Brownfield Remediation Final Paper

Brownfield Cleanup: Analyzing Remediation

Methods By David Garcia

Submitted to Professor Rick Zimmer

Department of Urban and Regional Planning

University of Cal Poly Pomona

Spring Quarter 2011

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Table of Contents

Abstract 3

Purpose Statement 4

Literature Review 6

Methodology 15

Analysis 19

References 24

Appendices 27

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Abstract

Research will determine suitability of a particular Brownfield site, pursuant

to proper assessment and remediation methods. The premises is to decide

whether the specific location, selected by the Lead Agency, is adequate and

will not impose serious harm or danger upon public health, once remediated.

Potential stakeholders affecting project completion will be noted, especially

those relating to the economic, societal, and environmental impact of the site.

In addition, examining the usage of health-related statutes and legislation,

through guidance from Government Agencies like the EPA and CEQA.

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Purpose Statement

In the past decade, a great deal of attention has shifted toward the

redevelopment of Brownfield sites, defined by the Environmental Protection Agency

(EPA) as abandoned, idle or underutilized industrial and commercial facilities where

expansion or redevelopment is complicated by real or perceived contamination

( Meyer 2000 ). According to Peter Meyer, sites which lay situated along older,

dilapidated parcels of land pose inherent risk for developers. The degradation of such

properties remains intrinsic to communal identity for years, even decades, resulting in

unpleasantness and community stigma. Areas which were once eclectic centers of

commerce and industry, become blighted, disjointed, and perceived as unsanitary, due

to high concentrations of contaminated particles. As a result, land remains inhibited

from community plans, causing a process of decay. Idle, contaminated properties are

often located near commercial or residential settings, and may include:

• Abandoned Train yards

• Oil fields

• Landfill sites

• Gas Stations

The surrounding landscape, environment and ecology are afflicted

by Brownfield risk factors. Endangered species or habitats may require urgent care

and protection, especially those on the brink of extinction. Through habitat

conservation, the population may return to fruition. An area’s water supply may be

compromised if Brownfields are left idle and unmanaged. Through filtration and

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extraction of harmful chemicals like lead, alkaline and acid, water can be restored

to sanitary levels. Air quality may be the most vital element to consider, having a

lasting effect on the resident population. The potential for developing chronic,

respiratory conditions such as asthma, lymphoma and lung cancer can result from

weakened immune systems in connection with hazardous land.

Potential Stakeholders have a vested interest in redeveloping contaminated

properties. Many are active members of a city’s redevelopment agency, occupying

various positions within the local planning commission. Other stakeholder’s are

members of the general community, whose tax base allows for funding of projects.

Cohesion of socio-economic and environmental factors allows Brownfield

projects to define the region in which they exist. Coexisting with surrounding

commercial, residential or industrial areas, Brownfields come to symbolize change,

while providing vast economic opportunity.

Literature Review

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Due to the direct and indirect effect on land and property value,

consideration of contamination and solutions to it have emerged in significance in the

last decade ( Remediating Contaminated Land 2011 ). In recent years, new policies

and laws from the State and Federal Government, have assisted with proper

management and handling of contaminated site risks. For developers, it

is crucial to fully understand the terrain they are navigating. Every square foot must be

considered, both above ground and below. It is a delicate process requiring ample

research, scrutinized monitoring and strategic oversight . While virtually every state

allows consideration of risk in some fashion as part of their cleanup process, in most

jurisdictions, the manner by which risk is considered is still evolving ( Reott and Grayson

1998 ). Thus, developers must rely on similar case studies to decide on appropriate

action. The hazards and obstacles developers must overcome, are often,

insurmountable. For this reason, it is crucial that the Lead Agency familiarizes itself

with all major and underlying risk factors affecting health and future site potential.

Site Risks

Developers should consider the target area’s scope and existing conditions.

Location, size, and site configuration are just a few of the characteristics

associated with site risks. Location is primary – it cannot be changed. If the

property is small, however, there may be opportunities to combine it with adjacent

property as a means of maximizing redevelopment options ( Obrien and Gere ).

Location is vital, when decisions for appropriate action are made. Sites which

lay along residential areas, can often times, be linked with existing infrastructure,

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including water, gas, and electricity. In Pennsylvania, the city of Johnstown

enacted a site cleanup and remediation over a former Steel Company.

One of the main objectives for their plan, was tapping into existing infrastructure,

using careful precision and modification. Effectively, the Johnstown Redevelopment

Authority was awarded substantial grant money and earned the cooperation of various

creditors and investment agencies ( Brownfields EPA Region III 2002).

Plot and Land search tools are the ideal solution for any property developer.

One challenge of selecting a Brownfield property is the size of the plot. An old town

center petrol station or workshop might only occupy a relatively small footprint. But

because of economies of scale, most property developers are only interested in

building 30 or more units at a time ( Brownfield Development 2010). Although gas

stations carry a relatively light footprint and are smaller in comparison, Developers

may choose to go with a larger site, where profit can be maximized. This selection

method can sometimes create uneven balance and apportionment for Brownfield sites,

but ultimately, it’s the developer’s discretion.

New standards have been implemented to gauge which sites are best suited for

site selection. According to Evans Paull, the Northeast Midwest Institute has analyzed

various lot-sizes, to propose a common standard for Brownfield sites. The study

included average lot size, average investment and amount of jobs created:

o Mean site size: 5 - 6 acres

o Median site size: 3 – 4 acres o Mean site investment: $20 - $25 million

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o Mean jobs created or retained (80 – 100 permanent full-time jobs

Exposure and Pathways

Exposure pathways can be defined as the manner by which a person or an

organism may be exposed to a chemical of concern or contaminant. A complete

exposure pathway consists of a source, a release from a source, a migration and

transport mechanism, an exposure medium (e.g., air) or media (in cases of intermediate

transfer), an exposure point, and an exposure route ( Mississippi Department of

Environmental Quality 2007). According to Dillon Consulting, exposure is illustrated

utilizing a Venn diagram, where overlap exists between Hazard, Receptor, and

Exposure Pathway. Key toxins and hazards include Petroleum, Hydrocarbon, Metals,

Chlorinated Solvents, Asbestos, and Mold. Receptors are unquestionably represented

by human populations including workers, residents, visitors, women, and children.

Elevation and surface features present other obstacles for developers to

overcome. The direction and position of land can sometimes cause spillage or

chemical release toward the direction of the grade. In addition, toxic vapor can seep

out of ground openings, posing new challenges and concerns. Absorption of toxic

substances along exposure pathways may occur by contact, ingestion or inhalation.

Types and usage of site can also determine the level and presence of contaminated

particles. Industrial sites tend to be the most hazardous and potentially volatile.

Industrial properties are typically contaminated with asbestos, heavy metals, volatile

organic compounds (VOCs), semi-volatile organic compounds (SVOC), and

polychlorinated biphenyls (PCBs) from manufacturing operations at the property

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(EPA 2010). By analyzing soil components and toxicity levels, developers can decide

what method of remediation to implement.

Financial Risk

Financial Risk is driven by the process needed to purify the site. Purification process

depends on types of contaminants present, toxicity level, and exposed pathways.

If a Brownfield has contaminated soil, the developer may choose to implement an

excavation and removal, or soil vapor extraction of the soil. Superfund sites, which

potentially are the most dangerous, may require greater technology and long-term

operation or maintenance, bringing uncertainty to investors . According to Risk and

Insurance analyst, Adam Bressler, lenders remain cautious about providing debt

financing on properties known for suspected contamination.

On a 565-acre site in Richmond Virginia, a former army Defense Supply Center

underwent treatment for on-site contaminants. A hydrocarbon removal was

conducted, with results indicating the presence of toluene, a solvent

which can cause neurological harm. Actual cost of the pilot study was $76,099,

consisting of $18,225 for capital equipment and $57,874 for operation and

maintenance. The unit cost of the pilot study treatment activities was $76/yd3, per

1,000 yd3 treated ( Office of Solid Waste and Emergency Response 2010 ).

Because of the multitude of risks stemming from Brownfield project, investors

and developers often buy Pollution Liability Insurance, which essentially, protects

Brownfield-backers from third- party lawsuits. Offered by several insurance

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companies, pollution legal liability insurance addresses the third party risk posed by

contamination, both pre- and post-remediation, among other things. An example of this

contingent risk includes possible claims by neighboring landowners and lessees

(Missouri Department of Natural Resources 2010). Our changing economy is leaving

local governments struggling to find new ways to provide economic growth and to

create jobs in an economic, social and environmentally responsible manner. The silver

lining of Brownfields is that they offer the opportunity to address multiple local needs.

Corroborating Site Risks and Remediation

Risk Management of Brownfield sites is often assessed utilizing a three-tiered

system, based on site characteristics. The tier system operates by analyzing human

and ecological risks, in a cause-and effect model. Decisions are made in each of the

three tiers to determine the best device for on-site remediation. Another approach

common to the study is the RAGS study. The Risk Assessment Guidance for

Superfund is used in collaboration with the EPA to address criteria incorporated into

the human health evaluation process. Base-line Risk Assessment uses qualitative and

quantitative analysis to describe exposure, toxicity, and risk characterization,

being compartmentalized into four major groups. The California Human Health

Screening Levels ( CHHSLs) is a useful tool, helping the Lead Agency assess

contamination, based on a list of 54 Hazardous Particles. Levels of Significance and

Thresholds must be followed during implementation of necessary mitigation measures.

Tier System for Risk Management

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The cornerstone of the Brownfields Program is a three-tiered risk-based process

for evaluating human health and environmental risks. These tiers are referred to as

Tier 1, Tier 2, and Tier 3 ( Mississippi Department of Environmental Quality 2002 ) .

The tiers are designed to allow the applicant to evaluate and determine appropriate

remedial options for site specific conditions. Tier 1 identifies site specific data, which

is then compared to a table of target amounts for on-site chemicals deemed to be

acceptable. Tier 2 gives the applicant the opportunity to perform a more

comprehensive evaluation of site-specific conditions. Revisions can be made to Tier 1,

in terms of how long-term remediation will be handled. Remediation goals can be

adjusted in accordance with any changes made to on-site data and specific

information. Tier 3 concerns the possibility of human health being jeopardized by trace

levels of contamination in connection with a set remediation goal. The ecology is also

considered using the same rubric. Land–use regulations are addressed in terms of

how to reduce or eliminate potential risk.

The State of Illinois utilizes a system referred to as TACO. The Tiered

Approach to Corrective-Action Objectives is a methods for deciding the precise amount

of remediation necessary for site cleanup. The TACO approach looks to conserve

expenditures, reduce heavy investment and find practical solutions toward

rehabilitating sites ( Illinois E.P.A 2007 ).

Human Health Evaluation Process

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In the current state, the California Human Health Screening Levels

provides a set of criteria for measuring site safety. The California Human Health

Screening Levels (CHHSLs or “Chisels”) are concentrations of 54 hazardous chemicals in

soil or soil gas that the California Environmental Protection Agency (Cal/EPA) considers

to be below thresholds of concern for risks to human health. The CHHSLs were

developed by the Office of Environmental Health Hazard Assessment (OEHHA) on

behalf of Cal/EPA, and are contained in their report entitled “Human-Exposure-Based

Screening” ( California Human Health Screening Levels 2005 ).

Steps for addressing immediate characteristics include identifying chemicals

of concern. The first step is recording CHHSL’s for chemicals occupying differing

forms of matter ( water, air, surface, sub-surface, etc. ) Also, measuring CHHSL’s to

determine cancerous and non-cancerous effects. Formulae are then implemented to

measure the amount of carcinogen present divided by the amount needed to cause

cancer overtime. Sites afflicted by toxic but immobile chemicals such as PCB’s, DDT,

and arsenic usually require a standard remediation. Other chemicals, whose

properties cause leeching into surrounding soil and groundwater, may require greater

detailed levels of extraction. In some cases, naturally occurring chemicals may exceed

state-regulated levels, however, Cal/EPA does not require the lowering of such

particles. An example of this is arsenic, which has a naturally higher concentration than

average-safe levels for residential, commercial and industrial use.

Risk Assessment Guidance for Superfund

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Helps provide various definitions used to address health concerns ranging

from cleanup expectations to the impact on human health. The Superfund program

seeks to locate, investigate, and clean up the worst hazardous waste sites throughout

the United States. In some cases, local governments may be held liable for

contamination at a site based on their role as a past or current owner or operator of a

contaminated site ( LGEAN 2010 ).

Cleanup Standards states a strong preference for remedies that are highly

reliable and provide long term protection. In addition to the requirement for remedies

to be both protective of human health, the environment and cost effective ( Office

of Emergency and Remedial Response 1989 ). The RAGS approach provides guidance

for selecting the proper remedy for site cleanup. The primary consideration

in selecting a remedy is that it be protective of human health and the environment, by

eliminating, reducing, or controlling risks posed across each pathway. Next, the lead

agency reviews any resulting public comments on the Proposed Plan, consults with the

support agencies to evaluate whether preferred alternatives are still appropriate,

and then makes a final decision. A record of decision (ROD) is written to

document the rationale for the selected remedy ( Office of Emergency and

Remedial Response 1989 ). An important procedure RAGS uses is data acquisition.

In general, types of data collected are identified and listed using full term as well as

the acronym. Most of the data is acquired during the course of remedial investigation/

feasibility study ( RI/FS).

Baseline Risk Assessment

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Baseline risk assessment focuses on quantitative and qualitative

variables, like natural hazards— such as catastrophic weather or seismic events

( Information Technology Sector 2009 ). In dealing with Brownfield projects,

Baseline risk often concerns potential for developing serious illness or disease

from on-site toxins. In a memorandum sent by John Clay, issues concerning

exposure to on-site chemicals are addressed, using both quantitative and qualitative

analysis. Where the cumulative site-risk to an individual based on reasonable

maximum exposure for both current and future land is less than 10, and non-

carcinogenic hazard quotient is less than 1, action generally is not warranted unless

there are adverse environmental impacts ( Clay 1991).

Methodology

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Premise

Initial assessment, proposed mitigation, and ultimate remediation may help

guide a contaminated site from obscurity to potential redevelopment. Utilizing

thresholds and screening levels, in accordance with quantitative/ qualitative

measures dependent upon human health, ensure the validity and integrity of the

Lead Agency toward rehabilitating the Brownfield site. Improving the Socio-Economic

and Environmental health of the area is a key priority.

Site Background

The study site chosen, a former Crown Coach facility in Downtown Los

Angeles, was suspected to contain substantial amounts of chemical and

biological hazards, affecting the immediate vicinity. Upon request by the

Los Angeles Community Redevelopment Agency, Camp Dresser and McKee Inc.

conducted a Phase 1 Environmental Site Assessment. The main objective of

the Phase 1 ESA, was to identify the presence of hazardous substances and petroleum

products on-site. Results and determinations of the Phase 1 Report were made in

accordance with information obtained by Camp Dresser and McKee. An interview was

later conducted with CRA Project Manager Dan Weissman. During a site

reconnaissance undertaken on March 14, 2008, the property was assessed for the

presence of solid waste, non-hazardous waste, polychlorinated biphenyls, air quality,

potential asbestos containing material, storage tanks, ground water, wastewater,

and pesticide use ( Camp Dresser and McKee 2008 ). The property, encompasses

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an area of 20.6 acres, being zoned as M3-1 and M3-2 ( heavy manufacturing and

industrial use. ) It is situated at an elevation of 225 feet above sea level, sloping

toward the south east. Previous uses of the site included manufacturing activities

until the late 1980’s, as well as being a small rail yard. In the early 1990’s,

early stages of soil excavation began, and in 1999, the property was entered into a

Voluntary Cleanup Agreement with Cal/EPA. Currently, the main lot is vacant and in

the process of remediation. ( Refer to Appendix B )

Historically, the site has been shared by many companies, with a heavy

emphasis on light-manufacturing. Between 1970 and 1984, Essick Manufacturing

Company occupied the buildings in the central and northwestern part of the facility,

which included five spray booths and one vapor degreaser. The Crown Coach

Facility originally operated a coach manufacturing facility, in the northern portion of the

site. The uses extended into railroad easements, coach building shops and railroad

lines which were once associated with the Amtrak rail yard on the east. Infrastructural

elements associated with the site include two sets of power lines crossing the property

from east to west, a sewer drain located at the southeast corner, as well as

groundwater wells and SVE equipment stored on-site and in close proximately to the

Amtrak facility. The subject property is currently owned by the state of California,

managed by the California Department of General Services. According to Project

Manager, Dan Weissman, CDM was unable to establish contact with past owners of

the site. Much of the site’s history was obtained via city records and past interviews.

Various departments and agencies have assisted with site assessment and

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analysis. The Department of Toxic Substance Control initially issued a No Further

Action Letter for the above 30-ft. layer of soil. Later, the DTSC stated the presence of

Volatile Organic Compounds was not properly delineated, and may have

recontaminated the top soil layer. Soil Vapor Extraction pilot studies were conducted on

various soil layers. The results indicated that an extensive SVE system could properly be

administered and utilized to purify ground-layer residuals. Additional tests included

borings being drilled at various locations on site, to evaluate underground sediment.

10 samples were collected for presence of petroleum hydrocarbons, in which only one

sample was found to contain a concentration of 68 milligrams per kilogram.

The presence of toluene and PCE were identified in over 50 percent of soil

samples, as well as trichloroethylene ( TCE ) along with the presence of 11 other

volatile and semi-volatile organic compounds. The Department of Toxic Substance

Control later concluded that maximum concentrations of 9,116 micrograms per

liter of PCE and 502 grams per liter of TCE were detected in a soil depth of 5-15 feet.

According to Camp Dresser and McKee, the presence of TCE and PCE were highest on

the Eastern Portion of the property. Their reports also concluded that estimated cancer

risk was around 6, which is considered acceptable by the EPA. CDA made note that any

type of redevelopment should incorporate ventilation and air ducts to effectively

remediate the risk of cancerous on-site particles.

In 2005, with oversight from the CRA, Soil Vapor Extractions were conducted

on shallow surface soil, within a 30 foot layer. A total of 29 pounds of Volatile Organic

Compounds were collected and successfully removed during this period. Camp Dresser

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and McKee concluded that since substantial amounts of VOC’s still remain in

deeper ground levels, lateral and vertical extension of the SVE system may need to be

implemented. In addition, a ground monitoring system would provide a backup

device, capable of detecting microbial contaminants on-site. Camp Dresser and McKee

also proposed tapping into the Amtrak Redondo Junction Facility, which borders the

subject property on the east, as a potential Renewable Energy Concept. In 2008,

Edward Song and Sibel Tekce of CDM, undertook a visual inspection of the property,

with questions being answered by Mr. Weissman, onsite. Non-Hazardous Wastes

were identified, including a long PVP pipe, an empty 55-gallon metallic drum, and

a partially embedded metal rod, which may have been connected with the site’s

previous railroad activity.

Analysis

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Variables

The following are a list of Qualitative and Quantitative measures critical toward

successful remediation of the study site, complying with CA. Human Health guidelines.

• Hazardous and Non-Hazardous Waste Substances

• Sub-Surface and Above Layer Soil

• Presence of Carcinogenic Particles

• Water Supply and Storage Tanks

∙ Transport Mechanisms and Exposure Pathways

• Existing Infrastructural Elements

• Topography

The variables were analyzed in terms of their on-site presence, hazardous

degree, and suitability level for cleanup. In addition, utilizing the 6th step in the

CHHSL’s Guide, which preserves human health by comparing on-site chemicals with

thresholds needed to cause harm. Given the sites’ history of manufacturing products

for the Crown Coach company, main hazzards and risks stem from historical usage of

machine shops, air-conditioning manufacturing, paint and spray booths. Over time,

much of the chemical contamination from such action, spewed beneath the soil.

Therefore, it was necessary to access the site’s subsurface layers and underground

water supply, which subsequently, may have been contaminated.

As previously noted in the Site Background, shallow underground soil contained

the chemical liquid, toluene, often used in paint thinners and solvents. Left untreated

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in large amounts, toluene can cause serious neurological harm, headaches, vision loss,

even death. On-site, the chemical was found in abundant concentrations in shallow

sub-surface layers. Through ventilation and Soil Vapor Extraction, the presence of

toluene will diminish over time. Safe levels of Toluene are around 100 ppm. A soil

extraction was also proposed in the Phase 1 document, to collectively remove any

remaining residual particles.

Other chemicals being remediated include trichloroethylene, ( TCE ) styrene,

grease, oil and tetrachloroethene ( PCE ) which is commonly used for degreasing

automobile parts. Pursuant to the sites’ product assembly history, the presence of

these toxic chemicals was highest along the eastern portion of the property. Based

on the findings, a complete soil removal was developed with a cleanup level of 10 ppm

of TCE. According to EPA Standards, safe levels of TCE are usually around 50ppm

(CHHSL 2005). Nearly 40,000 tons of VOC’s, lead, oil and grease was also removed

during this time. Recent implementation of deep surface SVE equipment, continues to

yield productive results.

Given the sites topography, with a general decline toward the southeast,

hazardous surface particles could move down the grade of the property, washing

away from the site, naturally depositing into sewage drains. This would help alleviate

and circumvent extensive remedial options, on areas where natural surface slope

exists. The main exposure mechanism and medium of concern is air. Wind can often

blow toxic surface-residue across the site, creating new problems to manage.

( Refer to Appendix A )

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During a site reconnaissance, undertaken by Camp Dresser and McKee,

No observable Storage Tanks were identified, either above or below ground. Storage

Tanks often cause leakage of hazardous chemicals, liquids or gas directly into surface

or sub-surface sediment. In addition, ground water can be severely comprised

if underground-storage tanks rupture or leak outward. This actualization was a

monumental relief for the Lead Agency, causing optimism and reassurance.

As previously noted in the Site Background, a cancerous risk of 1E-6 was

determined, based on chemical components, liquids and solutions whose properties

influence the creation of cancer cells. However, this threshold is deemed to be

reasonable by EPA Guidelines, and with proper vapor barriers and active ventilation,

this threat can be mitigated efficiently. Hazardous Wastes were either remotely

identifiable or non-existent. Non-Hazardous Wastes included pipes, metal rods, and

other objects possibly left over from manufacturing or railway activities previously

conducted on-site.

Evaluating the site’s current infrastructural- elements included Power Lines,

Sewage, Drainage, and an Amtrak facility offered as a potential renewable energy

concept. These utilities could help facilitate the remediation process of the site and

possibly invite ‘green’ energy sources to be used. The CRA has already given thought

toward utilizing the Amtrak grid located on the site’s Eastern portion.

Similar Remediated Sites

Within the Phase 1 Document, other sites with similar backgrounds and located

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within .5 mile radius from the Crown Coach site, were listed under the Comprehensive

Environmental Response, Compensation, and Liability Information System ( CERCLIS ).

National Aerosols Product Comp. is located along E 14th Street, .4 miles North West

of the subject property. This site has undergone a preliminary site assessment and

designated as low priority. The sites groundwater runs along a cross gradient from

adjacent properties, not constituting a major concern or health hazard.

Another site in close proximity, is the Western Lead and Metal Co. along

E 11th St. and .46 miles from the Crown Coach facility. This site constitutes a high

priority level for lead-based contamination. In response, an extensive soil extraction

was implemented, with nearly 2,500 tons being excavated and treated offsite, with

4-inch asphalt caps being placed over the main lot. Based on medium-level soil risk,

handlement of lead remedial activities and the propertys’ location, it does not

pose any inherent risk factors to the Crown Coach site.

Findings and Conclusions

Collaborating with Camp Dresser and McKee (CDM) the CRA continues to

oversee the current remediation process. Although much of the shallow surface layers

have been excavated and purified through soil and vapor extraction, deeper depths

remain susceptible to the presence of Volatile Organic Compounds. Deep-layer gas

monitoring will be used periodically, to check for upward migration of VOC’s.

The site has many assuring factors to enhance its credibility. Historically, there is no

documentation of Herbicide or Pesticide Use on-site. The site lacks cultivation of

various trees , shrubs, bushes or weeds, indicating Herbicide usage would not have

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been likely. Also, the presence of Polychlorinated Biphenyls was inconspicuous or

non-existent, fostering overall security of human health. The sites’ water supply

does not appear to be in grave danger, and through filtration, purification may

be possible. According to the Phase 1 Environmental Site Assessment, the subject

property was entered into a voluntary cleanup program, and listed as a low –level

priority. After recently speaking with Project Manager, Dan Weissman, the

time estimate is roughly two years for remediation completion, at which point, post-

remediation monitoring will likely occur. Through care, precision, and scrutinized

monitoring, this site will eventually be deemed safe, environment –friendly and

properly recognized as another Brownfield success story. In accordance, the CRA

has contacted a possible developer, Genton, demonstrating an interest in the sight’s

future potential, which at the present- time, remains unlimited.

References

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Bressler, A. ( 2000 ). Brownfield Redevelopment: A Risk versus Reward Proposition International Risk Management Institute. Retrieved October 31, 2010. Available from: http://www.irmi.com/expert/articles/2000/hannah12.aspx

Brownfield Development. ( 2010 ). Property Funding and Commercial Financing in the U.K. Cited January 28, 2011. Available from: http://www.property-funding.co.uk/property-development-finance/brownfield-development/

Brownfields EPA Region III ( 2002). U.S. Environmental Protection Agency. July 2002. Cited January 26, 2011. Available from: http://www.epa.gov/reg3hwmd/bf-lr/success/PA-johnstown.pdf

Camp Dresser and McKee ( 2008). Phase 1 Environmental Site Assessment Report. April 3, 2008.

California Human Health Screening Levels in Evaluation of Contaminated Properties. California Environmental Protection Agency; January 2005. Cited January 11, 2011. Available from: http://www.calepa.ca.gov/brownfields/documents/2005/CHHSLsGuide.pdf

CHHSL ( 2005). Use of California Human Health Screening Levels in Evaluation of Contaminated Properties. January 2005.

Clay, Don R. Role of the Baseline Risk Assessment in Superfund Remedy Selection; Office of Solid Waste and Emergency Response; April 22, 1991. Cited January 12, 2011. Available from: http://www.epa.gov/oswer/riskassessment/pdf/baseline.pdf

Cummings, B. ( 2009). Redeveloping Brownfield Sites a Complicated Process. News Times. Cited January 29, 2011. Available from: http://www.newstimes.com/news/article/Redeveloping-brownfield-sites-a-complicated-4688.php

Dorsey, J. ( 2003 ). Brownfields and Greenfields: The Intersection of SustainableDevelopment and Environmental Stewardship. Retrieved October 31. Available from:http://www.stateinnovation.org/Research/Transportation,-Infrastructure,-Smart-Growth/Brownfield-Development/dorsey_2003.aspx

Environmental Protection Agency ( 2010). Engineering Controls on Brownfields Information Guide. November 2010. Cited February 3, 2011. Available from: http://www.epa.gov/brownfields/tools/ec_information_guide.pdf

Hirschhorn, Joel. ( 2010). Brownfield Projects to Improve Public Health. National Governors Association. Cited February 4, 2011. Available from: http://www.nga.org/cda/files/1102BROWNFIELDS.pdf

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Illinois Environmental Protection Agency. ( 2007.) Making Contaminated Property Safe. Cited January 30, 2011. Available from: http://www.epa.state.il.us/land/brownfields/cleanup/taco-brochure.html

Information Technology Sector. ( 2009). Information Sector Baseline Risk Assessment. August 2009. Cited February 3, 2011. Available from: http://www.dhs.gov/xlibrary/assets/nipp_it_baseline_risk_assessment.pdf

Kirkwood, N. “ Why is There So Little Residential Redevelopment of Brownfields? Framing Issues for Discussion.” Joint Center for Housing Studies Volume. 1 Issue 3 ( 2001 ) Page 2 Paragraph 1. Retrieved October 28. Available from: http://www.jchs.harvard.edu/publications/communitydevelopment/kirkwood_w01-3.pdf

LGEAN. ( 2010) Local Government Environmental Assistance Network: Brownfields/ Superfund. Cited February 2, 2011. Available from: http://www.lgean.org/p2/brownfields.htm

Meyer, Peter. ( 2000 ). Reclamation and Regeneration of Brownfields. U.S Development Administration. Cited February 1, 2011. Available from: http://www.eda.gov/PDF/meyer.pdf

Mississippi Department of Environmental Quality. Brownfield’s Program; February 22, 2002. Retrieved January 23, 2011. Available from:http://www.deq.state.ms.us/mdeq.nsf/pdf/GARD_brownfieldrisk/$File/Proced.pdf?OpenElemen t

Missouri Department of Natural Resources. (2010). Financial Tools for Brownfields Voluntary Cleanup Sites. May 2010. Cited February 2, 2011. http://www.dnr.mo.gov/pubs/pub2114.pdf

Obrien and Gere. (2010). Brownfields. Environmental Services; Syracuse, New York. Cited January 31, 2011. Available from: http://www.obg.com/resource-files/Brownfields.pdf

Office of Emergency and Remedial Response. U.S. Environmental Protection Agency; 1989. Cited January 13, 2011. Available from: http://www.epa.gov/superfund/partners/osrti/index.htm

Office of Solid Waste and Emergency Response. ( 2010 ). U.S Environmental Protection Agency. Cited January 30, 2011. Available from: http://costperformance.org/pdf/DSCR_Richmond.pdf

Paull, Evans. ( 2008 ). The Environmental and Economic Impacts Brownfield Redevelopment. Northeast Midwest Institute; July 2008. Cited February 2, 2011. Available from: http://www.developingspokane.org/docs/Target_Areas/Brownfields/EnvironEconImpactsBFRedev.pdf

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Reolt and Grayson. Risk Based Corrective Action: Lessons for Brownfields from the Illinois Rulemaking. Air and Waste Management Association; June 1998. Cited January 12, 2011. Available from: http://www.jenner.com/files/tbl_s20Publications%5CRelatedDocumentsPDFs1252%5C230%5CRisk-Based%20Corrective%20Action.PDF

Sawyers, Doug. ( 2008). Brownfields Redevelopment. Malcolm Pirnie. Cited February 1, 2011. Available from: http://www.pirnie.com/index.php?Itemid=1059&id=513&option=com_content&task=view

Site Remediation. Remediating Contaminated Land; 2011. Cited January 12, 2011. Available from: http://www.siteremediation.com.au/bioremediation/contaminated-land-%E2%80%93-the-potential-hazards/

Subang, Theresa- Repasso. ( 2008 ). Putting Numbers on the Risk Factors for Contaminated Sites. Golder Associates. Cited January 28, 2011. Available from: http://www.golder.com/gh/en/modules.php?name=Publication&sp_id=88&page_id=212&service_id=56

Thalheimer, Andrew H. ( 2009 ). Dillon Consulting. October 27, 2009. Cited February 3, 2001. Available from: http://www.esans.ca/pdf/NSAR-ESANS_Brownfields%20Presentation_27Oct09.pdf

Weissman, Dan. (2010 ). Environment LA. Cited February 23, 2011. Available from: http://www.ci.la.ca.us/ead/brownfields/crowncoach.htm

Appendix A- Soil and Groundwater Supply

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Figure 1- A focused model illustrating soil and groundwater concerns in contaminated properties.

Appendix B- Crown Coach Site Aerial

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Figure 2- An aerial view of the Crown Coach Site facility located near East Washington Blvd.

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