – Voluntary Cleanup Program

  15. Ecology Process • STEP 1 (post-release discovery): Prepare and Submit Voluntary Cleanup Program Application • Can apply at any point in the cleanup process. • Include a work plan for the next proposed step, e.g., remedial investigation or remedial action. • Request an opinion. • Sign in blue ink. http://www.ecy.wa.gov/programs/tcp/vcp/vcp2008/vcpForms.html

  16. Ecology Process • STEP 2: Conduct the Remedial Investigation (WAC 173-340-350) • PURPOSE: To collect data necessary to characterize the site for the purpose of developing and evaluating cleanup action alternatives. • In other words, develop a Conceptual Site Model and put your site in a box.

  17. Ecology Process • STEP 3: Conduct the Feasibility Study and Disproportionate Cost Analysis (WAC 173-340-350 through 370) • PURPOSE of the Feasibility Study: To develop and evaluate cleanup action alternatives to enable a cleanup action to be selected for the site. • Active: Ex situ vs. in situ • Remediation systems: e.g., DPE vs. SVE vs. AS • Chemical and biological injections • Passive • Vapor intrusion barriers • Groundwater barrier walls www.daienv.com

  18. Ecology Process • STEP 3: Conduct the Feasibility Study and Disproportionate Cost Analysis (WAC 173-340-350 through 370) • PURPOSE of the Feasibility Study: To develop and evaluate cleanup action alternatives to enable a cleanup action to be selected for the site. • Screen the alternatives according to the minimum requirements outlined in WAC 173-340-360:

  19. Ecology Process • STEP 3 (cont’d): Conduct the Feasibility Study and Disproportionate Cost Analysis (WAC 173-340-350 through 370) • PURPOSE of the Disproportionate Cost Analysis: To determine whether a cleanup action uses permanent solutions to the maximum extent practicable. Includes an evaluation of cost vs. benefit of each alternative relative to the most permanent alternative proposed. • Screen the alternatives according to the Evaluation Criteria outlined in WAC 173-340-360 • Cost is an additional consideration in the DCA

  20. Ecology Process • Simplified Summary of a Disproportionate Cost Analysis (adapted from the LDW 2012 Final Feasibility Study: http://www.epa.gov/region10/pdf/sites/ldw/fs13/final_fs_sections_11-13_103112.pdf)

  21. Ecology Process • STEP 4: Prepare a Cleanup Action Plan (WAC 173-340-380) • PURPOSE of the Cleanup Action Plan: To outline the cleanup approach that was developed during the FS and will be applied at a site. • The level of detail is commensurate with the complexity of the site and the proposed cleanup action. • Engineering Design Report (WAC 173-340-400[1][a])

  22. Ecology Process • STEP 5: Conduct the Cleanup Action • Most commonly an excavation or system installation • Soil, soil vapor, and groundwater compliance sampling (protection, performance, and confirmational)

  23. Ecology Process • STEPS 6 and 7: Prepare the Cleanup Action Report and submit to Ecology for review and approval. • Construction/excavation approach • Operation and maintenance summaries • Field documentation • As-built reports • Compliance sampling results (protection, performance, and confirmational) • EIMS • Ecology correspondence and submittal

  24. Case Study • Phase I ESA • Heating Oil • Automotive Repair Facility • Phase II ESA • Clean groundwater • Contaminated soil After (2012 through present) Before (1959 through 2010)

  25. Case Study • Remedial Investigation • Findings • Cleanup Action Plan • Cleanup Action • Planned vs. discoveries • Site-Wide No Further Action

  26. Questions?

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