Systematic Planning and Field Decision Making for

Brownfields AssessmentsA Presentation to:

Western Brownfields WorkshopSeptember 29, 2016

byBill Rees, VCP/Brownfields Section ManagerUtah Department of Environmental Quality

Site CharacterizationSite characterization should be conducted to evaluate a site. Plan the work, develop a Sampling and Analysis Plan and Quality Assurance Project Plan prior to field activities.

Understand both the current use and site history.

Recognize that many process areas and possible discharges often occur inside buildings or on concrete slabs used for storage. Sampling should be conducted in these areas.

It is often difficult to sample under a concrete slab or inside a building due to space constraints, access issues or slab thickness.

Impacts Under a SlabWhy is this important - foundations and subsurface infrastructure features (such as piping, oil/water separators) can settle and cracks appear. Possible conduit to the subsurface.

In addition, there can be unknowns, such as even older slabs, foundations, or even sumps, from previous property uses.

Clean samples outside the building or slab do not necessarily demonstrate the area under the building or slab is clean. This can generate uncertainty, especially when an initial assessment, such as a phase II, has not evaluated the area in question.

This uncertainty should be factored into future sampling and site redevelopment/cleanup planning so unknowns encountered during construction do not cause a delay in the project.

Floor Drains

Storage on Concrete

Work Bays

Spills/Poor Housekeeping

Old Structures

Unknown Drainage Box

Sumps

Former Oil/Water Separator

Potential Path ForwardPrepare for the unexpected. Develop a contingency plan so there is a strategy to address unexpected issues.

Communicate uncertainties to the entire team often. Do not assume the construction contractor will address an unexpected environmental issue, if encountered.

Ensure an Environmental Professional is on-site as concrete slabs are removed/buildings demolished.

Characterization can also be conducted during cleanup efforts. Be flexible, stay in contact with the project team.

Site conceptual model updated accordingly to help with decision making.

Ogden Business ExchangeSite was a former stockyard and later used for storage and other uses that created a tremendous amount of uncertainty.

Initial assessment conducted as part of an EPA Community-Wide Assessment grant.

Property is approximately 50-acres and areas under concrete and buildings were not sampled initially. Numerous sumps identified inside the buildings.

Site entered the Voluntary Cleanup Program and cleanup was phased.

To address uncertainty, areas under concrete and buildings were addressed in accordance with the Remedial Action Plan (RAP) and corresponding contingency plan accepted for each phase of project.

Ogden Business ExchangeField screening, sampling procedures, and cleanup levels established in each RAP. Environmental Professional on-site.

Characterization/cleanup conducted, as buildings and concrete removed. Grab samples biased toward areas of possible impact and decisions drew on previous assessment data, field observations and discussions with UDEQ.

Over 260 sumps and 17 drums removed, approximately 500 tons of contaminated soil disposed off-site, and thousands of tons of concrete recycled for base under roads.

Confirmation samples collected as material removed to demonstrate cleanup goals achieved.

Site has now been cleaned up and redevelopment is proceeding on phase I, which is a large bicycle manufacturing facility.

Ogden Business Exchange

Ogden Business Exchange

Ogden Business Exchange

Ogden Business Exchange

Ogden Business Exchange

Ogden Business Exchange

SummaryContamination can be present under buildings and concrete slabs. It can often be difficult to sample under a building.

Develop a contingency plan so unknowns can be addressed.

Communicate uncertainties to the entire team often. Do not assume the construction contractor will address an unexpected environmental issue, if encountered.

Prudent to have an Environmental Professional on-site as concrete slabs/buildings removed. Collect samples.

In some instances, characterization efforts can be included in a Remedial Action Plan. Need some knowledge of the site.