Environmental Issues

Environmental Conditions
June 21, 2013

Weston and Sampson Engineers, Inc., (Weston & Sampson) was contracted by the City of Montpelier (City) through Stantec, Inc. to perform a Phase I Environmental Site Assessment (ESA) of the Carr Lot, located at 1 Taylor Street in Montpelier, Vermont (hereinafter referred to as “the Subject Area”). A locus map and a site plan are included as Figures 1 and 2 respectively. The Subject Area is approximately 1.16 acres and is currently utilized as a parking lot for State of Vermont employees. The City of Montpelier (City) is planning on obtaining ownership of the Subject Area and redeveloping it as a multi modal transit facility. The City has applied for acceptance into the Brownfields Reuse Initiative Environmental Liability Limitation Program (BRELLA). This Phase I ESA is required as part of the BRELLA application.

Objective
The main objective of the Phase I ESA is to identify the presence or likely historical presence of any recognized environmental conditions (RECs) or historical recognized environmental conditions (HRECs) as defined in ASTM E-1527-05: Standard Practice for Environmental Site Assessments and to satisfy the requirements of the EPA All Appropriate Inquiry Rule (AAI). The information gathered during this Phase I ESA is detailed in this report. A Phase I ESA is not intended to eliminate all uncertainty or to be exhaustive in nature. The level of data collection and review is designed to assess the environmental conditions of the real estate, taking into account commonly known and reasonably ascertainable information.

Hazardous Waste Site
The Subject Area has a long history of industrial use including many decades as a scrap yard. As a result of this use, the Subject Area is listed on the Vermont Department of Environmental Conservations (VTDEC) active hazardous waste site list as Site # 2002-3024 and is also regulated by the EPA Toxic Substances Control Act (TSCA) Program. Numerous investigations and remediation of the Subject Area has occurred and multiple reports have been generated regarding surface and subsurface environmental conditions. Many of the investigations and remedial efforts have focused on defining the extent and degree of contaminants as they relate to potential redevelopment of the property.

The investigations, remediation and reporting have been presented to and approved by the VTDEC throughout the entire process. A detailed review of each activity was not performed as part of this Phase I ESA. Select key documents summarizing Subject Area environmental activities were reviewed and have been found to contain sufficient information to generate the conclusions and recommendations contained here in. A list of reference documents is included in Section 12 of the report.

ES-2 Weston & Sampson
The contaminants identified associated with the Subject Area include polychlorinated biphenyls (PCB), metals (primarily lead), and polynuclear aromatic hydrocarbons (PAHs). Remedial efforts have included removal and disposal of PCB contaminated shallow soils and installation of a Subject Area wide cap of clean gravel. These efforts have reduced the risk of public exposure to contaminants for the current use as a parking lot. However, significant volumes of contaminated materials remain beneath the Subject Area which will require management/remediation should use of the area change.

Other uses nearby which may have environmental conditions that could impact the Subject area include 2 former auto repair garages, a retail gasoline distribution station and the rail line.

RECs Revealed
This Phase I ESA has revealed the following RECs in connection with the Subject Area:
  1. REC-1: PCBs Shallow soils throughout the Subject Area are impacted by PCB contamination. Soils with PCB concentrations above 5 parts per million have been removed from the property. The removal of these soils and capping of the area has resulted in a “Temporary Solution” allowing current use of the property to continue until December 31, 2014 unless revoked, suspended, modified, extended or terminated. A “Permanent Solution” for remediation of PCBs with the current use would involve paving of the parking lot. If any changes to the current use occur amendment to the existing Corrective Action Plan will be necessary. Special handling and disposal of any disturbed soils will be required.
  2. REC-2: Lead. Shallow soils throughout the Subject Area are impacted by several metals, primarily lead. PCB related remediation has resulted in removal of a limited amount of lead impacted soils. If any changes to the current use occur, amendment to the existing Corrective Action Plan will be necessary. Special handling and disposal of any disturbed soils will be required.
  3. REC-3: PAHs. Shallow and deep soils throughout the Subject Area are impacted by PAHs. PCB related remediation has resulted in removal of a limited amount of impacted soils. If any changes to the current use occur, amendment to the existing Corrective Action Plan will be necessary. Special handling and disposal of any disturbed soils will be required.
  4. REC-4: Contaminated Groundwater Migrating onto Site. Chlorinated solvent contamination of the groundwater in the western portion of the Subject Area exists at or slightly above Vermont Groundwater Enforcement Standards (VGES). The source of this contamination is from off-site to the north. Evaluation of the potential impact of these contaminants on redevelopment activities will be necessary if a change of use is to occur near this plume of contaminants.