A large manufacturer had outgrown its current facility and had interest in expanding to a larger industrial building to support growth of the company. APPLIED ENVIRONMENTAL was chosen to assist in performing environmental due diligence for the new facility.
The Phase I ESA identified several recognized environmental conditions. The subject property was an open leaking underground storage tank (LUST) site, and an active Part 201 site. In addition, historical operations resulted in deposition of airborne lead from exhaust vents outside the building. A make-shift paint booth with prominent floor stains was observed during the site reconnaissance. Additionally, a historical township dump was located southwest of the subject property.
Through dialogue with MDEQ project managers, it was identified that the subject property’s open LUST status had been closed. According to the MDEQ project manager, existing contaminants on the property were being addressed under Part 201.
A Phase II ESA was conducted, including both soil and groundwater sampling, to address the RECs identified in the Phase I ESA, and also to evaluate potential exposure pathways related to the chlorinated solvent release resulting in the Part 201 status of the subject property.
Soil samples collected from borings advanced inside the building near the historical release of the chlorinated solvents had concentrations of tetrachloroethylene which exceeded the Residential and Commercial I – Part 201 Generic Cleanup Criteria & Screening Levels, Drinking Water Protection Criteria, Groundwater Surface Water Interface Protection Criteria, Soil Volatilization to Indoor Air Criteria, and the Soil Saturation Concentration Screening Level.
A second subsurface ESA, which included soil gas sampling, was conducted to define the horizontal and vertical extent of the soil impacted above the Soil Volatilization to Indoor Air Criteria and the Soil Saturation Concentration Screening Level. Laboratory analysis indicated a very high level of tetrachloroethylene in the soil. The delineation effort was successful in defining the horizontal and vertical extent of chlorinated solvent impact which exceeded the Soil Volatilization to Indoor Air Inhalation Criteria and the Soil Saturation Concentration Screening Level.
Approximately 150 cubic yards of chlorinated solvent impacted soil which exceeded the Soil Volatilization to Indoor Air Inhalation Criteria and the Soil Saturation Concentration Screening Level were excavated from beneath the subject building floor. Soil verification sampling confirmed the remediation objective, and the client was able to provide a safe working environment for employees and satisfy Due Care responsibilities.
The identification of contaminants remaining on the site following the soil removal activities determined that the site met the legal definition of a “facility”. Subsequently, a Category “S” BEA and Due Care Plan were prepared and disclosed to the MDEQ. A spatial separation strategy was employed to distinguish between existing PNA contamination and a new release.
Despite the numerous concerns identified at the property, APPLIED ENVIRONMENTAL worked with the legal council, banker and MDEQ departments to achieve the goals of the client and limit their liability.