Vieau Associates, a division of GZA, was commissioned to assess a nearly 100-year-old active munitions manufacturing plant operating across 70 structures comprising 845,000 square feet on 187 acres and located on the periphery of a major metropolitan area posed unique challenges to the interpretive elements of a Phase I environmental site assessment following the ASTM E1527 and All Appropriate Inquiries (40 CFR Part 312) standards. Raw materials, primarily metals, are subject to smelting, extrusion, plating, drawing, annealing, fabricating, stamping, pressing and other operations governed principally by RCRA, CAA and CWA regulations. However, there were no regulations on these activities in place for approximately 75% of the facility’s operational history. Numerous releases to the environment had been reported; the Vieau team reviewed hundreds of environmental documents dating to the 1980s, addressing: 15 Master Sites (known sources of hazardous substance releases) having already undergone investigation and remediation; past and ongoing groundwater monitoring results; numerous former and current chemical and petroleum USTs; and hazardous waste generation, wastewater discharge and air emission permits.
A meaningful analysis of environmental conditions and risks associated with Superfund enforcement required us to separate de minimis conditions and Controlled Recognized Environmental Conditions warranting no further investigation, from Recognized Environmental Conditions (where further inquiry is warranted). Our expertise in RCRA compliance (hazardous waste management regulations), Clean Air Act and Clean Water Act regulations was brought to bear into our basis of opinion to support our conclusions and recommendations.
Recognizing the ramifications of our conclusions to financing and the importance of this large employer to the community, our report was subject to a high-level of outside technical and legal review and achieved the objectives of the users. Of significance was our analysis of the potential for VOC-contaminated groundwater to migrate towards residential neighborhoods and pose a risk of vapor intrusion, a risk not considered by prior investigations. Our assessment addressed Activity and Use Limitations, business environmental risks (non-CERCLA releases), dust as a potential regulated waste, and indoor air quality issues.