Managing Construction on a Brownfield Site
By David J. Cameron, senior project manger and Brian E. Davis, environmental project manager; Michael Baker Corporation
Michael Baker Corporation worked with the Beaver County Board of Commissioners in Pennsylvania, managing construction of a new 402-bed detention facility designed to replace the county’s aging Civil War-era jailhouse. The site of the Beaver County Jail-the oldest operating jail in the state-did not allow for adequate expansion without incurring major expense. Thanks to a comprehensive environmental assessment program before the purchase of a brownfield site and a progressive land recycling program (Pennsylvania Act 2), the company was able to complete the new 151,000-square-foot facility on schedule and under budget.
Brownfield sites, unused and abandoned industrial sites, often are attractive properties on which to construct detention facilities although many are rife with environmental problems. Because of the special circumstances surrounding the use of these sites, there are several factors to consider before ultimately determining their feasibility.
This article discusses our experience in evaluating and building on a brownfield site and our suggestions to construction managers-and other people-considering taking on such projects.
Investigate the Site
As the construction manager for the Beaver County Jail, Michael Baker Corporation worked closely with the Board of Commissioners to determine what environmental standards the site had to meet.
We were investigating the site to determine what materials/contaminants currently were on it, could it meet environmental cleanup standards, and what were the potential environmental liabilities. Environmental liability was a major concern because inmates are thought to be among our most litigious citizens.
We reviewed more than 30 sites-a number of them rejected outright because of the degree of difficulty and cost in complying with environmental standards-before settling on a 20-acre site in Hopewell Township.
Fortunately, by working in Pennsylvania we had the Pennsylvania Land Recycling Program (Pennsylvania Act 2) providing established ground rules for various contaminants and guidelines that allowed for the development of alternatives to help move the project forward. Other states have similar guidelines so make sure those are researched thoroughly. Using the guidelines, we performed a site assessment and a human health risk assessment to determine if the site could meet state environmental cleanup standards and, therefore, release the county from any liability under the provisions of Act 2. The cleanup plan was developed once we were satisfied the site could be successfully remedied.
Get a Release of Environmental Liability
The land sales agreement was structured so the county was not obligated to complete its purchase of the property if it failed to meet the Pennsylvania Department of Environmental Protection (PADEP) Act 2 requirements for release of liability. It was only after the site assessments and cleanup plan were completed and reviewed by PADEP that the county agreed to purchase the property. In addition, the sales agreement contained specific seller covenants and indemnification language releasing the county from any environmental liability.
The site, which had two previous owners, a steel company followed by a mining company, contained primarily blast furnace slag and steel slag. While we knew the previous owners were dumping slag, we did not know what else might be deposited there. Fortunately, we discovered that there were not other major hazardous constituents on the site and that our concern was with what was leaching out of the slag and into the ground-primarily inorganic constituents.
If we had discovered organic constituents, the cleanup would have been much more time-consuming and expensive. Workers would have had to wear protective suits with respirators and take many other safety precautions.
Work Closely with State Regulators
Act 2 required that we address environmental cleanup from two standpoints: human health and ecological concerns. From the onset of the project, it helped immensely having ongoing meetings with regulatory agencies, discussing the type of investigation to conduct, the most likely areas of concern, and the possible remediation methods. It was quickly determined that we would not have trouble meeting ecological standards because there were no critical habitats involved. However, we were aware that certain inorganic constituents exceeded statewide human health standards established by Act 2.
Fortunately, state regulators are accustomed to dealing with slag because of the abundance of slag left over by the Pittsburgh steel industry. Rather than just haul the slag to another dumpsite-which would have been time consuming and expensive-we met human health standards by eliminating exposure pathways. In other words, by eliminating human exposure or contact to the contaminants of concern, we would be in compliance. The state agreed to this strategy.
The human health risk assessment evaluation determined that there should be no human contact with the soil or groundwater. The detention facility would be constructed on a concrete slab and there would be 60 feet between the inmates and the groundwater. Furthermore, the remaining portion of the property would be covered with suitable soil, buildings, and parking lots. Groundwater would not be used on the site for any purpose. Since all the possible exposure pathways could be eliminated, the site was considered to be in compliance under the site-specific standard.
The Cleanup Plan
Ultimately, the construction plan was pretty much the same as it would have been for a greenfield site, with two exceptions: we had to over-excavate the foundation of the structure to remove approximately 40,000 yards of slag material and we had to cover all areas of the site not covered by concrete or paving with one foot of top soil. The slag had to be removed because it has a tendency to expand when exposed to air and water. New soil had to be trucked in for the foundation.
We did not have to obtain additional permitting to dispose of the slag because the previous property owner who operated the mining company planned to reclaim the material. In addition, one of the bidding contractors was removing the major portion of a nearby hillside for a shopping complex so we didn’t have to incur significant costs for obtaining and transporting new fill material. We also were lucky to be working with a publicly-funded agency that brought in utilities and built the infrastructure in an effort to make the entire area more attractive for future development.
Additional Brownfield Considerations
Never cut corners: When determining what material/contaminants are on the site you need to make sure you drill a significant number of soil borings and groundwater monitoring wells. This is necessary in order to conduct appropriate testing to reasonably determine what environmental hazards are present.
Location, location, location: Just as you would in a real estate deal, locate your project on the most desirable portion of the site. In our case, the jail represented a postage stamp-sized area on a much larger piece of land. By thoroughly investigating the entire site, we were able to choose the area with the least number of environmental issues to overcome.
Be prepared to deal with the public: Under the provisions of Act 2, we had to submit a cleanup plan that was then submitted for public comment. We were required to be present to explain how environmental regulations would be met and to put human health risks in proper context for the general public. We also assisted the county in setting up and conducting public information meetings.
Keep owners informed: It is critical to keep owners involved and informed of all aspects of the job to avoid surprises and disappointments. For the first year of the project, we met bi-weekly, and at times weekly, with county commissioners. Thereafter, we met monthly to discuss progress, problems, scheduling changes, and other issues.
Planning Pays Off
Finally, by identifying the environmental issues up front, and developing a cleanup plan, we knew precisely what measures to implement in order to manage safety-both human and environmental-and more accurately plan budgets and contracts procurement and maintain our construction schedule. In fact, we brought the Beaver County jail in $4 million under budget and kept potentially expensive change orders to a minimum.
David J. Cameron is senior project manager for Michael Baker Corporation and has, during his 25-year construction career, specialized in institutional and commercial construction in both the public and private sectors. He can be reached at: dcameron@mbakercorp.com.
Brian E. Davis, P.G., is environmental project manager for the company and has more than 15 years experience in geological, hydrogeological, solid and hazardous waste investigations and has been responsible for numerous projects related to hazardous and solid waste management. He can be reached at: bdavis@mbakercorp.com.
