No Further Action

by Derrick Lingle
Sep 19, 2018


Contaminated sites with a history of heavy industrial use are complex projects to remediate for future development. These properties carry significant liabilities for current and prospective owners which need to be resolved through the appropriate remedial actions and due diligence. Envirologic has performed environmental investigations and remediation for over 29 years and understands the regulatory and financial demands placed on projects with this type of use history.

Envirologic was retained by the leading North American redevelopment firm, Commercial Development Company, Inc. (CDC), which specializes in the acquisition of contaminated industrial sites and their associated environmental liabilities. Envirologic was tasked with representing CDC's environmental interest in the acquisition of the decommissioned DTE Energy power plant in Marysville, Michigan, and the associated Greenwood Oil Terminal. The 30-acre power plant complex was built in the 1920s, had reached its useful life, and was prime real estate for revitalization. This waterfront real estate sat empty until the plant was finally decommissioned in 2011 and available for sale. The 40-acre oil storage and distribution facility was constructed in the late 1970s and was supported by a deep-water port at the power plant. Although the terminal and deep-water port are not currently operating, they are still usable.

Envirologic's role was to evaluate site characterization data that had been identified through divestiture due diligence and to develop a comprehensive remedial investigation and action plan acceptable to the seller, DTE Energy, which was a condition of the sale. Envirologic presented the remedial investigation and action plan to DTE, who accepted it, thereby facilitating the final acquisition of the property.

Envirologic, on behalf of CDC, also applied for and received funding from an EPA Brownfields Assessment Grant that had been awarded to the St. Clair County Brownfield Redevelopment Authority. These grant dollars were used to help fund assessment and cleanup planning on the project site. Envirologic has helped over a dozen communities in Michigan successfully apply for and receive these important environmental assessment tools. This grant allowed CDC to begin a remedial investigation immediately, in accordance with the very limited timeframe established in the purchase agreement with DTE. After the closing of the sale, Envirologic implemented the remedial investigation in July 2014 and completed it in April 2015. The remedial action plan called for an extensive investigation of both sites, so that all areas of contamination could be defined and remedial actions could be identified.

The investigation of both sites encompassed numerous routes for contaminants to travel, which posed complex environmental challenges. The power plant sits along a major Great Lakes waterway, the St. Clair River, with one of its property boundaries adjacent to the river. Bunce Creek also traverses the property in two locations and empties into the river. When the plant was constructed, the banks of the river had to be built up to support the power plant's infrastructure, including the deep-water port. Historical photographs document that the riverbanks were filled with unknown industrial debris and that the materials were brought in from surrounding industries operating in the area. These materials posed a potential risk to the river. Other infrastructure-such as coal storage, aboveground and underground storage tanks, and oily waste basins-presented additional concerns.

The Greenwood Oil Terminal storage facility, which has over 15 million gallons of aboveground storage, sits on top of the former coal and coal ash storage area for the power plant. Bunce Creek extends onto the property and cuts through the former coal and coal ash storage areas. The oil storage terminal received fuel oil from ships off-loading at the deep-water port at the power plant. The oil was stored and eventually piped to another power plant 20 miles north. The oil storage infrastructure, combined with the previous storage of coal and coal ash, created a unique combination of contaminants in an environment not conducive for remediation.

Envirologic conducted a multimedia investigation encompassing numerous potential exposure pathways, including but not limited to contaminated groundwater discharging to surface water, drinking water, vapor intrusion, and direct contact. The investigation comprised the advancement and installation of numerous soil borings, groundwater monitoring wells, and creek pore water screens and piezometers from which soil, groundwater, and pore water samples were collected and analyzed for a myriad of contaminants. Incremental sampling methodology was also implemented at the power plant to evaluate direct contact concerns in the shallow soils. From these data, Envirologic prepared conceptual site models of both sites that presented complete and potential contaminant exposure pathways, in addition to recommendations for controlling and/or eliminating the exposure pathways through remedial action and/or administrative and engineering controls. Following the remedial investigation, more than 17,000 tons of impacted soil was excavated from both facilities.

The oil storage terminal received a site-wide No Further Action (NFA) determination from the Michigan Department of Environmental Quality on March 30, 2018. The entire power plant parcel was divided into four NFA areas based on previous site use. The power plant received the final NFA determination on June 1, 2018. As was required by DTE Energy as part of the property transaction, no post-closure plans, such as monitoring or financial assurance mechanisms, were deemed necessary for closure at either facility.

Both sites are currently marketable to prospective developers without traditional barriers (environmental and old structures) to the redevelopment of the industrial properties. The power house was demolished in November 2015, and the site was subsequently cleaned up. Currently, the power plant property is a vacant field. The City of Marysville announced a vision for a destination development that includes a hotel, retail/office space, restaurants, and a marina with pedestrian walkways. These uses will bring the community good jobs and a strong tax base long into the future.

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industrial remediation  environmental investigation  regulatory concerns  environmental liabilities  decommissioned energy plant  marysville  waterfront real estate  deep-water port  site characterization  envirologic  greeenwood oil terminal  dte power plant

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