Environmental Assessment and Cleanup

1. Environmental Assessment and Cleanup • Phase I is complete and Recognized Environmental Conditions are identified –WHAT HAPPENS NEXT?!?!?!?! • PHASE II

2. The primary objectives of conducting a Phase II ESA are to evaluate the recognized environmental conditions identified in the Phase I ESA or transaction screen process for the purpose of providing sufficient information regarding the nature and extent of contamination to assist in making informed business decisions about the property; and where applicable, providing the level of knowledge necessary to satisfy the innocent purchaser defense under CERCLA. Phase II

3. Environmental Assessment and Cleanup • Consultant prepares a detailed workplan based on all identified RECs • If program is EPA or State-funded, the workplan and Quality Assurance Project Plan (QAPP) must be approved by regulators • If not funded by EPA or State, collaboration with State on workplan elements is crucial • Initiate conceptual scope of work (all stakeholders)

4. Environmental Assessment and Cleanup Environmental Media Sampling Techniques • Soil • Coring (geologic characterization) • Field screening • Analytical soil sampling • Groundwater • Monitoring wells • Profiling • Drinking water wells • Surface Water and Sediments

5. Environmental Assessment and Cleanup Environmental Media Sampling Techniques (cont) • Soil Gas • Vapor points (temporary or permanently installed) • Beneath building slab or outside of buildings • Indoor Air • Field screening or laboratory analysis • Building Materials • Releases to concrete; lead paint; asbestos; mold

6. SOIL & GROUNDWATER

7. Well Construction and Soil Logs

8. SOIL CORE Contamination

9. SURFACE WATER

10. SOIL GAS

11. BUILDING MATERIALS

12. Environmental Assessment and Cleanup Common Contaminants at Brownfield Sites • Petroleum in soils/groundwater/Indoor Air • Leaking fuel storage or delivery systems, spills during delivery or use, intentional discharges • Releases from current or former underground storage tanks (USTs) or above ground storage tanks (ASTs) • Light Non Aqueous Phase Liquid (LNAPL) = FLOAT on groundwater

13. USTs

14. Environmental Assessment and Cleanup Common Contaminants at Brownfield Sites • Chlorinated solvents • Commonly used in drycleaning (PCE) and degreasing (PCE & TCE) • Tend to be odorless/colorless, therefore were widely dumped onto ground surfaces for disposal or into floor drain systems • Small amounts can cause widespread groundwater, soil, soil vapor and indoor air contamination • Dense Non Aqueous Phase Liquid (DNAPL) = SINK in groundwater

15. Environmental Assessment and Cleanup Common Contaminants at Brownfield Sites • Metals • Present in soil, groundwater and sediments • May be from used oil releases or leaks, may be result of manufacturing processes and waste disposal practices, may result from deposition of burned coal • Old Creameries (mercury) • May be naturally occurring in soil and groundwater or from upstream discharge – Collect BACKGROUND samples

16. Environmental Assessment and Cleanup Common Contaminants at Brownfield Sites • Polynuclear aromatic hydrocarbons (PAHs) • Result from incomplete combustion of carbon(i.e., coal, gasoline, wood) • Common at most industrialized or urban sites • Tend to sorb to soils

17. Environmental Assessment and Cleanup Common Contaminants at Brownfield Sites • Polychlorinated biphenyls (PCBs) • Used widely from the 1950’s through late-1970’s in transformers, cutting oils, lubricants, insulators, building caulk, mastic, roofing tiles,inks • Tend to adsorb to soil but have the ability to migrate in groundwater • Regulated by TSCA

18. Environmental Assessment and Cleanup Common Contaminants at Brownfield Sites • Asbestos • In building materials as insulation, used as brake insulation, may be in soils, located along rail lines that were transporting asbestos, • Shared regulation based on source of asbestos between ANR and DOH • Coal Tar • Byproduct of coal gasification (early 1900’s process) • Some fractions SINK and some FLOAT • Dioxins • Byproduct of burning/heating chlorine containing products, especially from the bleaching process used in pulp and paper mills

19. Environmental Assessment and Cleanup Phase II Results • Results of Phase II are compared to relevant screening values or Standards; • Water Supply Rule (10 V.S.A. Chapter 48, Groundwater Protection; 10 V.S.A. Chapter 56, Public Water Supply; 10 V.S.A. Chapter 61, Water and Waste Water Permits; and 18 V.S.A. §1218) • Water Quality Standards (10 V.S.A. Chapter 47) • Soil Screening Values (Regional Screening Values) • Indoor Air Screening Values (HAAS and DOH Background) • Sediment Quality Screening Values

20. Vermont Department of Environmental Conservation Regulatory Tools related to site work Liability (10V.S.A. § 6615) Corrective Action Procedures (10V.S.A. § 6615b) Hazardous Waste Management Regulations (3 V.S.A. § 2853(5) and 10 V.S.A. chapter 159) Solid Waste Management Rule (10 V.S.A. Chapter 159) Water Supply Rule (10 V.S.A. Chapter 48, Groundwater Protection; 10 V.S.A. Chapter 56, Public Water Supply; 10 V.S.A. Chapter 61, Water and Waste Water Permits; and 18 V.S.A. §1218) Water Quality Standards (10 V.S.A. Chapter 47)

21. Vermont Department of Environmental Conservation Guidance Documents related to site work Site Investigation Procedures Corrective Action Guidance Underground Storage Tank Closure and Site Assessment Requirements Agency Guidelines for Petroleum Contaminated Soil and Debris New Investigation and Remediation of Contaminated Properties Document – Public Review Period SOON