Environmental Assessment at Raymond E. Shepherd House

ASTI managed the environmental requirements for the development of the Raymond E. Shepherd House, a multi-story building for low-income housing, in the City of Ferndale. The project was funded in part by the Michigan State Housing Development Authority (MSHDA) and a Michigan Department of Environment, Great Lakes, and Energy (EGLE) grant, and therefore, required coordination and approvals at each step by MSHDA and EGLE.

Phase I and Phase II Environmental Site Assessment (ESA) defined the property as a Part 201 “facility”. The source of contamination was historical urban fill that extended to four (4) feet below ground surface. ASTI prepared a Baseline Environmental Assessment (BEA) and filed the document on July 2021 with EGLE.

ASTI understood the client’s wishes to excavate the historical fill from the property to remove all contamination. Without due care obligations, EGLE and MSHDA agreed that the final document needed to release full funding was a No Further Action (NFA) request. ASTI prepared a Response Activity Plan – Remedial Action Plan (ResAP) for the property to eliminate exposure risks for identified relevant pathways, mainly direct contact and volatilization to indoor air (VIAP). Chemicals of concern at the site were volatile organic compounds (VOCs), polynuclear aromatic hydrocarbons (PNAs), lead, and mercury in soil. The ResAP was approved by EGLE on October 2, 2022.

While the drinking water pathway at the property is relevant, it is not complete because municipal water is supplied to the property, and no drinking water wells are located on the property. However, for NFA approval, EGLE required a restrictive covenant for the property that prohibits the installation or use of wells for consumption.

Contaminated soil at the Subject Property was removed from the property. Remedial actions conducted in 2023 consisted of excavation and offsite disposal of the soil fill on the Subject Property. ASTI collected
Verification of Soil Remediation (VSR) samples, following guidance in EGLE’s Sampling Strategies and Statistics Training Materials (S3TM) guidance.

VSR analytical data demonstrate that no contaminated soil remains on the Subject Property. The Subject Property was subsequently returned to grade with clean backfill. Historical contamination has been removed at the Subject Property, and no further actions are needed for residential usage of the Subject Property.