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Brownfields Case Studies

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A presentation by EPA's Technical Assistance to Brownfields Providers at NADO's Annual Training Conference, October 26, 2015

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Brownfields Case Studies

  1. 1. Regional Planning Commission’s Brownfield Redevelopment Program
  2. 2. RPC’s Brownfield Program  Regional Planning Commission Overview ‐ Government Entity ‐ Member Parishes: Jefferson, Orleans, Plaquemines, St. Bernard, St. Tammany & Tangipahoa Parishes ‐ Commission is made up of elected officials, community representatives, transportation agencies ‐ Professional Staff carries out day-to-day work  Program Director: Rebecca Otte ‐ Secures & Manages Grant Funding (EPA Grants) ‐ Oversees Environmental Assessments ‐ Helps Applicants through the Environmental Process ‐ Coordinates Brownfield-related Outreach
  3. 3.  U.S. Environmental Protection Agency (EPA) ‐ Provides funding through competitive grants ‐ Oversees compliance with EPA grant requirements  Louisiana Dept. of Environmental Quality (LDEQ) ‐ State Environmental Regulatory Agency ‐ Overseas technical aspects of environmental assessments & cleanups ‐ Responsible for approving all environmental cleanup activities ‐ Also has a Brownfields Program  Louisiana Brownfield Association RPC’s Brownfield Partners
  4. 4. What we look for in a Brownfield Project:  Redevelopment of an Underutilized/Abandoned Property which is hindered by real or perceived environmental contamination  Site Champion that will be involved throughout the process  Redevelop will be Income Producing or for Community Benefit  Will help spur further economic development/ investment  Redevelopment is a Good Possibility  Site access  Compliance with EPA’s Continuing Obligations
  5. 5. RPC’s Brownfield Program What IS NOT included under Brownfields Funding:  Payment for environmental assessments already conducted  Funding for Site Purchase  Funding for Site Redevelopment, unless related to the Cleanup  Payments to other consultants or to property owners for environmental activities
  6. 6. Remediation/ Cleanup  Reducing the risk of exposure ‐ Treating contamination on-site or in situ (in the ground) ‐ Removing the contamination ‐ Institutional Controls (e.g., conveyance notice to not allow groundwater to be used for drinking water) ‐ Engineering Controls (e.g., capping contamination with a parking lot) Goal: Reduce the risk of exposure to unsafe levels of contamination to protect Human Health & the Environment
  7. 7. Remediation/ Cleanup  Proposed Redevelopment affects the Cleanup Plan  Coordinate Cleanup with Redevelopment  Can layer funding ‐ Public/ private Funding ‐ Grants/loans  EPA Cleanup Funding = Additional Requirements
  8. 8. Examples of Brownfield Sites
  9. 9. Former Schwegmann’s Superstore Algiers (New Orleans)  Environmental Issue: Needed to address fuel tanks to secure bank loan for site purchase  Proposed Redevelopment: Event Rentals expanded operations  Environmental Work:  Event Rentals – Phase I  RPC – Phase II & UST Closure Event Rentals also worked with New Orleans City council to create Economic Development District around the site
  10. 10. Progressive Church Family Life Center Site History  Asbestos in soil from previous fill activities  Updated Phase I ESA- former junkyard on the site  Phase II ESA delineated asbestos contamination & limited area of heavy metal & petroleum contamination  Cleanup: 12,876 tons of soil removed  LDEQ Certificate of Completion issued Sept. 10, 2008 Location: 4th and Cohen Streets, Marrero, Jefferson Parish, LA Size: 18 acres  Total Investigation Cost: $111,500 - Paid for through RPC’s Brownfield Assessment Grants; LDEQ waived their oversight fees  Total Cleanup Cost: just shy of $500,000  $200,000 USEPA Brownfield Cleanup Grant (Competitive Selection)  $300,000 Loan from RPC’s Brownfield Cleanup Revolving Loan Fund  Also received LA Brownfield Cleanup Tax Credit
  11. 11. Garden on Marais 4600 Marais St., New Orleans (near Industrial Canal)  Environmental Issue: Former Pesticide Facility  Proposed Redevelopment: Community Garden  Environmental Work:  RPC Phase I & II assessment  Incorporated sampling for LSU Ag Center Evaluation  Utilized Workforce Development Students  Rec’d NFA from LDEQ
  12. 12. Former St. Rose de Lima Cathedral & School  Proposed Redevelopment: - Charter School Incubator - Artist Space & Support Services - Community Meeting Space Bayou Treme Center
  13. 13.  Environmental Issues: - Underground Tank – Heating Oil - Lead, Asbestos & Bird Droppings  Environmental Work:  Phase I & Update  Phase II under VRP  Closed & Removed UST  Prepared Cleanup Plan & Related Documents  Working with BTC on Lead & Asbestos Abatement  Other Considerations:  Historic District  Use of CDBG Funding  Owned by Catholic Archdiocese Bayou Treme Center
  14. 14. St. Margaret’s at Mercy  Environmental Issues: - Asbestos in Building - Fuel tanks onsite  Environmental Assessment Work: - Phase I - St. Margaret’s - Phase II Work Plan – City of New Orleans - Phase II implementation – RPC - Cleanup Plan – RPC  Cleanup Funding: - UST Removal - LDEQ Grant - Asbestos Abatement:  EPA Competitive Cleanup Grant  Brownfield Cleanup Loan from City of New Orleans
  15. 15. St. Margaret’s at Mercy  Redevelopment Planning Underway: - Senior Living Facility already built - Additional Senior Living Units in Renovated Structure - More information on the tour!  Considerations: - Historic Tax Credits - Significant community interest
  16. 16. Falstaff Brewery Location: 2600 Gravier Street, New Orleans, LA Size: 8 acres Site History:  Brewery Closed in 1978; Site left vacant  Phase I ESA conducted in Aug. 2005 in preparation for site purchase; Paid for by RPC Brownfield Assessment Grant  Extensive Asbestos Containing Materials, Lead-Based Paint, and Solid Waste throughout 7-Story Structure  Falstaff Properties I LLC purchased property and cleaned up contamination Success Status:  Opened in 2008  Currently at 95% Occupancy  Mixed-Use Residential & Commercial Property  Includes Affordable Housing Units Before: After:
  17. 17. New Orleans BioInnovations Center Location: 1441 Canal St. Site History:  Former gas station  UST Cleanup funded by the LA Dept. of Economic Development and U.S. EDA Success Status:  LEED Gold  200 direct jobs  Clad with precast panels fitted with glass, which reduces the amount of heat entering the building.  Sunscreens on the glazing provide lighting and storm protection and reduce energy costs.  The white reflective roof of the building also reduces the energy costs. Other sustainable features of the facility include a rainwater retention system to collect water from the roof and electric vehicle charging stations.
  18. 18. Considerations for Brownfield Funding  EPA Funding Comes with Strings Attached  EPA & LDEQ approvals  EPA reporting  Quality Assurance Project Plan  RPC helps with “string management”  RPC helps facilitate the LDEQ review process by: ‐ Flagging sites as redevelopment projects ‐ Reviewing documents prior to submission ‐ Working with the LDEQ Team Leaders on timing
  19. 19.  Brownfields does not move quickly  Takes about 30 days to enroll a site ‐ Timing depends on how long it takes to receive paperwork & access agreement from applicant  Phase I: 60-90 days (normally 30 days with private funding)  Phase II: 6- 12 months  VRP Phase II: 12 – 18 months  Cleanup: At least 12 months Brownfields Timing
  20. 20. Contact Information Rebecca Otte Brownfield Redevelopment Program Director Regional Planning Commission brownfields@norpc.org (504) 483-8513 Questions?
  21. 21. Environmental Process Site Cleanup/Reuse Plans & Remediation Address contamination to mitigate risk of exposure that may impact human health or the environment Not always in this order Phase I Environmental Site Assessment (ESA) Research report to look at what was at the site previously and what’s there now and identify any potential environmental concerns Phase II Environmental Site Assessment (ESA) Collect and analyze soil and groundwater samples to determine if contamination is present and if so, to what extent
  22. 22. Environmental Process Reasons to Conduct a Phase I Environmental Site Assessment:  Determine if contamination may be present ‐ Avoid surprises during the construction phase ‐ Reduce purchase price ‐ Address environmental issues prior to redeveloping the site  Document site conditions before you purchased it ‐ Liability Protection from EPA & LDEQ ‐ Eligibility for Brownfield Funding
  23. 23. Environmental Process Liability Protection Conditions:  Phase I Environmental Site Assessments must meet EPA’s All Appropriate Inquiry / ASTM E1527-13 Standard  Performed by a “Qualified Environmental Professional”  Timing: Important to time the Phase I assessment to ensure it’s valid at time of purchase ‐ Phase I Assessments expire after 1 year for liability protection ‐ Portions of the Phase I report need to be updated after 6 months
  24. 24. Environmental Process Regulatory Oversight Options for Phase II Assessments and Cleanups/ Remediation:  Traditional Oversight - Commonly called RECAP: Risk Evaluation/ Corrective Action Program  Only address areas with recognized environmental concerns  Assessment Phase is generally quicker and lower costs  May need to sample offsite to determine horizontal extent of contamination (increases costs & time)  Less flexibility if cleanup is required  LDEQ may reopened the investigation in the future (e.g., if LDEQ lowers the maximum safe concentration levels of a contaminant found onsite)
  25. 25. Environmental Process Regulatory Oversight Options for Phase II Assessments and Cleanups/ Remediation:  VRP: Voluntary Remediation Program  Investigation/Cleanup covers the entire Site as defined by the Applicant  Requires additional sampling & analysis which increases upfront costs  Requires public notice & specific LDEQ approvals which increases time  Not required to sample offsite to determine horizontal extent of contamination (may save costs & time)  More flexibility if cleanup is required Can use Engineering/ Institutional Controls  Once the LDEQ approves the cleanup, the site cannot be reopened Liability protection flows down to future owners
  26. 26. Example: Traditional Program/ RECAP Building Heating Oil Tank Fuel Tank
  27. 27. Example: Voluntary Remediation Program Building Heating Oil Tank Fuel Tank
  28. 28. RECAP Investigation (Phase II ESA) VRP Investigation (Phase II ESA)  Generally lower in costs - Less samples collected - Fewer pollutants to analyze for  Generally a faster process - No public notice required  May miss contamination in another area of the site  May need to sample offsite to determine horizontal extent of contamination  Generally more expensive - Requires more samples to be collected - Requires a wider range of analyses  More time consuming - Specific process requires more approvals - Public notice requirements  May find other contamination that was not previously known  Investigation confined to site boundaries RECAP Remediation/ Cleanup VRP Remediation/ Cleanup  Remediation of all risks is required, e.g. any contamination that is above RECAP standards needs to be remediated  Engineering/ Institutional controls generally not acceptable  Remediation can be tailored for the intended future use of the site  Engineering/Institutional controls may be used to prevent exposure to contamination - Cost savings RECAP Final Result VRP Final Result  No further action at this time (NFA) letter from LDEQ  Site may be reopened in the future (for example, if LDEQ lowers the maximum safe concentration levels)  Certificate of Completion (COC) for the entire site defined in the application  Release of liability from EPA & LDEQ for all past contamination at the site (transferable to future site owners)
  29. 29. Environmental Process - Cleanup  Remediation/ Cleanup is reducing the risk of exposure to contamination at the site as detailed in the Site Cleanup Plan, including: ‐ Treating contamination on-site or in situ (in the ground) ‐ Removing the contamination ‐ Institutional Controls (e.g., conveyance notice to not allow groundwater to be used for drinking water) ‐ Engineering Controls (e.g., capping contamination with a parking lot) Goal: Reduce the risk of exposure to unsafe levels of contamination to protect Human Health & the Environment
  30. 30. Environmental Process - Cleanup  Proposed Redevelopment affects the Cleanup Plan  Coordinate Cleanup with Redevelopment  Can layer funding ‐ Public/ private Funding ‐ Grants/loans  EPA Cleanup Funding = Additional Requirements
  31. 31. Web Resources  US Environmental Protection Agency’s (EPA’s) Brownfields Website: www.epa.gov/brownfields/  US Department of Housing and Urban Development (HUD): http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_plann ing/economicdevelopment/programs  EPA’s RE-Powering America’s Land Initiative: www2.epa.gov/re-powering  The Brownfield and Land Revitalization Technology Support Center (EPA, USACE, ANL): www.brownfieldstsc.org

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