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Site Remediation Program (SRP)

July 6th, 2016

Phase I Environmental Site Assessment Spotlight: HREC

One of the major changes to the Phase I Environmental Site Assessment ASTM standard (E1527-13) is the enhanced definition of a REC (Recognized Environmental Condition).  ASTM added the term CREC (Controlled REC), in addition to the previously defined REC and HREC (Historical REC).

An HREC property is one that was previously deemed to have potential or actual contamination, but has since undergone remediation that meets current standards of cleanup.  An HREC site is not subject to any land use restrictions.

Case Study

Gabriel was conducting a Phase I in Chicago of a former machine IEPA-logoshop. The site was identified on the regulatory database search as an SRP (Site Remediation Program) site.  SRP is a voluntary cleanup program run by the Illinois EPA.  The IEPA is authorized to issue No Further Remediation (NFR) letters to the Remedial Applicants who have successfully demonstrated, through proper investigation and possible remedial action, that environmental conditions at their remediation site do not present a significant risk to human health or the environment.

This site received an NFR letter with no use restrictions or engineered barriers required.  Since the site clean-up, the property has been unoccupied and no longer has any hazardous substances on the premises.  Therefore, the previous contamination caused by past operations of the occupant represent an HREC for the site.

If you have questions about how Gabriel determines if an environmental condition is an HREC, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman{at}gabenv.com.

November 4th, 2015

Contaminated site becomes new helicopter airport in Chicago

On the near west side of Chicago, an abandoned contaminated property has recently been cleaned up and put into progressive reuse as Vertiport Chicago, a helicopter airport.  Previous uses of the svertiport chicagoite included a garage (with two USTs), dry cleaner, and transportation company (with two USTs). The property had been vacant since at least 2005 and was overgrown with weeds.  Illegal dumping had occurred on the northeastern and eastern parts of the land.  Extensive subsurface investigation work found that the site was contaminated with lead, arsenic, and PNAs (Polynuclear Aromatic Hydrocarbons).

The airport developer worked with their environmental consultant and the Illinois EPA to determine a cost-effective solution to this contamination.  Instead of requiring the expensive removal of this contaminated soil, IEPA agreed to an industrial/commercial use restriction and a groundwater use restriction.  In addition, the property owner must maintain engineered barriers across the site including a concrete building foundation, a concrete parking lot, concrete vertiport, and alternative engineered barriers with new clean topsoil in the landscaped areas and the detention basin.

Vertiport Chicago has been operating since May 2015.  Its clients include emergency medical services helicopters for the nearby medical district who are able to land without landing fees, as well as more profitable clients such as DHL and corporate CEOs who ferry in documents and executive staff from O’Hare to downtown in a matter of minutes – no matter what the traffic is on the Kennedy Expressway.

www.vertiportchicago.com

May 19th, 2015

It’s TACO Tuesday!

All cleanup programs in the state of Illinois are based on TACO limits, but not everyone knows exactly what TACO IEPA-logomeans – or why it makes cleaning up your property easier.

TACO is an acronym for “Tiered Approach to Corrective Action Objectives.”  Prior to the implementation of TACO standards in the mid-1990s, the Illinois EPA (IEPA) took a “one size fits all” approach to cleaning up contaminated properties.  All sites, regardless of their location, use, contaminants, etc., had to be cleaned up to the same standards.

This regulatory climate changed as cleanup programs across the U.S. continued to mature.  Environmental agencies realized that cleaning up an industrial property that was only going to be used for a parking lot was a lot different than cleaning up a former gas station to become apartments.  Remediation objectives became risk-based and site-specific.

Today, TACO takes into account three main components to determine environmental risk:

  1. Contaminant(s) – ie: chemicals
  2. Exposure route(s) – eg: air, drinking water, etc.
  3. Receptor(s) – eg: people, plants, or animals

Through both the Site Remediation Program (SRP) and Leaking Underground Storage Tank (LUST) program, environmental consultants such as Gabriel conduct a site investigation consisting of soil, groundwater and/or vapor testing.  Once these results are analyzed for each of the above components, the environmental consultant can work with the IEPA project managers to determine the best way to clean up the property.  The three most common risk management tools are:

  1. Active remediation – eg: contaminated soil removal; bioremediation; chemical remediation; etc.
  2. Engineered barriers – eg: asphalt parking lot, concrete floor, building control technologies (BCTs), etc.
  3. Institutional controls – eg: drinking water restriction, commercial/industrial use restriction, etc.

Once a property owner has satisfied the applicable program requirements and documented that the contaminants had either been reduced below TACO standards or controlled through engineered barriers or institutional controls, the IEPA will issue a No Further Remediation (NFR) Letter.

These TACO standards mean that you’ll often be able to clean up your property with less expense and hassle, which promotes progressive reuse of contaminated property.

If you have more questions about how the TACO regulations work, contact John Polich, P.E. at jpolich[at]gabenv.com or 773-486-2123.

March 26th, 2015

When to conduct vapor sampling

When working to get a No Further Remediation (NFR) letter through the Illinois EPA’s Leaking Underground Storage Tank (LUST) program, an investigation of three pathways of concern must be conducted: soil, groundwater, and vapor.  IEPA has required soil and groundwater evaluations for over 20 years, but they only recently started requiring vapor intrusion assessments.

Because vapor assessments are not required for all LUST Incidents, IEPA has published a flowchart to help determine when soil gas sampling is necessary:

lust-flowchart

Gabriel’s Project Managers work with the Illinois EPA’s LUST division to determine the appropriate sampling for each specific site, including if this indoor inhalation exposure route must be investigated.

The Site Remediation Program (SRP) also requires the investigation of vapor in certain circumstances, but because the contaminants of concern vary greatly within the SRP program, they don’t have a similar flowchart established.  Each site is addressed on a case-by-case basis.

If you have any questions about vapor assessments or a specific site, contact John Polich at 773-486-2123 or jpolich[at]gabenv.com.

November 19th, 2014

Why are dry cleaners often listed as a REC?

Dry cleaning machine from the 1960s

Dry cleaning machine from the 1960s

When conducting a Phase I Environmental Site Assessment, Gabriel’s Environmental Professionals (EP) know that when we find evidence of a current or past dry cleaner on site, we need to pay extra attention.

Dry cleaners raise a red flag for us due to the chemicals they use to clean the clothing (chlorinated and/or petroleum solvents) and historic poor housekeeping practices.  It was not uncommon for used solvents to be dumped out the back door before there were stricter environmental regulations.  Chemicals were often spilled around the machines, and rarely were the shops equipped with spill containment equipment as they are now required to have.

Contamination caused by dry cleaners can impact soil and groundwater, as well as cause vapor migration and intrusion issues.  Studies have shown that approximately 75% of all dry cleaners have some level of contamination.

As a result of these factors, EPs often list the former or current presence of a dry cleaner as a Recognized Environmental Condition (REC) in a Phase I.  While not every dry cleaner has serious contamination, it is generally prudent to investigate areas both inside and in the back of the building.

“‘Taken to the cleaners’ can have a particularly disturbing connotation for owners, sellers, and lessors of real estate,” says environmental attorney Lawrence Schnapf.

To learn more about the key risks posted by dry cleaners and strategies for managing these risks, download “Dry Cleaners: the Environmental Scourge of Commercial Real Property,” from Mr. Schnapf’s website.

If you have specific questions about dry cleaning contamination for a property you own or are considering purchasing, contact John Polich at jpolich[at]gabenv.com or 773-486-2123.

August 6th, 2014

What the heck is a “CREC”?

When the new E1527-13 Phase I Environmental Site Assessment standard was released in late 2013, ASTM included a new term: CREC. ASTMlogo

A CREC is a Controlled Recognized Environmental Condition, a subset of the traditional REC. CREC was developed to address the controlled presence of potential hazardous substances or petroleum products, as defined by the local environmental regulatory agency.

CREC examples:

  • Site A had a Leaking Underground Storage Tank (LUST) incident which was cleaned up to the satisfaction of the IEPA, with a land use restriction (eg: could only be used for commercial-industrial use). This would be considered a CREC since there are still hazardous substances and/or petroleum products present on the property, however the property has  been deemed safe for commercial or industrial use (though not residential use).
  • Site B was a former industrial operation that went through the Site Remediation Program (SRP) cleanup process. As part of the No Further Remediation (NFR) letter, the contaminated part of the property must remain capped by an engineered barrier. This would be considered a CREC since there are still hazardous substances present on the property, however they have been controlled by the engineered barrier.

Though the CREC is considered a REC, most CRECs would not be a major concern for a buyer or their lender. This language was developed to clarify situations such as these in order to give purchasers and lenders greater peace of mind about these sites.

June 4th, 2014

Kerry Wood Cubs Field Gets $2 Million Clean-up Grant

After Kerry Wood retired from the Chicago Cubs, he decided to open a state-of-the-art ballpark for Chicago Public League athletes and Chicago residents through his Wood Family Foundation. “Kerry Wood Cubs Field will be a special place for our community for years to come. Having been drafted out of high school, I know the importance of having a place to play. Keeping baseball alive in our city is something that is close to my heart. I’m excited for our kids to play under the lights and start their own dreams. Anything is possible,” Wood said.

Kerry Wood Field groundbreaking

Groundbreaking ceremony (Photography by Steve Green, Wood Family Foundation)

Unfortunately, the construction of the ballpark was halted abruptly in 2013 when contamination was discovered due to the site’s former use as a brickyard.  After nearly a year of environmental testing and liaison with the Illinois EPA (IEPA), the project is back on track thanks to Governor Quinn agreeing to fund $2 million in clean-up costs.

“This project is a great example of the work we do every day to improve Illinois communities by cleaning up contaminated sites to benefit residents and young people,” IEPA Director Lisa Bonnett said.

Kerry Wood Cubs Field will be built on a property located at 3457 N. Rockwell St. The state’s investment, through the IEPA, will fund the removal of contaminated soil, followed by site grading and leveling.
The Chicago Cubs, Chicago Cubs Charities, Wood Family Foundation, City of Chicago, Chicago Park District, Chicago Public Schools and Turner Construction will together contribute an additional $5 million to complete the stadium project.  When completed, Kerry Wood Cubs Field will have a capacity of 1,100 spectators.  It will be owned and operated by the Chicago Park District and be used by Chicago public high school teams, recreational leagues, and the general public.
Artist rendering of Kerry Wood Cubs Field

Artist rendering of Kerry Wood Cubs Field