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Chapter 7 Special Mgmt. Areas Brownfields

Chapter 7 Special Mgmt. Areas Brownfields. Domenic Rocco, P.E., CPESC PA DEP – SERO Chief, Permits and Technical Services PA SWM BMP Manual Pilot Training Split Rock, Carbon County. Agenda:. Brownfields Lingo Misconceptions Background What’s changed? Permitting for Brownfield Sites

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Chapter 7 Special Mgmt. Areas Brownfields

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  1. Chapter 7Special Mgmt. Areas Brownfields Domenic Rocco, P.E., CPESC PA DEP – SERO Chief, Permits and Technical Services PA SWM BMP Manual Pilot Training Split Rock, Carbon County

  2. Agenda: • Brownfields Lingo • Misconceptions • Background • What’s changed? • Permitting for Brownfield Sites • Specific Conflicts • E&S • PCSWM • Example Site • Recommendations • Next Steps

  3. Brownfield Lingo & Misconceptions: Brownfield are real property, the expansion, redevelopment , or reuse of which may be complicated by the presence or potential presence of hazardous substances, pollutants or contaminants. (Source: EPA) • Brownfield - • Act 2 - The Land Recycling and Environmental Remediation Standards Act of 1995 • Act 2 is a voluntary program. • NIR – Notice of Intent to Remediate • A brownfield cleanup does not mean the site will be “clean” afterwards. • May involve a “cap” to isolate contamination. • Not all Clean-ups go through Act 2*. • Ex. Superfund • Not all sites qualify for Act 2*. • Not all brownfield sites that go through Act 2 require a physical cleanup. • no earth disturbance (for cleanup phase) • “Release of Liability” Protection • “Soil Mgmt Plan” does not cover E&S

  4. Brownfield Lingo & Misconceptions: • Brownfield - • Act 2 - The Land Recycling and Environmental Remediation Standards Act of 1995 • Act 2 is a voluntary program. • NIR – Notice of Intent to Remediate • A brownfield cleanup does not mean the site will be “clean” afterwards. • May involve a “cap” to isolate contamination. • Not all Clean-ups go through Act 2*. • Ex. Superfund • Not all sites qualify for Act 2*. • Not all brownfield sites that go through Act 2 require a physical cleanup. • no earth disturbance (for cleanup phase) • “Release of Liability” Protection • “Soil Mgmt Plan” does not cover E&S

  5. Background: • Brownfield projects have become a significant portion of the NPDES workload. (SERO > 40%)* • Brownfields are common in urbanized areas and along old industrial corridors* • rivers, canals and railroads. • Pre – 2005: Permits not needed for brownfield cleanups under Act 2. • Many problems encountered with clean up w/ improper E&S Controls • Citizen complaints • Finger pointing • Full Circle: Different interpretation of existing rules.

  6. Both need NPDES permits PAG-2 Indiv. Permit What’s changed? • Brownfield sites under Act 2 now require NPDES Permits • Clean up • Redevelopment • In many cases, Individual Permits required. • Potential to discharge chemicals, solvents or other hazardous waste. • Levels of Contamination: • Residential Statewide Health Standard • Non-Residential Statewide HS • Background Standard (GW) • Site Specific Standard • Act 2 NIR Letters now reflect these changes. • Cleanups under Superfund are still exempt from NPDES Permits (permit equiv) • PA SWM BMP Manual has section on Brownfields - (Section 7.2) • Future: Expect to see new BMPs or changes to existing BMPs for Brownfield Sites.*

  7. Redevelop. Clean-up Communication ? Consultant Contractor Consultant Contractor Permitting for Brownfield Sites: Brownfields Lead?

  8. Permit Reviews: • Require a great deal of coordination • Internal Coordination: • Brownfields & Cleanups are not just Act 2 • Act 2 – ECP/Special Projects • Superfund – ECP/HSCA • Ag Orchard – Waste Management • “Addressing Pesticide Contamination on Agricultural Land Proposed for Development” • Other clean up – Waste Management • External Coordination: • Cleanup Consultant/Contractor • Redevelopment Consultant/Contractor • Owner/Applicant

  9. Contaminant Sources Transport Mechanisms Soil Groundwater Surface Water Exposure Pathways Receptors Human Ecological Potential for Sediment Mobility Site Constraints:Brownfields Site Characterization • Remedial Decision: • Monitored Natural Attenuation • In-Situ Capping • Dredging & Excavation (Soil) • Pump & Treat (GW)

  10. Risk Assessment? • Risk-based approach • E&S Program deals with both direct pollution and potential pollution • Applicant needs to convince Plan Reviewer(s) that the risk associated with a contaminated discharge has been abated to a level protective of human health and/or the environment.

  11. Application Form Provide a detailed written description of the project. If phases, describe amount of disturbance in first phase and the planned disturbance in each subsequent phase. 1 Remediation 50 10 04/2007 06/2007 2 Redevelopment 50 40 07/2007 07/2009 Details - Dominant land use for the 5 years preceding the planned project. Details – land uses for the past 50 years, or longer if known. Heavy Metals (Lead) 1.2mg/Kg Foundation Soil 07/03 (12) 8/04 (2) VOC’s (Benzene) See Attached UST Groundwater See Attached

  12. E&S Conflicts: • Pollutants of Concern? • VOC’s (Benzene), Heavy Metals (Lead, Arsenic) • Application asks for potential pollutants • Section rarely completed correctly.* • How to disseminate info once received? • What contaminant levels pose a concern? • How are contaminants transported? • Suspended or in-solution? • Can conventional E&S BMPs do the job? • What additional BMPs are needed? • Information needs to be presented in “plain language”. • Conflicts with Redevelopment activities: • Basin/Trap/Swale • Building foundation • Utility lines!!

  13. Typical E&S Mechanisms • GOAL – to prevent a discharge from a contaminated area. • Avoid/Minimize/Protect (Erosion Control) • Settling (Sedimentation Control) • Filtration (Sedimentation Control)

  14. Non-Structural Minimize Disturbance Seasonal Restriction Phasing Construction Sequence Structural (Stabilization) Temporary Mats/Blankets/Linings Mulching Vegetation Permanent Vegetation Imperviousness Erosion Control

  15. Settling Silt Fence Compost Berms* Traps Basins Filtration Compost “Filter” Berms* Rock Filters/Inlet protection Filter socks* Filter bags (pumping) Flocculants (PAM)* Isolate, Collect and Dispose Berms Sumps Small areas - $$$ Sedimentation Control Source: EPA Source: Terra Tubes

  16. Compost Blanket Compost Berms Compost Socks

  17. THE USE OF COMPOST AS AN EROSION AND SEDIMENT CONTROL BEST MANAGEMENT PRACTICE • MATERIAL • Compost shall be a well decomposed, weed free organic matter derived from agricultural, food, and yard or wood/bark organic matter source. The compost must be aerobically composted at a Pennsylvania Department of Environmental Protection (DEP), Bureau of Waste Management permitted site. The compost shall possess no objectionable odors and will be reasonably free (<1% by dry weight) of man-made foreign matter. The compost product shall not resemble the raw material from which it was derived. • The physical parameters of the compost should be: • pH 5.5 – 8.0 • Moisture Content 35% - 55% • Particle Size 98% pass through 1” screen • Soluble Salt Concentration 5.0 dS Maximum • COMPOST FOR EROSION CONTROL • Compost shall be uniformly applied at a rate of 270 – 540 cubic yards per acre (2 to 4 inch layer) to slopes of up to 2:1. Slopes with problem soils and more runoff will require greater application rates. On highly unstable soils, use compost in conjunction with appropriate structural measures. Spread the compost uniformly, then track (compact) the compost layer using a bulldozer or other appropriate equipment. Alternatively, apply compost using a pneumatic (blower) unit. Project compost directly at soil, thereby preventing water from moving between the soil-compost interface. Apply compost layer approximately 3 feet over the top of the slope or overlap it into existing vegetation. Follow by seeding or ornamental planting. Where planning immediate grass, wildflower, or legume seeding or ornamental planting, use only a well composted product that contains no substances toxic to plants. Very coarse composts should be avoided if the slope is to be landscaped or seeded, as it will make planting and crop establishment more difficult. Composts containing fibrous particles that range in size produce a more stable mat. • COMPOST FILTER BERMS • Compost may also be used to construct a filter berm for sediment control. Composts denser in nature and containing particles that range in size produce the most stable berms. Do not use compost filter berms in channels. Construct a 1 ½ to 2 foot high by 2.5 to 3 foot wide berm of compost parallel to the base of the slope or other affected area. For maximum water filtration ability, construct a 1 ½ to 2 foot high trapezoidal berm which is 3 feet wide at the top and 4 feet wide at the base. Pg. 136a in PA E&S Manual

  18. Other E&S measures Site Specific blends Technology from Landfills • Anionic Polyacrylamide Flocculants (PAM) • Alternate Daily Cover products. • Posi-shell • Large stockpiles

  19. PCSWM Conflicts: • What areas are suitable for infiltration? • Area of historic fill and industrial use • Train yard • Incinerator • Manufacturing facility • Where are the known “hot spots”? • Usually doesn’t cover entire site. • What is the contingency plan in the event unexpected contamination is uncovered? • Avoid Redevelopment/Cleanup Overlap

  20. ? Typical PCSWM Mechanisms BMPs: • Structural • Non Structural Function: • Volume Control • Water Quality • Channel Protection • Flood Control

  21. Which PCSWM BMPs? • Non Structural • Reducing ED/Imperv. • Disconnecting Imperv. • “Greening” things up • Structural • Water Quality • Bioretention • Utilize Parking Islands • WQ Inserts/Inlets • Green Roofs • Capture & Reuse • Cisterns • Restoration BMPs • Riparian, Landscape, Soil Amend, Floodplain • Infiltration still viable outside of hot areas.

  22. HOT SPOTS Heavy Metals VOCs Typically, no additional runoff from clean up so no PCSWM needed until redevelopment Example Site: E&S Control Plan Non-Structural • Supplemental Notes • Site Preparation • General Notes • Maintenance • Construction Sequence EXCERPTS: DURING EXPOSURE, TEMPORARY DIVERSION BERMS WILL BE INSTALLED TO DIVERT WATER AROUND IMPACTED AREA. ANY QUESTIONABLE MATERIAL ENCOUNTERED WILL BE STAGED ON PLASTIC SHEETS WITH FILTER BERMS…. FREE WATER IN IMPACTED AREAS WILL BE COLLECTED FOR DISPOSAL. SPECIAL CARE WILL BE TAKEN TO MINIMIZE EXPOSURE DURING DEMOLITION PHASE TO AVOID DISCHARGES OF CONTAMINANTS… ENVIRONMENTAL MONITOR SHALL TEST UNDERLYING SOILS TO CONFIRM ATTAINMENT OF STATEWIDE RESIDENTIAL H.S. • PCSWM Plan • Non-Structural • Avoid Infiltration in vicinity of hot spots. • Sequence/Notes • In some cases, follow normal protocols.

  23. Example Site: E&S BMPs • Compared with Silt Fence: • Better performance* • Less maintenance headaches • Some can be left in place

  24. Recommendations: • Complete Application: • Potential Pollutants– Table A.8 • Identify Hot Spots on Site Plans Good Site Characterization is critical • Permit Coordination - Section G • ECP/Waste Reviewers & any tracking number. • Full disclosure • What’s on the site? • How are all “concerns” being addressed • Unless “hot spots” are out of the proposed development area, redevelopment should wait until clean up is completed. • Thinking out of the box: • BMP Selection – beyond the “typical” • Plan Notes and Construction Sequencing are major tools.

  25. Next Steps: • Update the application and instructions. • Public Education • Create Fact Sheets • Outreach • Possibly create a new GP for “low risk” brownfield clean-ups. • Update Guidance • E&S Pollution Control Manual • SWM BMP Manual • Share info and learn from each other. - FIN -

  26. Questions?

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