Ashley Capital redeveloped two former salvage yards totaling 18 acres into a state of the art 252,000 square foot freezer, warehouse, and truck terminal building for Lipari Foods, Inc.

This brownfield project was complicated by the environmental conditions associated with the long history of auto salvage use dating back to the 1940s. A variety of debris and car parts as well as releases of petroleum and lead were present across the site. A particular challenge was the lead levels in the former auto crushing and storage areas, where lead was present at levels as high as 55,000,000 ppb.

SME conducted extensive site characterization to assist Ashley Capital in developing an environmental management plan for the construction phase that complied with Michigan’s Part 201 due care obligations. Our approach consisted of several strategic rounds of a combination of test pits and soil borings to characterize the contamination and buried debris at the site.

We used an iterative approach to delineate first horizontally, then vertically, the extent of characteristically hazardous levels of lead. The results of our assessment were incorporated into the construction sequencing and logistics to minimize the cost associated with handling the lead contaminated soil.

In additional to the lead impacted soil, we also delineated the extent of petroleum contamination to support the appropriate upgrades to the site utilities and the development of health and safety protocols for the workers who would be working below grade. We also conducted hazardous materials assessments of the on-site structures prior to demolition, monitored the demolition activities, and characterized the waste generated by those activities.

A further challenge was the extensive historical fill. The fill was not suitable for support of typical shallow foundations. SME developed a foundation plan consisting of rammed aggregate piers to extend building loads through the unsuitable fill into natural soil suitable to support the building.

Although great care was taken to minimize the extent of excavation of characteristically hazardous lead, it was unavoidable in the areas of foundations and utilities. SME worked with EGLE (formerly MDEQ) to develop an acceptable regulatory approach to allow the ex-situ treatment of characteristically hazardous soil. This would allow the soil to be treated on-site to render it nonhazardous. The treated soil could then be disposed of at a nonhazardous waste (e.g. Type II) landfill at significant cost savings. SME obtained an exemption from a RCRA permit and also helped secure a grant and loan from EGLE’s Clean Michigan Initiative (CMI) program to further offset the costs.

The selected soil treatment amendment was Blastox®. This product would chemically neutralize and bind the lead contamination such that it would no longer leach above the characteristically hazardous level of 5 mg/L via the toxic characteristic leachate procedure (TCLP). We worked with the product supplier to conduct several bench tests to evaluate the appropriate dosing prior to initiating full scale implementation. This approach reduced the estimated hazardous disposal costs from $2 million to approximately $750,000. Furthermore, approximately $500,000 of that cost was covered by a grant from the CMI program and significant savings to the developer.

Other noteworthy activities consisted of characterizing the extent of contamination from a leaking underground storage tank (LUST) and conducting the environmental oversight, sampling, and documentation of its removal. We also evaluated the residual petroleum contamination and the potential for vapor intrusion and presented Ashley Capital with several options for mitigation the potential risk. The project team decided that a remedial excavation of the residual petroleum contaminated soil to unrestricted residential standards was the most cost effective solution to mitigate the risk and we conducted environmental monitoring, sampling, and documentation during the removal. Although not the liable party, the developer elected to submit a LUST closure report for the release to prevent the site from remaining on the open LUST list even though the contamination had been removed.

After completion of the building, SME conducted indoor air sampling to confirm that the residual petroleum contamination did not pose a vapor intrusion risk. We also worked with the construction team to develop a landscaping plan that would include exposure barriers to mitigate dermal contact risks associated with the lead contamination left in place. SME completed Section 7a Documentation of Due Care Compliance (DDCC) that was submitted to and approved by EGLE. The building is now complete and fully operational and has created significant new jobs.