TABLE NO. 2 Industrial-Commercial

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1 Phase II Environmental Site Assessments (ESAs) What is a Phase II? An intrusive investigation of a site to collect samples of environmental media (i.e. soil, groundwater, surface water, and soil gas) for analytical testing Soil & Groundwater Testing Vapor Intrusion Investigation When is a Phase II Necessary? Assess RECs for Due Diligence prior to site acquisition Site characterization for No Further Remediation (NFR) Letter Practical redevelopment considerations 1

2 What to look for in a Phase II ESA Clearly stated objectives Assess some or all RECs Initial assessment vs. delineation Sampling Plan Rationale (How many? Where? Why?) Contaminants of Concern (COC) Conclusions/Recommendations Clear and concise Regulatory issues Practical considerations What if I find Contamination? May require additional investigation/delineation Active remediation Cleanup is not always required (risk-based closure) Balance regulatory requirements with practical considerations 2

3 Illinois Risk-Based Cleanup Program 35 IAC Part 742 (415 ILCS 5/58.5) Tiered Approach to Corrective Action Objectives (TACO) Regulations Establishes procedures for the development of site- specific soil and groundwater remediation objectives that are protective of human health and the environment while incorporating site related information such as geology, contaminant conditions and land use These Agency Program-wide regulations were promulgated in 1997 One of the most successful voluntary cleanup programs in the Nation. Since inception, approximately 3,500 NFR letters have been issued using TACO. -Source: Illinois EPA-January 2013 Basic TACO Overview Tier 1, Tier 2, Tier 3 Pathway Exclusion Area Background Determinations Engineered Barriers & Institutional Controls NFR Letter 3

4 Tier 1 Lookup Table Tier 1 Evaluation Soil Remediation Objectives (SROs) Groundwater Remediation Objectives (GROs) Land Use Designation Residential vs. Industrial/Commercial Construction Worker Evaluate Human Exposure Routes Soil Ingestion Soil Inhalation Soil Migration to Groundwater Groundwater Ingestion Coming Soon - Proposed indoor inhalation/vapor intrusion Tier 1 SRO Lookup Tables TABLE NO. 1 Residential SROs ANALYTE SB-101 (3-6') Route Specific Values Ingestion Tier 1 Soil Remediation Objectives (Tier 1 SROs) Residential Property Use Ihlti Inhalation Soil Component of Groundwater Ingestion Exposure Route Class I Class II Benzene Ethylbenzene 60 7, Toluene , Xylenes , TABLE NO. 2 Industrial/Commerical SROs Industrial-Commercial Route Specific Values Tier 1 Soil Remediation Objectives (Tier 1 SROs) Industrial/Commercial Property Use Construction Worker Soil Component of Groundwater Ingestion Exposure Route ANALYTE SB-101 (3-6') Ingestion Inhalation Ingestion Inhalation Class I Class II Benzene , Ethylbenzene , , Toluene , , Xylenes 0.9 1,000, ,

5 Tier 2, Tier 3 & Pathway Exclusion Method Use of site-specific specific physical and chemical data Exposure route evaluation Requires basic site and contaminant conditions be met: The attenuation capacity of soil and the soil saturation limits of COCs cannot be exceeded (i.e. no free product) Soil cannot exhibit characteristics of Reactivity Soil must have a ph between 2 and 12.5 (Corrosivity) Metals must not exhibit characteristic of Toxicity How are Exposure Pathways Eliminated? COCs meet Tier 1 or Tier 2/Tier 3 Objectives Safety precautions will be taken to ensure construction worker safety, (I.e. a Health & Safety Plan, Hazard Communication Plan, etc.) An engineered barrier is in-place that meets the requirements of TACO An IEPA-approved municipal groundwater use ordinance is in effect or site- specific groundwater use prohibition An institutional control (i.e. NFR letter) will be placed on the property to ensure maintenance of the engineered barrier or groundwater use restriction 5

6 NFR Letters Formal Agency acknowledgement of regulatory closure LUST NFR Letter (415 ILCS 5/57.10) The NFR letter signifies that all statutory and regulatory corrective action requirements applicable to the occurrence have been complied with, all corrective action concerning the remediation of the occurrence have been completed, and no further corrective action concerning the occurrence is necessary for the protection of human health, safety and the environment. SRP NFR Letter (415 ILCS 5/58.10) The NFR Letter signifies a release from further responsibilities under the Act in performing the approved remedial action and shall be considered prima facie evidence that the site does not constitute a threat to human health and the environment and does not require further remediation under the Act if utilized in accordance with the terms of the No Further Remediation Letter. Stipulations of NFR Letters Residential vs. Industrial/Commercial Focused vs. Comprehensive Maintenance of Engineered Barriers Groundwater use restrictions Site Safety Plans Off-Site notifications, Highway Authority Agreements (HAA) and/or Environmental Land Use Controls (ELUCs) Future handling of residual impacted soils/groundwater Filing Requirements 6

7 Vapor Intrusion - Proposed IEPA TACO Regulations Proposed Amendments to 35 IAC Part 742 Regulations (R11-9) First introduced in early 2009 (R09-9) 9) Current version accepted by Pollution Control Board on November 18, 2010 (R11-9) Adds exposure routes to be considered - Revised Outdoor Inhalation Exposure Route - New Indoor Inhalation Exposure Route Introduces new environmental media-soil gas Basic VI Overview Maintains Tiered Approach Concept Tier 1 look up tables Tier 2/Tier 3 site-specific specific evaluations Building Control Technologies Sub-Slab Slab Depressurization (SSD) System Sub-Membrane Depressurization (SMD) System Membrane Barrier System Vented raised floor system 7

8 Environmental Services Geotechnical Services Geothermal Services 8

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15 Wayne R. Smith, P.G. Wayne Smith is a Vice President of Pioneer Environmental Services, LLC and part of the management group that leads the company. He started his career as a Project Manager with Pioneer in His experience at Pioneer includes his work as a project manager, a senior project manager, and the environmental services director in charge of the company s operations. During his tenure in the environmental field, he has conducted more than a thousand Phase I and Phase II Environmental Site Assessments for industrial, manufacturing, and commercial properties throughout the United States. Wayne has also developed and implemented active remediation systems and successfully achieved regulatory closures on a wide range of contaminated sites. Wayne was the lead consultant responsible for successfullly completing more than 200 Brownfields redevelopment projects in Illinois. His expertise and knowledge in the field has also afforded Wayne the opportunity to be a featured speaker at Brownfields Redevelopment seminars. Wayne s specific experience includes: Performing Phase I Environmental Site Assessments and Environmental Regulatory Compliance audits for industry at over 350 facilities. Designing and managing soil and groundwater investigations for more than 750 sites. This work included: identification of areas of concern, sampling plan development, plan implementation and field supervision, project management, client contact, and report preparation. Conducting over 200 environmental risk assessments pursuant to the Illinois EPA s TACO (Tiered Approach to Corrective Action Objectives) regulations to obtain No Further Remediation letters through the Leaking Underground Storage Tank and Voluntary Site Remediation Programs to facilitate residential, commercial and/or industrial redevelopment. Designing and implementing numerous soil and groundwater remediation programs both for conventional remediation and alternative technology projects that included air sparging, soil vapor extraction, dual-phase extraction, groundwater pump and treat, low temperature thermal desorption, chemical oxidation, in-situ bioremediation, and natural attenuation. Conducting risk assessments using industry standards (Risk Based Corrective Action-ASTM), federal guidelines (Soil Screening Guidance-US EPA), and state procedures (TACO-Illinois EPA) to evaluate regulatory and practical considerations of Brownfields redevelopments. Responsible for creating, implementing, and directing standard operating procedures for the company and improving overall operating efficiencies and practices. Assisting clients with State and Federal Environmental Rules and Regulations, regulatory negotiations, and risk analysis. Was an integral part of a team that successfully negotiated one of the few Prospective Purchaser Agreements with the Illinois EPA and Illinois Attorney General in Authoring various environmental articles for industry trade publications. EDUCATION: Augustana College, Rock Island, IL B.A. Geology B.A. English CERTIFICATIONS / LICENSES: Licensed Professional Geologist (P.G.) - IL AFFILIATIONS: Illinois Association of Professional Geologists Urban Land Institute