Delisting a Site from Hazardous Site Inventory
Clearing Environmental Hurdles for Redeveloping a Legacy Solvent-impacted Site
In preparing a property for critical infrastructure redevelopment, time was of the essence for a new site owner requiring the seller to address legacy environmental liabilities at a former bulk liquid transportation facility in Savannah, Georgia. The liabilities involve multimedia environmental impacts from historical solvent releases. The new site owner had acquired the property, understanding that the pre-existing environmental conditions would be cleared within a specified time frame. Because the seller could not complete the environmental tasks within the agreed time specified in the sale document, the new owner could not utilize the property for its critical infrastructure expansion, triggering a lawsuit against the seller.
The seller retained EIC to develop and implement an accelerated plan to address legacy liabilities. Utilizing the Georgia Voluntary Remediation Program (VRP) provisions, EIC developed a unique environmental approach satisfactory to the new site owner and the Georgia Environmental Protection Division (EPD). EIC’s approach entailed hot spot removal of impacted soil source material from the vadose zone. EIC performed spatial and temporal analysis to demonstrate that the contaminant plume was stable and shrinking and proposed Type 5 Risk Reduction Standards (RRS) to address the residual groundwater impacts with Uniform Environmental Covenants (UEC). After EPD approval, the new site owner could redevelop the property in time for its critical infrastructure. Recently, the EPD removed the site from its hazardous site inventory (HSI), and the new site owner dismissed the lawsuit.