Service: Health Risk Assessments

A Human Health Risk Assessment might allow development to continue, or allow the issuance of a regulatory Closure or No Further Action letter, while contamination stays in the ground.

The Reynolds Group has been asked to speak about the use of Health Risk Assessments in brownfield development cases, at such venues as the Legal Issues Symposium, presented by the California Redevelopment Association.

Human Health Risk Assessment (6425XIII)

Client:	SILVERCREEK PROPERTIES
Proj Mgr:	Dwayne Ziegler	Completed:	08/01/2005
Industry:	Real Estate Developers	Service:	Health Risk Assessments Brownfields/redevelopment Soil Remediation Regulatory Response & Negotiation
TRGs involvement in a major shopping center development saved the owner of the project potentially hundreds of thousands of dollars. Two environmental issues arose during the development of an orange orchard into a large retail shopping center in Corona. One was associated with the past use of the land as an orchard and the other was associated with electric transformers formerly located on the property. During grading activities, soil heavily stained by oil was encountered. TRG tested the soil and confirmed the substance was smudge pot oil based on the chemical make-up and the former land use. The burning of oil in smudge pots helped prevent frost from forming on the fruit in the orchard. There had been extensive remediation of smudge pot oil at the site prior to the recent purchase of the property. However, the newly discovered stained soil was outside of the boundaries of the area cleaned up in the past. The Santa Ana Regional Water Quality Control Board (SARWQCB) was the lead regulatory agency on the past and current smudge pot issues. While TRG was assessing the smudge pot oil, the construction activities at the site caught the attention of representatives of the County of Riverside, who later contacted the owner and informed him of a former electrical substation that used to be on the site. The substation transformers had exploded and the potential of PCB contamination was never properly investigated to the Countys satisfaction. TRG engaged the County and the SARWQCB on the substation issue as well. The SARWQCB conceded oversight of both issues to the County. TRG performed a Health Risk Analysis for both issues and was able to show that leaving the contamination in place would not pose an elevated health risk to the future occupants of the site. By using this approach, TRG obtained closure for the site and saved the project $100,000 of unforeseen costs.

DRY CLEANER SOIL AND GROUNDWATER REMEDIATION (6597.VI)

Client:	DOUBLETREE CHEVIOT HOLDINGS, LLC
Proj Mgr:	Al Fuan	Completed:	In Progress
Industry:	Real Estate Managers/owners Drycleaners	Service:	Soil Remediation Litigation Support Regulatory Response & Negotiation Health Risk Assessments Groundwater Monitoring Groundwater Remediation
This active, contaminated dry cleaner site is found in an urban retail shopping center. Decades of dry cleaning activities at the site have impacted the soil and groundwater with PCE. The owner of the retail center is seeking reimbursement from both current and former dry cleaner operators, and there is litigation pending on payment for cleaning up the source of PCE with the dry cleaner operators. To avoid a protracted cleanup schedule and reduce litigation costs, TRG was retained by the land owner to assess and cleanup the site. Moving into the remediation phase involved coordination with a large number of permitting agencies to perform assessments, constructing a remediation system, operating the remediation system (vapor extraction and air sparging), and monitoring discharges. A major law firm is involved in overseeing The Reynolds Group's work with an eye towards efficiency and minimizing third party liability. TRG is working closely with legal counsel as they seek input into the sources of PCE and cost basis of remediation.

Asbestos Consulting AHERA (4601 SA)

Client:	SANTA ANA UNIFIED SCHOOL DISTRICT
Proj Mgr:	Ed Reynolds Jr.	Completed:	In Progress
Industry:	School Districts/private Educators	Service:	Asbestos/ Lead/ Mold Consulting Health Risk Assessments
Santa Ana Unified School District was one of The Reynolds Group's original clients in 1989. Since 1989, The Reynolds Group has provided many different types of environmental services to the School District. Two decades ago Santa Ana Unified was awarded USEPA grants to fully abate two schools of asbestos over the summer time. The work required completely gutting the schools at the end of the school year, removing the asbestos, replacing the fireproofing and re-constructing the schools before school began in the fall. The Reynolds Group was engaged to plan the work, write the specifcations, assist in bidding the work, plan the project, and provide 24/7 project oversight and air monitoring. Both of the multi-million dollar projects were completed on time to the satisfaction of the School District. Over the decades, The Reynolds Group provided other services to SAUSD including hazardous materials inventorying, underground storage tank consulting and assessment services. As recently as 2006, The Reynolds Group was re-awarded the federally-mandated AHERA (Asbestos Hazard Emergency Response Act) re-inspections contract in 2006 encompassing the entire Santa Ana Unified School District.

Drycleaner PCE Contamination (6875.VI)

Client:	STANDARD INSURANCE COMPANY
Proj Mgr:	Al Fuan	Completed:	In Progress
Industry:	Drycleaners Insurance Companies Real Estate Managers/owners	Service:	Soil Remediation Litigation Support Regulatory Response & Negotiation Soil Vapor Extraction Health Risk Assessments Site Assessment Operations And Maintenance Of Remediation Systems
Standard Insurance Corporation (Standard) is a publicly traded Fortune 500 corporation and Exxon Mobil Corporation is one of the largest oil companies in the world. In this project, The Reynolds Group is untangling the liabilities and cost responsibilities of a commingled plume. The case is being overseen by the California Department of Toxic Substances Control (DTSC) and involves drafting and implementing work plans under the DTSC s stringent Quality Assurance/ Quality Control requirements. Several prominent law firms are engaged in this matter. DTSC and client interaction are critical to the effective advancement of the project. Standard is pleased with The Reynolds Group's performance. The case involves the assessment and remediation of chlorinated compounds associated with a commercial facility that are commingled with contaminants associated with the Exxon Mobil operation. The Reynolds Group completed the assessment under DTSC guidelines and is currently removing volatile organic compounds (VOCs) from the subsurface via soil vapor extraction. The Reynolds Group will commence remediation of the groundwater soon. Because of the sites proximity to a residential neighborhood, The Reynolds Groups Health Risk Assessment (HRA) capabilities are also utilized.

DTSC Site Investigation (6532.IV)

Client:	NORAC, INC.
Proj Mgr:	Al Fuan	Completed:	In Progress
Industry:	Manufacturers	Service:	Regulatory Response & Negotiation Health Risk Assessments Spill Prevention Control And Countermeasure
TRG's client is the leading supplier of ketone peroxides in North America, supplies specialty chemicals to the metallic stearate market and also produces Active Pharmaceutical Ingredients (APIs). TRG's client specializes in complex multi-stage organic synthesis and separation. The site is located in the San Gabriel Valley Superfund area within the Baldwin Park Operable Unit. Groundwater in the site vicinity is known to be contaminated. Depth to groundwater is more than 200 feet below ground surface. Drilling conditions at the site are difficult due to the presence of cobbles and boulders in the subsurface. The Reynolds Group was originally hired by its client in 1996 to perform an assessment. Because of The Reynolds Group's work, the client contacted us in 2004 to perform additional consulting services. Our client was in the process of obtaining closure for one of the areas of concern identified by the California Department of Toxic Substances Control (DTSC). During the DTSC visit to the site, the DTSC observed conditions requiring further investigation. The Reynolds Group prepared and implemented the RCRA Facility Investigation Work Plan, DTSC Corrective Action, Current Conditions Reports, and assisted with the Public Participation requirements of the DTSC. The Reynolds Group participated in meetings with DTSC staff to negotiate realistic assessment work scopes. Investigation methods included: soil gas sampling, soil gas probe installation and sampling, soil boring advancement with sonic drilling techniques, and shallow direct push (probing) methods.

Brownfield Redevelopment (5946.III)

Client:	LAW OFFICE OF STAN RALLS
Proj Mgr:	Al Fuan	Completed:	In Progress
Industry:	Attorneys Manufacturers	Service:	Soil Remediation Regulatory Response & Negotiation Health Risk Assessments Groundwater Monitoring Site Assessment Groundwater Remediation
This site had lain fallow for a decade. It had contained a mechanical manufacturing business, a dry cleaner and a gas station at one time. TRG worked with the clients counsel to enable the client to sell the property to a new owner for redevelopment. In order to facilitate the sale, TRG identified the environmental liabilities associated with the past uses of the property, negotiated with the Voluntary Oversight Program at the Los Angeles Regional Water Quality Control Board to separate soil and groundwater contamination into two issues, and addressed the soil contamination based on health risk standards. The Reynolds Group obtained a no further action letter for the soils issue which was key to allowing the real estate transaction to proceed. The seller provided a discount on the market value of the property to the buyer to accept the risk and liability of future costs associated with further groundwater assessment and remediation. Both parties were ultimately satisfied. The client was able to sell the property for cash and transfer liability to the seller. The buyer was able to buy the property at a risk appropriate discount for future development. The City of Long Beach benefited by having a formerly blighted property developed as a major grocery center.

Major Retail Shopping Center DeMinimus Status (6782.XIV)

Client:	MAJOR CONFIDENTIAL RETAIL CENTER OWNER
Proj Mgr:	Ed Reynolds Jr.	Completed:	06/07/2008
Industry:	Real Estate Developers	Service:	Usepa Superfund -- Responsible Party Representation Litigation Support Regulatory Response & Negotiation Health Risk Assessments Site Assessment
This Regional Shopping Center lies in an area that is being considered for Superfund status because of its location relative to a regional groundwater contamination issue. The client has been designated as a potential Responsible Party (PRP). The site also lies near a major stream tributary and soil conditions are very rocky. The Reynolds Group was able to bring the client back into the good graces of the regulatory agency by negotiating a reasonable scope of work for additional site assessment. The Reynolds Group also performed a detailed review of adjacent potential cases that highlighted the possibility of off-site contamination. The investigation including installing "semi-permanent" soil vapor probes to a depth greater than 150 feet below ground surface and sampling them. Based on the results of the sampling The Reynolds Group prepared an expert's consulting report that detailed why the client should be considered at most a "de minimis" contributor to any regional groundwater issue. TRG noted that there is a neighboring large contributor to the contamination that seems to have caused most of the problems. The Reynolds Group is currently working to minimize the clients PRP liability and is working closely with legal counsel to craft strategies regarding coordinating work with the off-site PRP.

Drycleaner Assessment (6881)

Client:	HOLME ROBERTS & OWEN LLP
Proj Mgr:	Al Fuan	Completed:	11/30/2007
Industry:	Drycleaners	Service:	Soil Remediation Regulatory Response & Negotiation Health Risk Assessments Groundwater Monitoring Site Assessment
During the due diligence for a real property transaction, contamination was discovered at this site. The seller retained the liability to remediate the contamination and hired The Reynolds Group to provide turnkey environmental services to advance the project to a "No Further Action" letter. To expedite closure for the seller, The Reynolds Group was able to obtain "No Further Action" letter for the vadose zone, while continuing to remediate the groundwater at the site. The unconditional "No Further Action" letter for final closure (including groundwater) at the site was obtained only a few months later.

100 ACRE OIL FIELD REDEVELOPMENT (5616.III)

Client:	ESTATE WITH LARGE REAL ESTATE HOLDINGS
Proj Mgr:	Ed Reynolds Jr.	Completed:	08/13/2008
Industry:	Real Estate Developers	Service:	Brownfields/redevelopment Soil Remediation Health Risk Assessments
TRG performed excavation and bioremediation of petroleum hydrocarbon-impacted soils, asbestos abatement, and disposal of mercury-containing soils. During this work, TRG responded to many unexpected issues such as the assessment and removal of radioactive piping. Soil vapor surveys were used to assess potential health exposure risks. All of this work was performed at the same time as the decommissioning of the active oil field which required intense schedule coordination. The work of TRG staff resulted in 75 acres being developed for residential use. The remaining acreage was developed for commercial and industrial use.

Advancing Remediation at a Dry Cleaner (7489.I)

Client:	ENVIRONMENTAL ATTORNEY
Proj Mgr:	Al Fuan	Completed:	In Progress
Industry:	Attorneys	Service:	Soil Remediation Site Assessment Health Risk Assessments
The Reynolds Group has worked with an environmental attorney to assist a retail center owner in advancing remediation of a dry cleaner Riverside County under a voluntary program. The case involves a number of factors including financial distress, Human Health Risk, Assessment, and Remediation. Timing and sequencing of work activities are coordinated with the attorney.

Dry Cleaner Assessment (7564.VI)

Client:	PRIVATE PROPERTY OWNER
Proj Mgr:	Daniel Nunez	Completed:	09/30/2011
Industry:	Drycleaners Real Estate Managers/owners	Service:	Soil Vapor Extraction Health Risk Assessments Operations And Maintenance Of Remediation Systems Soil Remediation
The Reynolds Group recently completed a controversial assessment and remediation that involved Assessment, Health Risk Assessment and Remediation through the Orange County Health Care Agency (OCHCA). The controversy was that the City in Orange County where the work was conducted wanted to create a complicated chain of regulators: the Department of Toxic Substances Control (DTSC), the Santa Ana Regional Water Quality Control Board (SARWQCB), and the OCHCA. Working through Luis Lodriguezas Voluntary Oversight Program, TRG was able to secure a No further action letter from OCHCA without DTSC or SARWQCB involvement once concentrations in the ground were shown not to pose an elevated health risk.

Remediation at Gas Station Site (6122.CUF)

Client:	MAGIC GAS
Proj Mgr:	Al Fuan	Completed:	11/23/2010
Industry:	Gas Station/ Underground Storage Tank Owners	Service:	Soil Remediation Soil Vapor Extraction Health Risk Assessments California Cleanup Fund
When The Reynolds Group was brought onto this project in the Echo Park neighborhood of Los Angeles, the soil and groundwater contamination had not been fully assessed. The site was, therefore, not eligible for closure consideration. We assisted our client with their Cleanup Fund application and secured funding for the project. Once funding was in place, the cost of all subsequent work was pre-approved by the Cleanup Fund in order to guarantee reimbursement of costs, and the contamination was fully assessed. Upon completion of the assessment, TRG performed a limited amount of soil remediation and demonstrated the groundwater plume was stable (not increasing or spreading in area). Results of soil vapor sampling and a Human Health Risk Analysis (HHRA) demonstrated there was no risk of detrimental effects to human health by way of gasoline vapor intrusion.

Environmental Consulting & Environmental Contracting