Brownfields 2004, “Light or Heavy Starch: Cleaning the Cleaners” September 2004 Presented by Matt Shurtliff Roosevelt Towne Apartments

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Co-Authors oJoe Williams/National Church Residences oGene Schmittgens/Lathrop & Gage Environmental Attorney oKeith Piontek/The Forrester Group

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Roosevelt Towne Apartments oCity of St. Louis oJust north of the “Central West End” o8 story hotel built in 1928 oConverted to subsidized housing in 1982 o154 housing units

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 National Church Residences (Columbus, OH) oNot-for-profit managing over 225 affordable senior citizen and family communities oMission oProvide quality housing and care at affordable prices oSpecial concern for low- and moderate-income seniors, persons with disabilities, and low- and moderate-income families

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Environmental Site Assessments oPhase I: identified recognized environmental conditions on the hotel grounds and associated parking lot oTwo former dry cleaners oThree former service stations oPhase II: confirmed presence of constituents at concentrations exceeding State of Missouri Corrective Action Levels for Missouri (CALM) criteria

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Environmental Impairments Threaten The Deal oUncertainty on the scope of work that would be required to address the environmental conditions oUncertainties that undermine Brownfields projects: oHow long will it take to resolve it? oHow much will it cost to fix it? oCritical uncertainty – getting to regulatory closure when attainment of the groundwater cleanup standard (MCLs) is technically impracticable

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Strategy for Environmental Impairments Objectives –Reduce uncertainty –Minimize time and expenditures required Strategy Components –Missouri’s new RBCA process –Creative technical solutions –Stakeholder support

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Missouri’s New RBCA Process New, more flexible cleanup regulations on the verge of being adopted Generally consistent with the ASTM RBCA Standards Flexibility from MCLs as the groundwater cleanup standard More predictable and pragmatic path to closure

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Exposure Pathway Analysis: Groundwater Groundwater < 1,500 feet deep “not favorable” for high yield wells Public water supply principally from surface water Ordinance prohibiting installation of wells for purposes other than manufacturing No existing permitted wells within the city

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Complete Exposure Pathways Groundwater: Potentially complete for construction worker exposure (but not for groundwater ingestion). Surface Soil: Direct contact exposure potentially complete for any receptor at depths < 3 ft. Subsurface Soil: Potentially complete for construction worker. Vapor inhalation: Potentially complete for Roosevelt Towne Apartments residents.

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Additional Site Characterization Required to supplement existing site data for evaluation of two exposure pathways: Groundwater: only one onsite well from previous investigation Vapor intrusion: collection of site-specific data

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Addressing Groundwater Pathway Temporary monitoring wells to provide spatial data and flow direction. Development of site specific exposure estimates for construction worker pathway –Determined nature of utility lines –Local utility consulted to develop “reasonable worst case” exposure scenario for construction worker conducting repair below the water table.

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Addressing the Vapor Intrusion Pathway Technical approach had not yet been developed in MRBCA process. Tools that were used: oEPA Vapor Intrusion Guidance oJohnson-Ettinger modeling oVapor flux measurement

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Vapor Intrusion Assessment

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Exposure Evaluation oGroundwater: CVOC risk estimate does not exceed target risk level for construction worker. oSurface Soil: Available data show no exceedence of target risk levels. oSubsurface Soil: No exceedences of draft Missouri Tier 1 target levels. oIndoor Inhalation: Modeling and flux measurements predict indoor air concentrations below residential target risk levels.

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Success! oThe Forrester Group submitted its “creative technical solution” proposal in February oSite investigations Spring-Summer 2003 o“Conditional No Further Action (NFA) letter” issued by DNR in November 2003 (pending implementation of required institutional controls) oClosure documentation included restrictive covenants for future land use, and a soil management plan oNCR “closed the deal” in March 2004 oNFA letter issued by DNR in May 2004

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 Renovation Is Underway

Brownfields 2004, “Light or Heavy Starch” Roosevelt Towne Apartments September 2004 For Additional Information Matt Shurtliff The Forrester Group (636) (ext. 212) Gene Schmittgens Lathrop & Gage, LLP (314)