ID#1529 made on
SSc3 - Brownfield redevelopment
LEED BD+C: New Construction, LEED BD+C: Schools, LEED BD+C: Core and Shell
We are requesting approval of alternate documentation in support of SS Credit 3. Our project, multi-family housing in Bellingham WA, was built on a site containing petroleum-contaminated soil. The geo...
We are requesting approval of alternate documentation in support of SS Credit 3. Our project, multi-family housing in Bellingham WA, was built on a site containing petroleum-contaminated soil. The geotechnical engineering consultant for the project detected lubricating oil concentrations above Ecology Model Toxics Control Act Method A cleanup levels during their geotechnical engineering study. This study included soil borings in 6 locations, with contamination encountered in 2 of these samples. Based on this analysis and further evaluation during excavation, 860 cubic yards of contaminated soil were removed from the site and brought to an Environmental Services facility in Everett, WA for soil remediation. Clean fill was then imported to the site. A specific Phase II environmental assessment was not conducted based on the recommendation of the environmental consultant. In lieu of conducting the additional soil borings that would be part of the Phase II analysis, it was decided to proceed with excavation and clean-up procedures. During excavation and clean-up, additional soil sampling was conducted to ensure that all contaminated soil had been removed. Below is the recommendation of the environmental services firm, which had been contacted to perform a level II ESA, explaining why the level II assessment would not be necessary in this particular situation: "I have to apprise you that the information generated by a level II ESA should essentially duplicate the sub-surface analysis already performed by Geoengineers. Our Level II approach would be to sink 8 borings to a depth of 18 feet, field screening during the boring and extracting 1 soil sample (WTPHD-ex) from each boring for laboratory analysis. This would generate additional data points to increase the confidence level for plume identification. I would suggest you consider a secondary strategy, which may be more economically viable, to begin the actual excavation of identified PCS with a regimen of soil sampling to verify satisfactory cleanup - this is the likely recommendation of a level II ESA." (Nowicki Environmental, e-mail communication June 27, 2005) We did pursue the alternative documentation method recommended in the CIR ruling of 5/7/2002. We contacted the Region 10 Brownfields Coordinator to request documentation that the site meets the EPA criteria for a brownfield. According to the Coordinator, there is no available EPA documentation of a brownfield. Instead, the EPA provides assessment only in relation to the granting of remediation funding. The Coordinator indicated that the EPA considers it acceptable to self-certify a brownfield, if it meets the national definition. As noted in the LEED reference guide, the EPA definition of a brownfield is as follows: "The term 'brownfield site' means real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollution, or contaminant." (www.epa.gov/brownfields/html-doc/hr2869.htm) Based on this definition, our project site clearly meets the definition of a brownfield. Our submittal to the USGBC in support of this credit would include the following documentation: 1. Geotechnical environmental site assessment report. 2. Geotechnical recommendations for meeting Level II ESA requirements. 3. Geotechnical remedial excavation monitoring and soil sampling report. This documentation shows both that the site was contaminated, that investigations at the level of a Phase II EAS were conducted, and that appropriate remediation measures were conducted to clean up the contamination.
The site meets the definition of a brownfield, as hazardous contamination was identified during the geotechnical environmental site assessment. The geotechnical assessment as performed essentially meets the objectives of a Phase II Environmental Site Assessment, and appropriate remediation was completed to meet the credit requirements. Ongoing monitoring of the site for the identified contaminant is also recommended (but not required for LEED certification) to ensure that contamination problems do not return.
Related Addenda (Corrections & Interpretations)