Environmental Consulting | Compliance Consulting | Regulatory Compliance | Brownfields | Berrien County | Cass County | Van Buren County | Southwestern Michigan
 
 
 
 
   
 
 
 

Brownfield Authority Work Plans - Michigan's Brownfield Redevelopment Financing Act (1996 P.A. 381, as amended) established a method to assist with financing environmental response activities at eligible (contaminated) properties. A Brownfield Authority Work Plan is a tool for local units of governments (LUGs) and developers to facilitate the implementation of eligible activities at an eligible property. Eligible activities can consist of the preparation of a Baseline Environmental Assessment, performance of response activities, and documentation of due care. For qualified LUGs, eligible activities might also include public infrastructure improvements, demolition that is not a response activity, lead or asbestos abatement, and site preparation that is not a response activity. The Work Plan presents a detailed description of eligible activities including the collection and analysis of environmental media, proposed sampling strategies, field sampling methods, decontamination procedures, recommended laboratory analysis, quality assurance/quality control procedures, a proposed schedule for completing the eligible activities, and the estimated costs for all eligible activities to be performed. Where appropriate, the Work Plan will also include a proposed schedule for property tax capture through tax incremental financing in order to reimburse eligible activities.

Project Design - Any successful project begins with thorough and sound project planning. In order to implement a successful brownfield project, sufficient time and effort must be devoted to the planning and design process. Keeping the end goal and ultimate land use in mind earlier as the planning begins, increases the designer's ability to achieve efficiency and direct the project to its successful completion. The planning and design process can begin with, and adjust in concert to, the site assessment phase. During the design process and prior to the development of project specifications, the compilation of all relevant pre-design information is performed to ensure clear understanding of the technical and overall project objectives and to facilitate the smooth transition from the site assessment phase to the development of project specifications and bidding documents. Other objectives of the project design phase are to identify and consider project constraints which can include funding, schedule, health and safety, equipment, off-site disposal, weather, permits, and community relations. The complexity of a typical brownfield project requires in-depth knowledge of a variety of technical fields including engineering, geology, chemistry, ecology and natural resources, and surveying.

Pre-Demolition Environmental Assessments - Prior to redevelopment, a Pre-Demolition Environmental Assessment is often necessary to assess a building, equipment, and the property in preparation for demolition and abatement activities at brownfield properties. The assessment activities consists of the evaluation of environmental and pre-demolition concerns including, but not limited to, the collection and laboratory analysis of environmental samples from areas where evidence of grossly affected materials are present, evaluation of potential asbestos containing material, transformers and other potentially PCB-containing equipment, equipment, discarded materials and containers, potentially hazardous materials and hazardous wastes, and other material that may require special handling during demolition operations (including contaminated soils). Results from these assessment activities identify regulated materials, hazardous materials, and all materials that may require special handling during the site preparation/demolition phase.

Universal Waste Identification - All waste streams identified during a Pre-Demolition Assessment are fully characterized either during or immediately after the project design phase (but prior to initiation of preparation of the Biddable Specifications Package) in order to evaluate proper removal, handling, and disposal requirements for each waste stream. Typical waste streams may include, but are not limited to, asbestos, hazardous soils, special waste soils, PCB-containing equipment (including light ballasts, transformers, and capacitors), light bulbs that contain mercury and lead, abandoned containers, sludges, stained concrete and wood, and mercury-containing switches.

Biddable Specifications Package - Specifications, a generic term that includes drawings, are developed during the remedial design phase and are included along with construction contract documents in the biddable specifications package. The specifications contain a detailed description of the technical and performance requirements the contractor must meet to implement the project and the criteria for determining whether those requirements are met. The specifications provide a single, legally enforceable document which presents in great detail all parties involved, contractual obligations, costs, schedules, administrative and technical details, and project requirements and deliverables. An example set of a typical brownfield redevelopment project specifications would include, but not necessarily be limited to, a description of activities for abatement, management, removal, and proper disposal of all regulated or hazardous materials identified within the building and associated structures, removal and proper disposal of all material requiring special handling (including asbestos-containing materials and contaminated soils), demolition and removal and recycling/disposal of the structure and associated foundations and equipment, removal and disposal of all underground storage tanks, if any exist, and removal and proper disposal of all contaminated liquids in structures, pits, or sumps, if any exist. Subsequently, the final bid specifications package is opened for public bids and a contractor is selected to execute the required activities.

Site Preparation/Demolition Oversight - Oversight of a contractor performing site preparation and/or demolition activities identified in the project specifications typically consists of reviewing the contractor's Health and Safety Plan, permit applications, waste profile summaries, monitoring project schedules, conducting pre-construction and weekly progress meetings, documenting field activities, preparing weekly status reports, tracking budgets and schedules, maintaining field records, providing engineering services throughout the field activities, certifying and preparing contractor invoices, and preparing as-built and record drawings after completion of demolition activities and site restoration activities.

Baseline Environmental Assessments (BEAs) - A BEA is an evaluation of an impacted property (in Michigan) that reasonably defines (at the time of purchase or occupancy) the existing environmental condition so that, in the event of a subsequent release of hazardous materials, there is a means of distinguishing the new release from existing contamination. When an acceptable BEA is disclosed to the State of Michigan, the purchaser of contaminated sites (if not responsible for the contamination) avoids further investigation and remediation liability with respect to the existing condition.

Due Care Compliance Analysis - In accordance with Section 20107a of the Natural Resources and Environmental Protection Act, owners of property who have knowledge that the site is a facility (as that term is defined in Part 201) have certain Due Care obligations. Due Care obligations pertain to issues such as avoiding exacerbation of existing impact, mitigation of unacceptable exposures, and providing notice of abandoned or discarded containers. Under the rules for compliance with Section 20107a, written documentation is required to be maintained and provided to the State of Michigan upon request.

Risk Analysis - Risk analysis is a practical approach where site conditions are evaluated for potentially completed exposure pathways, contaminant concentrations, and risk in accordance with established procedures. If an evaluation determines that site conditions exceed cleanup criteria and will not allow for the intended use of the property, potential response activities are evaluated to determine the most appropriate approach to eliminate any potentially completed pathways. After selection of the most appropriate response action for each given facility, the response action is implemented and maintained to ensure that potential pathways are not completed for potential receptors. The necessary level of response activity will vary from site to site depending on the identified risk.

 
 
 
 
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