Conducting a hazardous materials survey of a building which is to be renovated or demolished involves much more than simply completely a lead based paint or asbestos materials survey. When buildings are going to be renovated or demolished, the scope for abatement and hazardous materials management work needs to be defined, to avoid costly change orders during the reconstruction or demolition process. Also, building owners have to be careful to make sure that all wastes are properly managed, because mismanaged PCB capacitors and fluorescent light fixtures, mercury switches and/or mismanagement of mechanical or electrical components can result in future Superfund liability, if demolition wastes are not properly managed.

For buildings that are going to be renovated or demolished, it is very important that hazardous materials be properly separated, particularly if demolition waste or materials are to fit the category of "clean fill." Unfortunately, most demolition specifications and contracts currently issued, simply don't contain the proper regulatory language to minimize the owner's liability from improper disposal of off site materials. Throughout the Northeast here in the United States, Superfund off site disposal liability, as well as private litigation has occurred when materials ostensibly reported to be "clean fill," are later found to have significant quantities of hazardous substances.

Another frequent problem during building demolition and renovation projects is properly coordinating asbestos and lead based paint abatement work with demolition or renovation work. Very simply, more in depth surveys of asbestos containing materials and lead based paint are needed where major renovation or demolition work are planned. For example, when walls have been built out over floor tiles, it is not cost effective nor efficient to separate out demolition and abatement work, because costly remobilization of contractors will simply increase the cost of the project.

When RT is engaged to conduct hazardous materials survey on buildings which are planned to be renovated or demolished, we always focus on determining "what is the best way?" to deal with this individual structure. Because our principals have more than 25 years of experience on industrial closure and decommissioning projects, we can quickly identify the best demolition or renovation hazardous materials management approach, taking into account:

• The extent to which asbestos containing materials are present;
• The extent to which lead based paint is present, and whether it is practical to fully abate it or make particular areas "lead safe";
• We can advise how to manage utilities during abatement, demolition, and reconstruction, so as to minimize the cost for dealing with hazardous materials;
• Work closely with the architectural and engineering team to provide the owner with the best approach, for quick building and tenant space turnaround, while making sure that all abatement activities are conducted according to federal and state laws and regulations, and that all waste and materials resulting from the project, are properly managed.

For most building owners, this steps are essential, because leading New York financial houses, banks, pension funds, and insurance interests, who typically underwrite long-term building mortgages, have come to expect detailed documentation that building reconstruction and renovation was properly managed.

We at RT have cross trained many of our staff to be able to respond building owner's need as well as the needs of architects and building engineers, to quickly identify how to deal with the environmental issues associated with each building, and to quickly identify the best way to deal with them. However, because the renovation and demolition market is increasing in scale and scope, we felt it appropriate to be better prepared to service to wrap up the increasing hazardous materials survey market which is now upon us.

We already taken the steps to determine the best way to:

• develop specifications, to work with all trades, reflecting temporary and permanent utilities, partial or complete early or beneficial use.
• study each building and know how to phase abatement and hazardous materials management, and
• generate CADD floor plans using a schedule formats to summarize hazardous materials abatement needs on a floor-by-floor basis.

Already, Construction Managers and Architects have commented that such a simple approach should have been used earlier, helping to avoid the majority of "unexpected finding" problems which have unfortunately plagued many building demolition and renovation projects. We at RT automatically include the "unforseen condition" contractor reporting and construction cost management techniques in all of our standard drawings and specifications packages, to make sure that any unexpected involvement or conditions which arise during construction can be carefully managed, while other work continues in the building.

In summary, any consultant can complete a lead-based paint or asbestos containing material survey. Understanding building systems, how demolition and renovation waste should be properly managed, and working with an architectural engineering building turnaround team requires the experience and knowledge that only a company like RT Environmental Services can provide. If you have any upcoming building demolition or reconstruction projects, we would appreciate the opportunity to be considered as part of your building redevelopment project turnaround team. Should you need further information, do not hesitate to call either Mark Irani or Gary Brown in our King of Prussia headquarters at 800-725-0593.

RT Environmental recently completed upgrading of a secondary containment facility under NJDPCC regulations, for the Woodruff Energy Company, Bridgeton, NJ. Unexpected findings during the tank secondary containment upgrading project caused the need for emergency reporting to the New Jersey Department of Environmental Protection, when a long abandoned buried municipal waste water treatment plant was found beneath a former product transfer pumping station being demolished as part of the project. Following the initial finding of floating oil product, and because of concern that the waste water treatment system was still connected to the Cohansey River caused a temporary shutdown in the secondary containment upgrading project.

Woodruff Energy Company is a home heating oil, commercial business, and service station supply distribution facility, serving southwestern New Jersey. Oil storage facilities have been present on the site on Water Street in Bridgeton, even prior to Woodruff's operations, which began at the site in 1959. Historical operations included barge product delivery and railcar product delivery, although, all oil product operations in recent decades have involved product receipt and delivery by tanker truck.

Upon finding that the buried wastewater treatment plant, immediate contacts were made with the City of Bridgeton as well as the Cumberland County Utilities Authority. It was identified that a treatment system had operated on the site from 1883 until 1927, and investigation work began immediately to determine the size and extent of the buried wastewater treatment tanks at the site. DEP expressed concern that product, or dissolved product, might be migrating to the River, through unknown pipes or, the former wastewater discharge system. Drawings showed a long discharge pipe to the middle of the river.

County utility officials were instrumental in completing an immediate record search and RT worked closely with Lynne Mitchell of the New Jersey Department of Environmental Protection Southern Field Office, as well as Tim Maguire, senior DEP hydrogeologist. We began to conduct an immediate multi-phase investigation to:

• Use data logging techniques to determine whether or not the wastewater vaults were hydraulically connected to the aquifer, or river which is tidal, and verify groundwater flow direction.
• Expeditiously determine the extent of impacted soils at the facility, as some areas of product saturated soils were found in the vicinity of the wastewater vaults, and some floating product was found in the vicinity of the oil pumping station.
• Large test trenches were also excavated horizontally parallel to the river to determine and confirm that no pipelines existed which could convey product impacted groundwater to the River.
• Influent and effluent pipes to and from the wastewater treatment vaults, as well as other pipes, including product and old, small diameter terra cotta pipes encountered during the excavation were all drained and properly grouted, so that there is no potential for further migration to the nearby River.

The New Jersey DEP considers the Cohansey River to be in need of environmental protection, because of presence of shell fish beds, in the lower part of the River, in the Delaware estuary.

The entire project was conducted expeditiously, using a team approach. RT and DEP shared investigation approaches and findings on a daily basis, following a DEP visit to the site by senior officials from the Southern Field Office. With winter approaching, the key concerns were:

• Completing the investigation project such that secondary containment lining could still be installed before cold weather arrived (HDPE selected for secondary containment cannot be installed in low temperature conditions).
• As the previous secondary containment earthen berms had to be opened for the entire project, all parties felt it important to proceed with the work expeditiously, so that the secondary containment could be put back in place.
• All expressed a desire to work closely together using a high degree of careful technical focus to reach common understandings on the specific goals and need for each investigation and remedial step, and to work quickly towards a solution.

The Project turned into a model of cooperation, meeting with full intent and spirit of the New Jersey ISRA/Brownfields law. Although many people are under the impression that the Brownfields Law only applies to contaminated, abandoned urban sites, ISRA revisions also in the law actually allow DEP to adopt flexible and appropriate standards, for petroleum release sites using a risk based corrective action process. RT worked closely together with DEP to use appropriate standards as localized areas around the waste water treatment vaults were investigated, taking into account that the area would be capped by the secondary containment liner. Also taken into account were the investigation results, the site setting, and migration potential.

Once it was demonstrated that all potential migration pathways of concern to the river had been located and successfully closed, Class II soil standards were found to be applicable, and remedial needs were focused on two particular "hot spot areas", which were expeditiously remediated by excavation and removal of soil. Soil was shipped to a regional bioremediation facility for treatment. Engineering and investigation findings, as well as lab results, and key technical findings were forwarded to DEP by fax on a daily basis and investigation and remediation of the entire tank farm/wastewater treatment area was completed in a short three weeks.

There are many people who claim that investigation and remediation at petroleum sites can be overly complicated in NJ and that it can take years to get decisions and to reach a final conclusion. The fast-track project at Woodruff Energy showed that:

• New tools available as part of NJ Brownfields initiatives can allow for a rapid, technically complete remediation work, to address areas of concerns efficiently and effectively.
• Experienced regulatory professionals working closely together, can make quick decisions, carefully focused on specific technical areas, working collaboratively to address environmental concerns.

Although some view the Technical Requirements for Site Remediation in New Jersey as unnecessarily complex, environmental professionals who clearly understand them can work closely with the DEP to make fast field decisions, even when not everything is known initially about the history of a site. Unknowns can be quickly addressed using the most appropriate engineering and hydrogeologic investigation techniques to reach proper technical conclusions quickly.

Mr. Robert Woodruff, Sr., President of Woodruff Energy, commented that the level of cooperation was remarkable, in that daily investigation and remediation work could be planned and implemented with DEP oversight so as to be both focused and efficient. The project was a model of cooperation and provides the assurance that Woodruff's main tank farm facility has been through the investigation and remediation process so that areas under the liner system, are no longer of environmental concern. Woodruff Energy is starting 1999 as one of New Jersey's first ISRA/ Brownfields success stories, wherein fresh approaches and a high level of cooperation prove that environmental work can proceed quickly, efficiently, and professionally.

We at RT salute the Southern Field Office of the New Jersey Department of Environmental Protection for its highly professional and time sensitive oversight, of this important project. Without question, many property and facility owners in New Jersey will want to take advantage of new opportunities that exist to deal with site contamination issues under the New Jersey Brownfields Law.

For more information on the New Jersey Brownfields Law and associated ISRA program revision, contact Gary Brown or Tom Brady. Tom Brady can be reached at our New Jersey office (856) 467-2276 or at TBrady@rtenvnj.com.

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RT announced another land recycling project for which it is the lead environmental firm responsible for remediation. A buyer/seller agreement has been reached under the Land Recycling Program to clean up a former transformer manufacturing site at 18th and Callowhill streets in Philadelphia. The agreement between DEP, Moreland Investments (buyer), ABB Power T&D Co. (remediator) and Franklin Town Corp (seller) provides for the cleanup of contaminated soil at the center city property.

This four-party agreement will enable Moreland Investments to take title to the property and begin business activities when RT's cleanup of the property is complete. Moreland will construct a small commercial retail building and parking lot, improving the center city landscape and providing new jobs.

DEP Southeast Regional Environmental Cleanup Program Manager Bruce Beitler said: "Sites such as these are proof positive that the Land Recycling Program works. Here is a property that remained vacant for well over a decade which is about to be developed in a job-producing environmentally safe manner."

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**Bruce Beitler, PADEP Regional Land Recycling Coordinator and Gary Brown, President of RT, discussing the recently awarded contract with a Downingtown official.**

Site History

The 22 acre site was a foundry in the 1800's and eventually became an electrical equipment repair and refurbishment facility in the middle of this century. Very large electrical generators and other equipment were present until recently, and the release of dielectric fluids caused the large industrial building at the site to become PCB contaminated. On three occasions, it became necessary for EPA to expend Superfund monies to address releases at the site. Michael Towle, EPA Remedial Project Manager, lead a team which remediated the site to commercial/industrial standards.

Risk Management

RT prepared a risk assessment review for the site to help demonstrate that contaminants which remain at the site are of limited concern. RT investigated the site and installed borings and monitoring wells to provide site-specific data to support Brownfields and Land Recycling initiatives. EPA has requested, as part of a Prospective Purchase Agreement that the floor of the building be remediated to residential standards prior to residential redevelopment.

A new surface PCB remediation technique, offered by NETC, will be used to remediate sections of the floor which are to remain at below residential standards. Other remedial needs at the site include remediation of a floor drain area and UST removal. A PADEP Land Recycling grant, and potentially, a Brownfields grant will help fund remedial activities, which are expected to take two to three months to complete. RT has already demonstrated that groundwater at the site is not impacted and a stream running through the site (Parke Run, a tributary to the Brandywine Creek) is viewed as an important asset to be worked into the redevelopment scheme for the site.

Redevelopment

Downingtown Borough supports the residential redevelopment of the site because surrounding areas are residential and the site is close to the downtown business area. The Downingtown Main Street Association, through its Director, Barry Cassidy, is actively helping to move the project forward. PADEP has reviewed the project, which is going through Pennsylvania's award winning Land Recycling Program. Bruce Beitler, PADEP's Land Recycling Coordinator, approved the project as being acceptable for an Act 2 Grant.

The majority of the site will see residential redevelopment including apartments and/or townhouses. Massive foundations from the heavy industrial buildings at the site are planned to be used as residential building foundations and/or as a base for parking lots. A developer is expected to be selected for the site shortly, and site plan and local approval processes will also be under way in the near future.

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