brown field sites & remediation - an overview
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8/7/2019 Brown Field Sites & Remediation - An Overview
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Brownfield Sites & RemediationAn Overview for
ISO 14001 Awareness Training
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Brownfield Sites & Remediation
How do we decide on a particular cleanup technology ?
Will it be approved by regulators? What will it cost?
How do we use back-of-the envelope, feasibility studyand design-quality evaluations of remediation methods?
Examples and rule-of-thumb guidelines
Managing remediation cost, uncertainty and risk inbrownfield transactions
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Environmental Remediation and CostComponents
Site investigationo Monitoring wellso Sampling and analyzing soil and groundwater
Risk assessmento Define risk posed by the contaminationo Set cleanup objects and endpoints
Engineering studies and designo Identify cleanup methods
oDesign and estimate cleanup costs Direct remediation costs
o Capital expenditureso Operating, maintenance and monitoring
Indirect costs Can equal direct project costs!o Environmental insuranceo Administrationo Contingencies
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Remediation Considerations
At what stage environmentally is the brownfield project early in thesite assessment or is remediation underway? What is the transaction framework with regard to environmental
matters?o Are you responsible for cleanup?o Seller or a third party responsible?
Single asset or a portfolio of properties
What is known about the environmental conditions at the property?
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Remeditation Considerations (cont.)
Environmental as a percentage of overall transaction sizeo The smaller the environmental costs as a proportion of the brownfield
deal the better -- becomes less of a transaction risk
Regulatory framework dictates complexity and endpointso Asbestos easy to quantify and estimateo UST sites simple, well-known cleanup methods, public trust fundso Landfills increasing complexity both environmental & geotechnicalo
State Superfund sites more requirements - potentially higher costso Federal Superfund sites minefield of obligations, usually very costly
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Contaminants at Brownfield Sites
Gasoline, oil and other petroleum products Lead (especially lead paint), arsenic and other
metals Asbestos Degreasing and cleaning solvents PCBs - transformers and light balasts Combustions products and other semi-volatile
organic compounds (SVOCs and PAHs) Radiation Radionuclides
D
ioxins and furans Explosives
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Cleanup Technologies atBrownfield Sites
Soil and sedimento Excavate and dispose and/or treat off-siteo Cap, cover or containment
o Excavate, treat via biological/physical/chemicaltreatment and reuse on-site
o In-place biological/physical/chemical treatmento Other treatment processes
Groundwatero Pump-and-treat via biological/physical/chemical
treatmento Containmento In-place biological/physical/chemical treatment
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Cleanup Technologies Institutional Controls
Single most important development forbrownfields
Environmental land use controls -- also known as institutional
controls, activity and use limitations, and environmental userestrictions
Legal and administrative measures to protect human healthand environment
Risk based - residual contamination allowed
Limit exposure by restricting activity, use, and access toproperties with residual contamination
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How to Estimate Environmental Costs
Step 1 Review the available site informationo Assessment reports, engineering feasibility studies, cleanup plans and
estimates
Step 2 Determine if there is enough info to make an estimateo If yes proceed to Step 3o If no stop or complete further assessment and then proceed
Gates -- $100,000+ site investigation Burlington -- $15,000 engineering analysis
Step 3 Build a conceptual model of the cleanup actiono For example: Remove a UST, close a landfill, clean up solvents
Step 4 Prepare a back-of-the-envelope estimateo Utilize rule-of-thumb values for the remediationo Add insurance and other transaction and response costso Add a very healthy contingency (up to +100%)
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How to Estimate Environmental Costs (cont.)
Step 5 Input environmental costs to overall transaction modelo D
etermine if the the deal works with a conservative estimateo Assess deal sensitivity to environmental are the costs a large part?
Step 6 Re-estimate environmental costso Prepare a more precise estimate -- Feasibility Study qualityo Solicit quotes for environmental insuranceo Re-assess sensitivity to environmental costs and re-evaluate as needed
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Rule of Thumb Environmental Costs
Environmental Item Description Cost Notes
Assessments, Surveys and Study Items
Phase I Site Assessment Document review and site visit $1,500 - $7,500 Set ASTM methodology
Phase II Site Assessment On-site testing soil andgroundwater
$10,000 -$100,000s
Site-specific scope
Asbestos Survey Identify asbestos and estimate
abatement costs
$2,500 - $35,000 Determined by facility size
and potential for asbestos
Engineering Feasibility Study &Detailed Cost Estimate
Estimate cleanup with + 50% to30% range
$5,000 - $50,000 Dependent on quality ofsite assessment
Cleanup and Abatement Items
Asbestos Abatement Abate asbestos in buildingmaterials
$10,000 -$1,000,000+
Remove asbestos costdepends on facility size
Leaking UST Removal andGasoline or Fuel Oil Cleanup
Remove tanks and cleanup soiland groundwater
$50,000 -$500,000
EPA estimates averageUST cleanup cost $250K.
Paid with public funds.
Landfill Closure Liner cover system, leachatecontrol and methane gas
collection
$100,000 -$200,000 peracre of landfill
Additional costs incurreddepending on site
improvements
Chlorinated solvents PERC from dry cleaning &PERC, TCE and otherdegreasing solvents
$300,000 Millions
Low end dry cleanersHigh end industrial sites
with large spills
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Managing Brownfield Remediation Risk
Risks Managed with Environmental Insuranceo
Cost Cap Insurance Cleanup cost overruns - More volume of waste, cleanup simply moreexpensive to implement, inability to get an NFA
o Pollution Legal Liability Finding unanticipated contamination Third party claims bodily injury and property damage
Low probability of occurrence, but high cost
Changes to cleanup standards Generally, standards are being relaxed Low risk
Risks retained by the brownfield investor/developero Payment of deductibles usually only a few $100,000so Insurance does not pay claimso Claims exceed insurance coverage limits
Because of insurance, environmental may be the least risky aspectof our deals!