Site Investigation and Remediation
Innovation Saves Project and Money, Wins Phoenix Award
Westside Business Park Brownfields Site – Kansas City, Missouri
The Hispanic Redevelopment Corporation of Kansas City, Missouri, and its development partners (Westside) sought to revitalize the abandoned Kansas City Terminal Railway railyard and roundhouse. Utilizing a unique, financial/insurance instrument, a forward-thinking regulatory strategy, and a flexible, innovative investigation/remediation strategy, The Forrester Group assisted the client in avoiding hundreds of thousands of dollars in costs and accommodated the redevelopment project schedule and objectives.
Previous site investigations identified asbestos-containing materials, lead, and hydrocarbon contamination in soil. During site remediation, more significant contamination sources were discovered, including a buried rail car containing petroleum and ubiquitous arsenic contamination. This resulted in significant remedial scope expansion. Fortunately, at the beginning of the project, The Forrester Group recommended and the Client purchased an innovative insurance product to minimize their financial exposure resulting from unknown conditions.
The remediation solution included asbestos removal, sandblasting of the lead-based paint, and soil removal to eliminate the lead, arsenic, and petroleum impacts. Remediation costs were controlled by gaining MDNR approval to divide the site into cells and by using an innovative statistical approach to determine an alternate arsenic cleanup standard that limited excavation requirements and costs. This site also required implementation of other procedures unique to center-city projects, including a comprehensive stormwater control project designed to continually manage runoff from the site.
During site closure negotiations, The Forrester Group demonstrated that affected groundwater would be naturally remediated prior to leaving the site, thus avoiding further groundwater monitoring and treatment. The MDNR granted site closure, and the property is now the Westside Business Park in Kansas City, which includes the newly-renovated locomotive roundhouse. Site redevelopment culminated in receipt of a Phoenix Award.
RCRA Remedy Renegotiation Eliminates Unnecessary Remediation Costs – Missouri
At this active, 136-acre transportation site in Missouri, soil was impacted by lead and asbestos and groundwater was impacted by VOCs. The Client signed an Administrative Order of Consent with the USEPA to conduct RCRA corrective actions, and soil and groundwater remedies were identified in a Statement of Basis.
Upon inheriting this project, The Forrester Group successfully negotiated with the USEPA and the Missouri Department of Natural Resources to revise the groundwater remediation strategy. The new strategy called for risk-based closure for an area of groundwater that was marginally impacted above maximum contaminant levels and eliminated the installation of a groundwater recovery trench called for in the Statement of Basis. This change in remedial strategy has saved more than $1 million in construction, operation, and monitoring costs and has greatly shortened the path to closure in this part of the Site.
Subsequently, The Forrester Group obtained closure for soil and stormwater and is meeting agency requirements that will lead to site-wide risk-based closure for groundwater.
Risk-based Tier III Assessment Facilitated Renovation of Petroleum/Chlorinated Solvent-Impacted Site – Missouri
The Forrester Group enabled National Church Residence (NCR) to renovate a 1.6-acre senior citizens’ housing complex in St. Louis, using the Risk-Based Corrective Action (RBCA) Tier III provisions. The Phase I Assessment of the site revealed two gas stations and two dry cleaners had operated on the property. The subsequent Phase II site investigation indicated petroleum and chlorinated solvent impact to soil and groundwater.
The U.S. Department of Housing and Urban Development (HUD), the project funding source, had determined funding should be withheld because extensive soil and groundwater remediation could be required. At the time, Missouri’s Risk-Based Corrective Action program (MRBCA) was under development and in draft form but had not yet been implemented at a site.
Working closely with the MDNR, The Forrester Group collected key data and information to evaluate the true risk at the site. We conducted a focused direct-push soil and groundwater investigation to confirm that no additional sources of contamination were present. Subsequently, we conducted soil-vapor flux sampling to characterize potential vapor emissions, and a focused Tier III (i.e., site-specific) risk assessment to determine the associated risks.
On the basis of our analysis, MDNR determined that no remediation would be required as long as future exposure to impacted soil and groundwater could be managed through a restrictive covenant. This was acceptable to the client, and allowed HUD to approve funding for the building renovation.
Joe Williams, NCR’s Director of Acquisitions, highlighted The Forrester Group’s vital role:
“I truly believe this important project would not have been successful without the ‘out-of-the-box’ creative approach your firm used to accomplish environmental closure. As a federally-subsidized housing project, The Roosevelt Towne Apartments does not have vast resources at our disposal in order to resolve complex environmental problems. The Forrester Group understood this fact from day one and always took this into account when proposing possible solutions.”
VCP Tier III Investigation, Remediation, and Closure – Former Auto Wrecking Facility – Illinois
The Forrester Group performed an investigation and remediation of a 5-acre lead-impacted property owned by an industrial client in East St. Louis, Illinois. The United States Environmental Protection Agency (USEPA) sampled the site as part of a regional lead initiative, and found elevated concentrations of lead in surface soil across the site. To avoid an Administrative Order of Consent with USEPA requiring a large-scale remediation, the site was enrolled in the Illinois EPA Voluntary Site Remediation Program.
The Forrester Group designed a sampling program to determine representative lead concentrations across the site and the site-wide concentration. We also had groundwater wells installed to determine migration potential. USEPA-approved lead assessment techniques were used to develop a Tier III remediation objective for industrial-commercial land use. Data from the grid sampling was used to develop a remediation plan that minimized the volume of soil requiring removal to achieve an average concentration that met the Tier III remediation objective. Groundwater sampling demonstrated minor on-site lead impacts, and no off-site impacts.
This integrated approach reduced the amount of soil requiring removal to achieve the Tier III remediation objective from several thousand cubic yards with a typical approach to 800 cubic yards. The remediation was implemented during a two-week period. The client obtained a No Further Remediation letter, which relied on a local groundwater ordinance to eliminate the groundwater exposure pathway and a soil management plan to protect future site workers from exposure to soil left onsite.
Oil Spill Investigation and Remediation Complete Within a Week – Missouri
The Forrester Group investigated and remediated a lubricating oils spill at a metal stamping and pressing facility in Columbia, Missouri. The project was under the supervision of the Missouri Department of Natural Resources (MDNR) Brownfield/Voluntary Cleanup Program (B/VCP). As a result of our approach, there were minimal operational impacts, and the site achieved unrestricted use closure.
The site assessment revealed petroleum-impacted soil below the chemical storage area floor. Based on our review of the existing data, we were able to quickly confirm the source as lubricating oil and established that released liquids migrated through cracks in the flooring, impacting the subfloor of the building interior and subsurface soil immediately adjacent to the building exterior. The property was enrolled in the B/VCP to address the impacts.
Working with the remediation contractor, the facility manager, and the VCP project manager, The Forrester Group designed a process that minimized operational impacts and completed all indoor remediation work within seven days. Indoor remediation activities included concrete removal, excavation of impacted soil, confirmation sampling, replacement of subfloor material, and replacement of the concrete floor. Outdoor activities included removal of a small area of soil outside the exterior wall.
The entire process was completed in 12 months and resulted in a Certificate of Completion from the B/VCP.
Client Advocacy Saves Money at VOC-Impacted Site – Kansas
This chemical storage and distribution facility site is located in an industrial zone within a larger cleanup area being managed by the city of Wichita, Kansas. As part of the regional studies, Kansas determined the facility was a possible source of chlorinated VOC impact to groundwater.
In 2002, subsequent to negotiations with KDHE, The Forrester Group recommended that the client not agree to an Administrative Order of Consent but instead allow KDHE to implement a Unilateral Order. In so doing, the Client was protected from a cost recovery provision through which the Client would have become a PRP in the larger site. This has allowed limited Client resources to be used for environmental costs, rather than legal costs. However, we advised that work be conducted proactively to outpace city work, thereby earning goodwill with KDHE.
To date, The Forrester Group has completed on-site investigations and remedial actions to address on-site soil and groundwater and has begun post-remediation groundwater monitoring to assure the effectiveness of the remedy. Access agreements with off-site parties are now being negotiated to determine the extent of suspected off-site groundwater impact.