Brownfields assessment services at various sites including Puerto Rico

Nobis, with subcontractor support from GES, is currently performing Phase I and Phase II Environmental Site Assessments (ESAs) on behalf of the United States Environmental Protection Agency (USEPA) in support the TBA Program. This multi-site task order (TO) for Region 2 includes programmatic and site-specific activities to perform Phase I and Phase II assessments throughout New Jersey, New York, Puerto Rico, and the US Virgin Islands. Monthly reporting is completed for EPA and quarterly programmatic meetings are held with EPA to provide routine updates on the status of site activities. Planning documents prepared for this TO include contract-level deliverables (Generic Quality Assurance Project Plan [QAPP], Data Management Plan, and Health and Safety Plan [HASP]) supported by site-specific addendums (i.e., QAPPA and HASPAs) to tailor information and field investigation activities for each individual TBA site. Nobis is also providing Assessment, Cleanup, and Redevelopment Exchange System (ACRES) maintenance support for EPA.

Systematic planning meetings are performed with EPA and site-specific project stakeholders to kick off each TBA and to discuss results as they are received. Each kickoff meeting is structured according to a client-approved agenda that ensures the entire project teams know the history of each site, goals of each assessment, and objectives for Brownfields recipients pursuing reuse/redevelopment of each site.

All Phase I ESA activities are completed in conformance with the American Society for Testing and Materials (ASTM) Designation: E1527-21, and in compliance with the All Appropriate Inquiries (AAI) Final Rule at 40 Code of Federal Regulations Part 312. Phase I assessment activities include: obtainment and review of EDR® reports; site reconnaissance and compilation of a detailed photographic log; state and municipal file reviews as needed based on Freedom of Information Act requests initiated by the project team; interviews with site owners, users, and other representatives; and comprehensive reporting of findings in accordance with the ATSM standard and the AAI.
Phase II activities are being performed to evaluate Phase I RECs, including collection of soil samples and installation of monitoring wells via soil borings advanced with direct-push technology drill rigs, test pitting investigations, groundwater sampling, soil vapor sampling, hazardous building material surveys, and geophysical investigations to investigate subsurface features (e.g., potential tanks, drains, pipe chases, utility structures, etc.,). Nobis/GES have coordinated property access, filed appropriate 811 notification for utility clearances, and applicable permits with DNER for monitoring well installations.

Phase II assessment activities include validation of subcontracted laboratory analytical data, and data evaluation using federal criteria and Puerto Rico-specific standards (including the Puerto Rico Water Quality Standards and the Puerto Rico Residential, Industrial, and Protection of Groundwater Soil Standards Table 3 [Permanent Closure Guide for Underground Storage Tank Systems]) to characterize each site. Each Phase II report developed under this TO includes a detailed report of field investigation activities with field logs attached, analytical data tables with validation reports and raw data attached, figures depicting results, and an analysis of Brownfields cleanup alternatives (ABCA) for the site.

challenges

  • Challenges overcome that have been unique include the lack of Sanborn maps being available for Puerto Rico and the US Virgin Islands EDR database listings cover entire zip codes instead of radial distances from subject properties.

solutions

  • Performed extensive research to prepare a site inventory of potentially nearby sites identified by EDR in the same zip code(s) with potential to impact the TBA site, then performed in-person reconnaissance of those properties to verify their presence within radially-required distances.

results

Nobis has successfully completed over $1.8M in TBAs for Region 2 under the TO, including:

  • 16 Phase Is and 7 Phase IIs throughout Puerto Rico
  • 3 Phase Is and 5 Phase IIs in New York
  • 2 Phase Is and 2 Phase IIs in New Jersey
  • 1 Phase I in the US Virgin Islands