Service: Regulatory Response & Negotiation

Since 1989, The Reynolds Group has remediated and received "closure" on more than 250 environmentally-impaired properties.

As soon as a client retains The Reynolds Group (TRG), TRG engages the regulator(s) to suggest innovative ways to perhaps reduce the scope of work. Next, The Reynolds Group meets jointly with the client and regulator to negotiate next steps ("how clean is clean?")and future work.

The Reynolds Group has worked under the direction of all the major regulatory agencies including the Federal EPA, CAL-EPA, The California Regional Water Quality Control Boards, the Department of Toxic Substances Control (DTSC), and a variety of fire departments and county environmental health departments.

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.

USEPA Funded Remediation for Non-Profit (6737.III)

Client:	LULA WASHINGTON DANCE THEATRE
Proj Mgr:	Daniel Nunez	Completed:	In Progress
Industry:	Real Estate Developers City, County, State And Federal Agencies Non-profit Organizations	Service:	Brownfields/redevelopment Soil Remediation Regulatory Response & Negotiation Soil Vapor Extraction
The property, acquired by a non-profit dance studio in South Central Los Angeles, was found to be impacted by gasoline from former Underground Storage Tanks (USTs). Concerns about property value and health risks lead the property owner to obtain a Brownfield Grant. TRG was selected to advance remediation work under the oversight of the United States Environmental Protection Agency (USEPA), the Community Redevelopment Agency of the City of Los Angeles (CRA/LA), and the City of Los Angeles Fire Department (LAFD). After successful cleanup activities and health risk assessments, case closure is being negotiated for the property.

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.

Hexavalent Chromium (6687.IV)

Client:	CHROMAL PLATING & GRINDING
Proj Mgr:	Al Fuan	Completed:	In Progress
Industry:	Metal Finishers Manufacturers	Service:	Regulatory Response & Negotiation Site Assessment
The Los Angeles Regional Water Board (LARWQCB) began searching in the early 2000's for sources of chromium that had impacted key beneficial drinking water supplies in the Los Angeles area. One of TRG's clients, a plating company, was asked to look into its past practices and assess the subsurface because another Fortune 500 company downgradient had detected highly elevated concentrations of chromium and believed it to originate from TRG's client. Working with the law firm of Franklin, Bevins, Walsworth & McCall, TRG was able to advance work enough to demonstrate that the problem at the Fortune 500 company was more likely its own problem than TRG's clients. By creating a compilation, surveyed regional issues report, TRG was able to graphically demonstrate that its client's chromium issue was "de minimus". In this case, TRG worked through its clients insurer, Zurich Insurance North America.

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.

Relocation of Food Production/Unwindiing of Tenant Lease (6924.IV)

Client:	FRESH START BAKERIES
Proj Mgr:	Dwayne Ziegler Ed Reynolds Jr.	Completed:	12/30/2007
Industry:	Manufacturers	Service:	Soil Remediation Site Assessment Regulatory Response & Negotiation Asbestos/ Lead/ Mold Consulting
One of the largest national suppliers of baked products to McDonalds Restaurants needed to assess and mitigate soil contaminated with petroleum hydrocarbons (hydraulic oil) inside of their leased Southern California production site. In addition, TRG was requested to provide asbestos related pre-demolition consulting advice. Approximately two years before its lease expired, Fresh Start Bakeries began the process of evaluating potential environmental impairment caused during its operation of an industrial bakery at the site. Fresh Start engaged The Reynolds Group because of our prudent approach to assessing and dealing with environmental liabilities. After performing a complete assessment, TRG quantified and budgeted the cost of remediation. To ensure there would be no issues with the landlord/property owner upon the expiration of it lease, Fresh Start Bakeries asked The Reynolds Group to proactively engage the regulatory agency, the County of Los Angeles Fire Department, to approve an expedited Remedial Action Plan. The Reynolds Group demolished the concrete floor and excavated approximately 400 tons of soil from the interior of the production building in confined conditions. Excavation was advanced until on-site laboratory analysis of the soils confirmed that levels of hydraulic oil met the cleanup levels pre-established by the Fire Department. In the end, Fresh Start Bakeries received a "No Further Action" letter with no restrictions on the sites future use. The Reynolds Group arranged for the safe transportation and disposal of the contaminated soils and restored the floor inside the building to its original condition. All of the work was completed under a tight timeline over a Thanksgiving Holiday. During decommissioning and demolition of the manufacturing equipment and tenant improvement, issues related to potential asbestos containing materials in building products and kilns arose. The Reynolds Group was engaged to assess the issues, provide solutions and engage and manage a contractor to abate the issues as required for Fresh Start Bakeries to move out of the premises with no residual liability.

Brownfield Spill Response & Closure (7063.XIV)

Client:	7TH STREET DEVELOPMENT
Proj Mgr:	Dwayne Ziegler	Completed:	01/11/2007
Industry:	Real Estate Managers/owners	Service:	Regulatory Response & Negotiation Brownfields/redevelopment
Following the release of a significant quantity of PCB containing oils from a former electrical switching building, TRG assisted the Brownfield property owner with spill cleanup, documentation and closure activities. TRG followed protocols specified in TSCA and 40 CFR 761 to decontaminate and wipe test the building from which the PCBs were released. In addition, TRG oversaw the excavation and disposal of PCB impacted soils and solid wastes. Timing was critical at this Brownfield site because the release occurred at an abandoned building slated for immediate demolition. Without an agency release from spill response obligations, the grading and building at the site would have stopped, causing costly delays in the redevelopment. To expedite cleanup and closure, TRG informed the oversight agency (Los Angeles County Fire Department Hazardous Materials Division) of the on-going cleanup progress and confirmation testing results. Once it was decontaminated to strict regulatory standards, TRG negotiated with the LACFD to obtain an expeditious release of the building, so that it could be demolished. Closure was granted within a week of TRGs report submittal.

Injection and Monitoring (5671)

Client:	ARCO POWER GAS
Proj Mgr:	Daniel Nunez	Completed:	08/27/2007
Industry:	Gas Station/ Underground Storage Tank Owners	Service:	Regulatory Response & Negotiation Mtbe Remediation Groundwater Monitoring Groundwater Remediation
Located on the border of Los Angeles and Culver City, this site lies within the Charnock sub-basin, from which the City of Santa Monica has historically obtained drinking water. The City's production wells in the Charnock sub-basin were shut down in 1996 when MtBE was discovered to have impacted the deep aquifer. Because of its location within the Charnock sub-basin, strict scrutiny was applied to this site by the Los Angeles Regional Water Quality Board, the US EPA and the City of Santa Monica. The gasoline released at this site had impacted the groundwater. The gasoline plume was assessed with a network of 15 groundwater monitoring wells. The remedial approach consisted of air sparging, soil vapor extraction and injection of a chemical oxidant to "polish" the groundwater concentrations and achieve the stringent closure concentrations. Closure was granted by the Los Angeles Regional Water Quality Control Board. The Reynolds Group provided Cleanup Fund approved assessment and remediation services for this project.

Gasoline Plume (6961.VII)

Client:	CITY OF COACHELLA
Proj Mgr:	Daniel Nunez	Completed:	In Progress
Industry:	Gas Station/ Underground Storage Tank Owners	Service:	Soil Remediation Regulatory Response & Negotiation Soil Vapor Extraction Site Assessment Groundwater Remediation California Cleanup Fund
This project is ongoing and funded by the Emergency, Abandoned, and Recalcitrant (EAR) Account which is administered by the Cleanup Fund. TRG has assessed the gasoline plumes in soil and groundwater (which extends off-site across a city street and beneath neighboring properties), installed soil vapor extraction and air sparge systems and begun active remediation. The core of the groundwater and soil plumes have been cleaned up. Semi-annual groundwater monitoring takes place through a network of 11 groundwater monitoring wells. An MTBE cut off plume remains to be cleaned up. The next phase of the project envisions the installation of six off-site ozone sparge wells to address the plume in the groundwater that has traveled off-site. Additionally, to ensure an even greater impact on the overall project, TRG has coordinated efforts between the regulator on the case and the Clean-up Fund contact to lay out project plans and budgets on an annual basis thereby compressing the typical time-line of a project like this. Our client is kept up to date with every aspect of the project. Closure is expected from the Colorado River Basin Regional Water Quality Control Board within two years.

Insurance Policy Case (7115VIII)

Client:	FULLERTON UNIVERSAL
Proj Mgr:	Al Fuan	Completed:	04/05/2007
Industry:	Real Estate Managers/owners Insurance Companies Real Estate Brokers	Service:	Regulatory Response & Negotiation
In some environmental cases, The Reynolds Group discovers issues that may be covered by insurance policies. On one case in Fullerton, California that The Reynolds Group performed, a forensic investigation of insurance policies led to finding that a Firemans Fund policy existing for a case. Once pressed, the insurance company processed the policy and paid. Although The Reynolds Group was not contracted to be the consultant of record because the insurance company had its own preferred vendors, the Client won in that the insurance company began funding the environmental work and the Clients use of its own financial resources were diminished.

Case Closure in San Diego (7306.VII)

Client:	SWALL FINANCIAL SERVICES
Proj Mgr:	Al Fuan	Completed:	05/16/2011
Industry:	Gas Station/ Underground Storage Tank Owners	Service:	California Cleanup Fund Regulatory Response & Negotiation Site Assessment
TRGs client had an open case at the San Diego Site Assessment/Mitigation Unit since 1991. When TRG was contracted as the environmental consultant of record in 2008, the case had already been transferred to the San Diego Regional Water Quality Control Board (SDRWQCB). We helped our client gain access to the Underground Storage Tank Cleanup Fund (USTCF) which reimbursed them for previous costs associated with assessment and source removal. TRG then completed the assessment of the contamination at the site and aggressively pursued case closure from the SDRWQCB arguing there was no need for active cleanup at the site. In less than two and a half years, TRG was able to obtain funding and close a case that had lingered for well over a decade. All work performed by TRG was within USTCF cost guidelines and was fully reimbursed by the USTCF. In less than two and a half years, TRG was able to obtain funding and close a case that had lingered for well over a decade.

Environmental Consulting & Environmental Contracting