Options & Tools Available in Addressing Historical Site Contamination Issues

Once you have documented your property is contaminated, what are your options? Once you receive that Phase II Investigation report that shows your property has some contamination issues, don’t panic yet. Everyone has heard the horror stories about millions spent on cleaning up site contamination that occurred half a century ago. Fortunately, we have come a long way in understanding behavior, fate and transport of chemicals in the environment.  Additionally, site cleanup decisions are almost entirely risk-based, meaning contaminated soil does not need to be remediated to background conditions, and groundwater does not always require treatment to potable water standards. In Texas, most contaminated sites are subject to the technical regulations under the Texas Risk Reduction Program (TRRP) or the Petroleum Storage Tank (PST) rules. Both of these programs have evolved in pragmatic ways to rely heavily on evaluating individual exposure pathways and requiring response actions only for those pathways
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W&M Closes Contaminated Houston Site Through MSD

W&M conducted a soil removal response action for a contaminated property and detected total petroleum hydrocarbons (TPH) in the C12-C28 boiling point range at concentrations in exceedance of the Texas Commission on Environmental Quality (TCEQ) Texas Risk Reduction Program (TRRP) residential assessment level (RAL).

Remediation and VCP Closure of Gun Range

The Tri-City Firing Range, located in Plano, Texas (Site), has been utilized for police officer training purposes since its construction in the 1980s. Lead was identified in the soil on the property and sediments of an adjacent creek bed. W&M entered the Site into the TCEQ VCP, conducted soil and groundwater sampling to delineate the impact, developed the required VCP documents, completed limited soil excavation and off-Site disposal, and received final closure through the VCP.

On-Site sampling identified shallow surface soil impacts and only limited impacts to the sediment in the creek. No groundwater impact was identified at the Site. Once the Site was delineated, W&M developed a Response Action Plan (RAP) that was approved by the TCEQ and quickly completed by excavation and off-Site diposal. W&M determined that the Site could be closed under Remedy Standard A with and alternative cleanup level utilizing a transport model to verify determine a Tier 2 Protective concentration Level and thereby increasing the cleanup level from 15 mg/kg (State background for soil lead) to 500 mg/kg. This process allowed W&M to perform less remediation and, thereby, substantially decrease the remediation costs associated with this project. The project was completed on-schedule and on-budget even when additional tasks were requested by the City of Plano.

MSD for South Dallas Property

W&M was contacted by the City to assist a community non-profit organization with the environmental closure of a solvent plume originating from an historic dry cleaner on the property. The Grand Plaza Shopping Center located on Grand Avenue in Dallas, Texas has been the subject of extensive investigations and testing, including Brownfields Assessment Grants and a vapor intrusion study under EPA’s Superfund Innovative Technology Evaluation (SITE) program.

The City offered technical guidance to assist ICDC with the preparation of an application for a Municipal Setting Designation (MSD) to remove the groundwater ingestion pathway associated with the groundwater plume. An MSD process involves providing technical and location information to the City of Dallas and the TCEQ to demonstrate that there is no potable use of groundwater in the Site vicinity, and therefore that cleanup of groundwater to drinking water standards or other ingestion pathways is not required. W&M completed the CIty of Dallas MSD application, public meeting/City council hearing, TCEQ application, and final closure documation for this Site.

Environmental Services for TCCD Downtown Fort Worth

W&M conducted Phase I ESAs and Phase II investigations of several properties owned by various industries, including TXU Energy Company in Fort Worth, Tarrant County, Texas. The properties are located in an area being redeveloped by the Tarrant County College District (TCCD) for their downtown campus. The area is heavily developed with a number of industries and potential sources of contamination including several landfills, two power plants, a lead smelter, former gasoline stations and a residential community. The TCCD campus is considered an anchor for the downtown redevelopment project known as the Trinity River Vision.

The Phase I and Phase II ESAs indicated that the Site had been impacted by VOCs and metals. As a result, W&M completed the Innocent Owner/Operator Programs (IOP) application, conducted soil and groundwater sampling, worked with the TCEQ case coordinator, and completed the IOP report documentation (namely the Site Investigation Report or SIR). The sampling and data evaluation by W&M clearly demonstrated to the TCEQ that the Site had not "caused or contributed" to the contamination and the Site was subsequently granted Innocent Owner Certificates (IOC) for several properties. Other contaminated properties were granted closure through the VCP after submitting the appropriate Affected Property Assessment Reports (APARs) and conducting additional investigation or remediation.

The Sites were issued the appropriate regulatory closure certificates and the properties are currently undergoing development. The downtown campus and the Trinity River Vision are considered very important developments for the future of downtown Fort Worth. The project was completed in a timely manner and within the proposed budget. W&M’s expertise with the TCEQ at similar IOP and VCP sites was very helpful in the successful completion of this project.

Burlwood, LLC

W&M Brownfields assisted investors in the acquisition of a contaminated property in downtown Dallas, through a limited liability corporation, at a discounted price. A Municipal Setting Designation (MSD) application and other environmental services were provided to the investors in return for equity in the property. The property was leased to a neighboring manufacturer to provide income to the investors while awaiting full regulatory closure. This property is currently for sale.

Dallas Housing Authority

The W&M staff has worked with the DHA to remove a leaking PST, evaluate paint samples for lead-based paint (LBP), conduct Phase II Investigations, and evaluate/close site through the TCEQ VCP. W&M is currently working with the DHA to close their maintenance facility through the TCEQ VCP. The facility was impacted with an on-site leaking PST (LPST) and off-site chlorinated solvents (co-mingled plume). W&M has also worked with DHA to assess and remediate their former Superfund site.


W&M has a long history of working with AT&T on a wide range of projects dating back to 1998. Our work with AT&T has included Phase I ESAs, Phase II Investigations, removal of PSTs, closure of LPSTs through the TCEQ PST program (reimbursable and non-reimbursable sites), site remediation, and use of soil vapor extraction (SVE) as a treatment method. W&M has successfully worked with AT&T to become one of their prime contractors in Texas and surrounding states.

Greenway Investment Co.

W&M has had a long-term relationship with Greenway (local real estate developer) to perform a wide range of environmental projects including Phase I ESAs, Phase II Investigations, asbestos inspections, remediation projects, and site closures through the TCEQ VCP and Innocent Owner Program (IOP). Our work has included several challenging sites such as the former Exide battery facility on Motor Street (part of City of Dallas Brownfields project), former Alcatel facility in Richardson, and Gaston Avenue property (former dry cleaners that was granted a Municipal Setting Designation [MSD] by the City of Dallas). The MSD was utilized to close the site without long-term and very expensive groundwater remediation. W&M designed the response actions at this site and assisted the client with bidding support and contractor selection. W&M has closed a number of Greenway sites.

Dallas County

Our staff worked with Dallas County District #6 to address contaminated soil along Interstate IH-30 in Balch Springs, Texas. The subject property was adjacent to a gasoline service station and had been impacted with petroleum hydrocarbons. The impact had stopped development of a planned subdivision and specifically the utilities along the highway access road. W&M conducted Phase II sampling at the site, designed plans and specifications for modifications to the buried utilizes, and provided general consulting services to Dallas County to complete this project.