TRG & Environmental News

Friday, March 15, 2013
2012 Successes in Review
The Reynolds Group continues to advance assessment and remediation projects. Among our successes in 2012 are closures for the following cases: 
  • a former petroleum pipeline junction facility (brownfield) that is being re-used and developed into single family residences
  • a former plumbing facility near downtown Los Angeles
  • a dry cleaners in La Canada, California
  • an orange grove in Redlands, California
  • a manufacturing facility in Pico Rivera, California.
  • a cleanup case related to the California Underground Storage Tank Cleanup Fund in Santa Monica, California.
All six projects involve different regulators and different conditions. We are proud to be able to assist our clients to obtain "No Further Action" letters. In the year to come, we plan on closing out a dozen more assessment and remediation sites and continue our effort in providing services for public agencies, business owners, real estate managers and brownfield Stakeholders.


Wednesday, January 16, 2013
Low-Treat Underground Storage Tank Case Closure Policy
The State of California adopted the Low-Threat Underground Storage Tank Case Closure Policy (Low Threat Policy), and it became effective on August 17, 2012.  The Low Threat Policy specifically applies to petroleum Underground Storage Tank (UST) sites. Through a process of scientific evaluation and public participation, the California State Water Resources Control Board (SWRCB) promulgated an “updated and enlightened view” of “how clean is clean” for petroleum products (primarily gasoline) in soils and groundwater. The policy takes into account the protection of California’s precious groundwater resources and the current science of health risk exposures to humans. In effect, the Low Threat Policy increases the threshold of gasoline allowed to remain in the soils and groundwater and provides clearer criteria for case evaluation and closure.  

Case closure is granted by regulatory agencies and is officially acknowledged with “closure letters” which are “golden tickets” for property owners. Closure letters - sometimes called “no further action letters” state that no further environmental assessment or cleanup (remediation) work needs to be performed based on the facts and regulations at the time of the letter. We have seen that “closure letters” generally remove the financial liability and stigma associated with a contaminated real property. Closure letters allow property owners to realize the full value of their asset not discounted by unknown contamination remedies. Closure letters, in turn, allow for property sales, refinancing, and liquidation of assets nearer full market value. For small “mom and pop” gasoline station owners, “closure letters” enhance the positive equity in their property and can make a big difference in their asset planning -- thus they are called the “golden tickets.”

Currently, The Reynolds Group is reviewing all of our UST clients’ cases through the lens of the Low Threat Policy. Some of our clients’ persistently stubborn UST cases will be eligible for closure under the Low Threat Policy. We are pursuing closure for sites that meet the Low Threat Policy criteria. We have developed a Low Threat Policy Evaluation Package that can be used for all Underground Storage Tank cases. We will gladly review any case within the Low Threat Policy framework and develop an opinion as to whether or not the case can be closed under the Low Threat Policy or we will provide reasons why in our opinion it can not.

Property owners should understand that as of the beginning of 2013 there is a logjam of cases being evaluated for closure by regulators at the County, Regional, and State levels. Regulators have told us their priorities in the first half of 2013 are to close cases that meet Low Threat Policy criteria. We are hopeful that closing cases will allow regulator manpower and financial resources to be invested in higher priority (more contaminated) cases. However, the current backlog of closures means that once closure is granted on a case, closure letters may not arrive in the mail from the regulators for more than a year.

Tuesday, October 18, 2011
Vapor Intrusion Mitigation

The Reynolds Group recently completed a Vapor Intrusion Mitigation (VIM) Feasibility Test. The objective of the test was to see if we could prevent the intrusion of PCE, a chlorinated solvent, into an occupied building by depressurizing the limited space between the building’s concrete slab on grade and the soil immediately beneath it. Typically, the source of chemical vapors that intrude into indoor environments is contaminated soil or contaminated groundwater. VIM is not considered a means of remediating the source of soil or groundwater contamination. The following is meant to provide information on Vapor Intrusion Mitigation.


DTSC and VIM

The DTSC developed a Vapor Intrusion Mitigation Advisory (VIMA, April 2009) to assist with selecting, designing, and implementing appropriate response actions for sites where a potential vapor intrusion risk has been identified for occupants of existing or future buildings. Responsible parties may use the VIMA when 1) risk according to vapor intrusion is estimated by modeling or indoor air sampling; and 2) mitigation is proposed as part of a response action. According to the DTSC 2005 and 2009 guidance documents, the responsible party may propose vapor intrusion mitigation as a pre-emptive solution for a perceived rather than actual threat.


VIM Methods for Existing Buildings

According to the DTSC 2009 VIMA, sub-slab depressurization systems (SSD) are most applicable for existing slab-on-grade building construction. This guidance is also contained in the Interstate Technology and Regulatory Counsel (ITRC) Technical and Regulatory Guidance document dated January 2007. A SSD system is designed to function by continuously creating a lower pressure directly underneath a building floor relative to the pressure within a building. The resulting sub-slab negative pressure inhibits soil gases from flowing into the building, thus reducing VOC entry into the building. VOCs caught in this negative pressure field are collected and piped to an ambient air discharge point. The vacuum or depressurization under the slab is typically accomplished with a motorized blower. The blower draws air from the soil beneath a building and discharges it to the atmosphere though a series of collection and discharge pipes. Other remedies in addition to, or as alternatives to, SSD systems are available to address site specific conditions including sealing cracks and openings in the building foundation/floor and adjusting the building HVAC systems or installing a new system to maintain positive pressure indoors relative to the sub-slab area.


VIM Feasibility Testing

For the project recently completed, TRG’s staff constructed an extraction point through the concrete slab by coring through the slab and installing a PVC extraction pipe. The pipe was connected to a small blower, and the outlet of the blower was piped to two carbon filters in series. Several monitoring points that intercepted the space between the slab and the soil beneath it were installed through the slab. The monitoring points were used to measure the drop in pressure (vacuum) beneath the slab compared to the pressure inside the building.

The vacuum readings taken at the monitoring points showed that a small blower could be piped to two or three extraction points to create a vacuum under the entire building slab. Laboratory analyses of the extracted vapor stream showed the system was in fact recovering PCE. The PCE was captured by the carbon filters.


The results of the feasibility test showed that a small mitigation system could be installed and operated for a minimal cost to protect the building occupants from risks associated with vapor intrusion.

Saturday, September 17, 2011
Heavy Metals Site Closure in Beverly Hills
Our client, a commercial property management company in Beverly Hills has just received a No Further Action Letter from the Los Angeles County Fire Department HAZMAT Division. We helped our client wind down a tenant lease which stipulated an environmental assessment be performed. The lease further stipulated that any issues associated with the former tenant's metal plating operation discovered by the assessment be remediated to the proper regulatory standards.

Concentrations of contaminants in the soil such as chromium, copper, lead, nickel and zinc exceeded allowable limits and necessitated the physical excavation of the soils in order to clean up the site. Unfortunately, the impacted soils were beneath the building and below a shallow basement. Approximately 50 cubic yards of soil were dug up, manifested and properly disposed of. TRG was able to mobilized specialized equipment to the site in order to excavate the contamination from the basement level and load it into bins for transport to an appropriate disposal facility. Confirmation sampling showed pockets of contamination still in place after the initial excavation, and additional spot excavation was performed. TRG reported on the excavation activities which confirmed the metals at the site are now below concentrations negotiated with the County Fire Department.

This project was similar to several we have successfully executed for both tenants and property owners/managers. The lease has ben wrapped up and the commercial property is ready for the next business to move in and benefit our state's economy.
Tuesday, May 17, 2011
Heavy Metals Contamination Cleanup in Beverly Hills

TRG assisted a property management company in the wrap up of a tenant lease in Beverly Hills. The former occupant operated a metal plating business in the leased space. As part of the wind down of the lease, the tenant was required to return the property to its original condition. The property manager had been working with another environmental consultant who had identified metals in the soil beneath the former plating operation. However, the property manager retained TRG to perform the cleanup of the property and obtain case closure from the Los Angeles County Fire Department HAZMAT Division.


Concentrations of contaminants such as chromium, copper, lead, nickel and zinc in the soil exceeded allowable limits and necessitated the physical excavation of the soils in order to clean up the site. Unfortunately, the impacted soils were beneath the building and below a shallow basement. Approximately 50 cubic yards of soil needed to be dug up, manifested and properly disposed of. TRG was able to mobilized specialized equipment to the site in order to excavate the contamination from the basement level and load it into bins for transport to an appropriate disposal facility. Confirmation sampling showed pockets of contamination still in place after the initial excavation, and additional spot excavation was performed. TRG reported on the excavation activities which confirmed the metals at the site are now below concentrations negotiated with the County Fire Department. Case closure is eminent.



Tuesday, May 17, 2011
Will the Pace of Environmental Cleanups Be Affected By the New California UST Cleanup Fund Business Model?

As you may already be aware, The California UST Cleanup Fund is in the midst of changing its business model in order to manage its cash flow based on projected revenues for fiscal year 2011/12 which begins July 1st. The Fund now requires each claimant to provide a budget for the upcoming year’s assessment or cleanup/remediation activities. If budgets have not been submitted to the Fund, those sites will not receive reimbursements in the coming fiscal year. It is not clear at this point if the Fund will reimburse moneys spent equal to the submitted budgets.


The Fund is anticipating a dramatic decrease in revenues when AB1188 expires at the end of this calendar year. When AB1188 expires, the per gallon fee charged to UST operators will decrease from 2.0 cents per gallon to 1.4 cents per gallon. This 30% decrease coupled with dropping fuel sales as the price of gasoline remains above $4.00 per gallon will leave the Fund with a $126 million shortfall in FY 2011/12. The budgeting process the Fund is initiating is meant to address this shortfall.


Fund management has stated they expect to reveal the details of the new business model in May of this year. It is likely the improved cash management at the Fund will not alleviate the shortfall. It is also likely that assessments and cleanups will suffer delays due to lack of funding. As claimants fall behind on regulatory requirements to investigate and remediate soil and groundwater contamination, they risk falling out of compliance with regulatory agencies’ requirements.


Friday, April 22, 2011
Los Angeles Metropolitan Transportation Authority Contract Completion
The Reynolds Group just successfully completed an environmental screening project with the Los Angeles County Metropolitan Transportation Authority (MTA). MTA is expanding light rail service to Santa Monica from Culver City with the Exposition Phase 2 Light Rail Transit Project (Expo Phase II LRT Project). Part of the project involves acquiring properties along the route. MTA was concerned about possible liabilties associated with the past and present uses of these properties. TRG won the project in a competitive bid process and performed subsurface soil sampling and analyses. The work was coordinated with the businesses operating at the sites and was performed with no interruption to their operations. MTA is completely satisfied with the work, and we are pleased to have them as our client.



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Environmental Consulting & Environmental Contracting
Environmental Consulting & Environmental Contracting
Environmental Consulting & Environmental Contracting
Environmental Consulting & Environmental Contracting