Recommendations on Reed Park

At last report US EPA plans to cap Reed Park and remove most of the trees. Reasons given at the public meeting on August 26, 2013 and subsequent conversations included:

It would cost money to save them.
If a tree blows down, exposing the roots, subsurface contamination would also be exposed
The roots of trees only extend 8” below the surface, and putting two feet of fill above the roots of the trees to cap the soil would deprive them of oxygen and eventually kill them
Only a few people at public meetings focused on saving the trees
Many of the trees are old
Some trees are sick or dead
Some species of trees are undesirable
Some of the trees are not structurally sound and could fall on children

Most of the above rationales could be applied to trees throughout the city, etc. As a result it looked like the government was going beyond what is reasonable to try to justify the removal of most trees from the park to try to make their removal as part of the proposed remedial action more acceptable. That approach backfired.

A previous brownfields study in the park showed concentrations of polynuclear aromatic hydrocarbons (PAH) above those acceptable for direct human contact in the fill material sampled to depths of 2’ or 4’ in most of the park. Three to six inches of grassy topsoil has been covering most of the surface of the park and subsurface fill material for about 50 years or more. Portions of the park are also covered with concrete or sand (in the baseball diamond). The topsoil was never separately sampled and analyzed to determine if it presents a significant risk from direct contact. Fungus and other microorganisms in grassy topsoil are known to destroy PAHs at a rate of 0.2% to 17% per month. Microorganisms associated with tree roots can also destroy PAHs. For details, see http://www.academia.edu/2908115/Comparison_of_Trees_and_Grasses_for....

Given the amount of time that has passed and natural removal mechanisms, it is reasonable to assume that the current surface topsoil (0-3” to 0-6”) have PAH levels at equilibrium with contaminant transport mechanisms from subsurface soil due to natural bioremediation. Until the topsoil, etc. are sampled and analyzed, no significant risk from direct contact with the soil at the surface of the park has been proven. Under the circumstances, sampling the top 3” of topsoil is needed to determine if direct contact poses a threat to public health, as alleged.

Yesterday, I spoke with Partners Environmental—the contractor that did the Phase II investigation of Reed Park (upon which US EPA has been basing its planning for remediation of Reed Park). He told me that at meetings with the City of Cleveland, the health department, attorneys, etc. Partners Environmental, informed them that Reed Park presented no immediate danger to public health. (This is in sharp contrast to what the City has been telling US EPA based on the Phase II study results) However the Phase II investigation did show a need to remove and rebury or treat contaminated subsurface fill material if excavated, where and when the City does any construction in most of the park. Partners Environmental proposed to the City of Cleveland that it provide a Remedial Action Plan (RAP) and to help with specifications and bidding for the development of the park. They were not selected. Partners Environmental still has the key staff who were responsible for the Phase II investigation, and their experience could help EPA and their contractors avoid re-inventing the wheel in the development of an appropriate remedial action plan for the Park if hired to help in this work.

Under the circumstances, it would be appropriate to consider the configuration, past use, and plans for Reed Park and nearby areas:

Divide it into appropriate operable units (including separate units for the baseball diamond, clusters of trees and major single trees in the park, areas where the City is planning construction within the park, homes on W 15 St, etc.)
Take and analyze composite surface (0-3:or 0-4” from the surface) soil samples within appropriate operable units within the park and in nearby neighborhoods (subsurface sampling in nearby neighborhoods would also be appropriate)
Determine where surface soil contamination levels are acceptable for residential land use in the park and release those areas for renewed public access and recreational land use
Use EPA emergency response funding to remediate in those operable units where there is a significant hazard if the land use remains as is
Remediate contaminated subsurface soil only
- Where surface soil contamination presents a significant risk to public health and the subsurface soil is significantly contaminated
- When and where excavation takes place in contaminated soil

For more details, see:

http://freindsofwcreedfield.ning.com/

https://www.facebook.com/events/218610251634716/permalink/218663454...

Sincerely,

Claude Lawrence Cornett, Jr.

http://cornettenv.org/resume.htm