Johanna Heywood, PE, PG

Transcription

1 Johanna Heywood, PE, PG MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

2 Past use of the site Chemicals used on-site Surrounding property usage Does not generally confirm or delineate contaminated areas MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

3 Phase I Environmental Assessment Standards for Real Estate Phase I Assessments ASTM E EPA Regulation of All Appropriate Inquiry (AAI) 40 CFR Part 312; see Compliance with ASTM E complies with AAI Soil, groundwater, soil gas and surface water quality Check current and former uses of property Think about associated waste streams Check status of property in regulatory databases Check existing reports May hire consultant to do sampling ASTM Standards for Phase I and II investigations MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

4 Elements of All Appropriate Inquiry Phase I ESA Report Standard is ASTM E Objective: to identify Recognized Environmental Concerns (RECs) Defined as: The presence or likely presence of any hazardous substance 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 thread of a future release to the environment. {a past release, an existing release, or a material threat of a release}

5 Elements of All Appropriate Inquiry (cont.) Phase I ESA: Four Major Tasks 1. Review of public records Database companies & agency file reviews Review historical records Fire Insurance Maps, aerials photographs, city directories going back to first developed use 2. Visual inspection of property and adjoining properties 3. Interviews with past and present owners/occupants (among others) 1. Report preparation

6 Looks can be deceiving

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8 1951 Aerial Photos SITE

9 1962 Aerial Photos SITE

10 1980s Aerial Photos SITE

11 Info from State File Review

12 2000 Aerial Photo

13 1917 Sanborn

14 1955 Sanborn

15 Superimposed Sanborn on Aerial

16 Sampling plan should balance past use and proposed use Sampling may include soil, surface water, sediment, groundwater Asbestos and lead-based paint Natural resource evaluation MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

17 Phase II General Requirements Evaluate the RECs identified in Phase I ESA. Determine whether hazardous substances or petroleum products were released or disposed at the property. Follow the E Standard Guide for Environmental Site Assessments: Phase II Environmental Site Assessment Process. The work scope can greatly vary and is unique to each property. Location, number, and depth of environmental soil borings/temporary wells strictly based on Phase I ESA results. Environmental soil boring locations encompass areas identified as potentially impacted by past/current operations.

18 Phase II General Requirements Appropriate sampling methodology / locations dependent upon the following: Suspected source of contamination (point source or nonpoint source). Suspected type of contaminant (volatile or non-volatile). Media affected (soil and/or groundwater). Anticipated depth of contamination. Soil / Geological conditions at the site. Depth to groundwater and groundwater flow direction.

19 Phase II General Requirements Soil samples collected at 5 foot intervals with a direct push rig (or 2 foot intervals using a split-spoon sampler with a hollow stem auger rig) and visually classified. Soil samples analyzed for combustible vapor concentrations using an OVM/PID At a minimum, one boring located in the down-gradient and one boring in the upgradient direction. If groundwater present, collect & sample.

20 Phase II General Requirements (continued) Types of laboratory analysis performed based on historical site use. The most frequent constituents tested for are: Volatile and Semi-volatile Organic Compounds SVOCs) which include petroleum and solvents, (VOCs and PAH s (typical of heavier petroleum compounds), RCRA metals PCBs Pesticides and Herbicides Investigation derived wastes should be addressed Soil / groundwater analytical results compared with the applicable regulations and appropriate requirements ("ARARs") TDEC Division of Underground Storage Tanks requirements (UST sites) EPA Regional Screening Levels (RSLs)- Risk-based Standards (non-ust sites that aren t regulated by another Agency Division)

21 Geoprobe or Hollow Stem Auger Rig

22 Phase II General Considerations Help the client understand the Phase II ESA findings by: Immediately reporting any encountered hazardous or emergency condition to the client. Summarizing the data to describe general trends or patterns and compare with state action levels - Using maps to show spatial patterns of RECs - Drawing attention to data that indicates conditions of concern - Identifying possible anomalies or inconsistencies in the data Indicating the relative degree of uncertainty with each finding Advising the client of any concerns that were identified but not addressed in the assessment. Stating whether there is or is not evidence of substances of concern in excess of state action levels Describing the chemical nature and known physical extent of identified impacts.

23 Recognized Environmental Conditions: Historic use as an un-permitted landfill; Possible contamination associated with sediments in former Chattanooga Creek Channel Former Leaking USTs at adjacent site to south Current and historic land use east of site (transportation related, potential for petroleum and solvent releases) Current and historic land use south of site (foundry, steel fabricators and enamelware company)

24 Ag / Food Waste Recycler Wholesale Trucking facility Warehouses and offices Wholesale Trucks (annex) 4 1 SITE: foundry waste landfill; historic dump, 2 Original Creek Channel 3 LUST Site 4 Transportation-related offsite concerns 5 Approximate location of gas tanks noted on 1930 Sanborn Map; Former Gas Station (1960 City Directory)

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27 Sampling Plan to address RECs: ONSITE RECs No. of Borings No. of samples 0 5 groundwater Sample Location Existing monitoring wells Proposed Analyses VOCs, SVOCs, PAHs, RCRA Metals Anticipat ed Depth (feet) N/A Comments Assess for potential contaminants from landfill use and former Chattanooga Creek sediments OFFSITE RECs soil, 2 groundwater 3 soil, 3 groundwater East end of site, toward Alton Park Boulevard Southern site boundary VOCs, SVOCs, PAHs, RCRA Metals, EPH (SOIL ONLY) VOCs, SVOCs, PAHs, RCRA Metals, EPH (SOIL ONLY) 20 to 25 feet 20 to 25 feet Assess for potential contaminants relative to current and historic landuse north, east and southeast of site Assess for potential contaminants relative to current and historic land use south of site (including former LUSTs at NAR PARK) Note: PAHs - Polynuclear Aromatic Hydrocarbons RCRA Metals 8 RCRA metals VOCs - Volatile Organic Compounds SVOCs - Semi-Volatile Organic Compounds EPH Extractable Petroleum Hydrocarbons

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29 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

30 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

31 EPA Publication: Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

32 Industrial/Commercial Business Incubator Office Space Health/Elder Care Greenspace Recreational Residential Public Use Facility Educational Other MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

33 Community-wide inventory and site prioritization Phase I and II ESAs Regulatory involvement 10% for health monitoring Can purchase environmental insurance MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

34 Considers the proposed use of the site Exposure routes - soil, groundwater Industrial or residential criteria? (adult vs. child exposure scenarios) Is a site-specific scenario applicable based on the proposed use? MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

35 Cleanup funded through MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014 EPA Revolving Loan Fund

36 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

37 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014 Cleanup funded through EPA Revolving Loan Fund

38 Cleanup funded through MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014 EPA Revolving Loan Fund

39 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014 Cleanup funded through EPA Revolving Loan Fund

40 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

41 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

42 Report contents:

43 Summary of soil results:

44 Summary of groundwater results:

45 Summary of soil results:

46 Summary of groundwater results:

47 FINDINGS Impact to soil and groundwater Soil Note that lead in soil consistent w/ foundry sand PAHs in soil not atypical considering history of the site Groundwater Note trends, i.e. contaminant presence in wells placed for onsite vs offsite RECs LF wells had detected concentrations of VOCs and metals (below the comparison criteria) Wells placed relative to sites northeast, east and southeast of project site had no petroleum or solvent-related compounds no impact to site from those RECs PAH compounds ID d in wells along southern site boundary consistent w/ petroleum use to south, (below the comparison criteria)

48 RECOMMENDATIONS Need to factor in Development Plans Potential for contaminated soil to be encountered during construction Potential for exposure to construction workers Given types and concentrations of contaminants, experience says that TDEC may allow them to remain in place If removed from the site may require special handling and/or disposal Construction on a closed landfill will change previously approved Closure/Post-closure plan seek TDEC approval for modifications Given extensive history of industry at site and in area recommend Brownfield Agreement provides liability protection

49 Follow up Coordination w/ TDEC for Brownfield Agreement Prepare and submit Redevelopment Plan to address mitigating potential exposure (human health and environment) In this case we recommended capping site - Prevent contact - Minimize infiltration reduce potential for groundwater migration General Contractor prepared health and safety plan for his workers

50 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

51 MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

52 EPA Publication: Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014

53 EPA Publication: Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014