This eBook covers how to use CSM as a tool for managing Superfund (CERCLA) and RCRA corrective action as well as in site investigations related to contaminated site transfer.
BBJ Group air quality professionals provide a full range of air quality consulting services to both major and minor sources in a variety of industries. We assist with all aspects of air quality compliance, including application development, emission inventory preparation, and air dispersion modeling. Our team is well versed in local regulations as well as federal standards such as NSPS and NESHAPS. We work with clients to develop lasting air quality solutions from initial permit applications through long-term compliance assistance.
Identifying these pertinent deal issues allows a purchaser to maximize the number of concessions at closing, such as escrow arrangements, insurance policies, indemnities, and purchase price reductions. As a result, BBJ Group's strategy minimizes left-tail risk for investors at the time of both asset acquisition and exit.
Within a month, BBJ Group completed 67 Phase I ESAs for Sears-owned retail and automotive centers located in 22 states and Puerto Rico to identify recognized environmental conditions (RECs) related to current and past business operations.
Based on the RECs identified during the Phase I ESAs, BBJ Group developed a scope of work to perform Phase II ESAs for 44 of the locations to determine the presence and extent of subsurface impacts related to the site operations. Specifically, BBJ Group performed subsurface groundwater and soil sampling to assess for impacts related to underground storage tanks, aboveground storage tanks, oil/water separators, waste neutralization tanks, underground hydraulic lifts, and automotive center floor drains. Additionally, at select sites, BBJ Group performed groundwater and soil sampling to assess for potential migration of contaminants on to Sears’ property from RECs identified on adjacent properties (i.e. drycleaners and filling stations).
All Phase II activities and reporting were completed within the client-specified timeframe, which allowed the timely sale of the properties to a REIT.
Approaches to the RCRA Corrective Action process sometimes adopt a “Penny Wise, Pound Foolish” strategy and efforts associated with early assessment phases are minimized. However, a hasty RCRA Facility Assessment results in too many open questions and poorly framed defenses, which regulators use to leverage more expensive investigations and remedies that may be necessary.
Large parts of a century-old facility were man-made, consisting of fill materials placed in Lake Michigan. Free petroleum product was present beneath parts of the site, necessitating RCRA cleanup.
BBJ Group professionals were responsible for designing and installing systems for free product recovery. Within six months, free product in an area impacted by heavy fuel was reduced from 1.5 feet thick on the water table to only a sheen.
By completing site investigations, potential real estate purchasers and sellers are able to ascertain the environmental quality and “as-is” value of the property. As a core competency, BBJ Group has a strong background in collecting and evaluating the environmental data needed to develop opinions of cost to address environmental impairments.
BBJ Group managed the cleanup of a former glass manufacturing site within the New Jersey Department of Environmental Protection (NJDEP) Industrial Site Recovery Act (ISRA) program. Before BBJ Group’s involvement, progress was stalled after years of disjointed investigations. BBJ Group implemented an aggressive site-wide approach to move the cleanup forward by (1) properly identifying areas of concern through consolidation of historical information with new soil, groundwater, and vapor sampling data, and (2) designing remedial actions that met ISRA requirements while reducing overall project costs.
State agencies often have jurisdiction supplementing federal authority for cleanup of contaminated groundwater, surface water soil, and other media. To meet state and local requirements, BBJ Group professionals have investigated and restored more than 1,000 contaminated sites in North America.