HomeMy WebLinkAboutSupporting Documentation - 03/31/2025
NATIONAL INSPECTION SERVICES
Commercial and Environmental Due Diligence
PO Box 270774 | Fort Collins, CO 80527 | (970) 482-1976 | e-mail: info@nationalinspection.net | www.nationalinspection.net
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March 31, 2025 Mr. Colin Vito Mountain 300 LLC 262 E. Mountain Avenue Fort Collins, CO 80524
Work Plan for Underground Storage Tank (UST) Investigation and Removal
300 East Mountain Avenue, Fort Collins, CO
This work plan provides the details for the investigation and removal a potential underground storage tank (UST) located at 300 E Mountain Avenue in Fort Collins, Colorado (Site). A potential UST was recently discovered during drilling activities near the southwest portion of the Site. In addition, a UST is presumably located within the City of Fort Collins sidewalks, located immediately adjacent to the south of the (Site). This work plan outlines the site background and environmental conditions, the scope of work to be conducted for the removal of the UST(s), and discussion of any remedial measure required to manage the tank, associated contaminated soils or groundwater, if encountered. All City of Fort Collins required contractor licensing, permits, and traffic control measures will be obtained prior to commencing any work. National Inspection Services is prepared to assist in performing the assessment of the tank statuses and removal, assessment of the environmental conditions around the tanks, site restoration and closure in compliance with the Colorado Petroleum Storage Tank Regulations. Sincerely, Noah M. D’Antonio, President National Inspection Services
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Table of Contents 1.0 Site Background and Environmental Conditions ........................................................................................................................ 3 2.0 Project Understanding ........................................................................................................................................................................... 3 3.0 Scope of Work ............................................................................................................................................................................................ 4 3.1 Pre-removal Activities: ..................................................................................................................................................................... 4 3.2 Site Preparation & UST Removal .................................................................................................................................................. 4 3.3 Potentially Impacted Soils/Groundwater ................................................................................................................................. 5 3.4 Confirmation Sampling ..................................................................................................................................................................... 6 3.5 Site Restoration .................................................................................................................................................................................... 6 4.0 Tank Removal Documentation ........................................................................................................................................................... 6 5.0 Schedule ....................................................................................................................................................................................................... 7
Attachments: Figures Historical Site Documentation Statement of Qualifications
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1.0 Site Background and Environmental Conditions As part of a Corrective Action Plan (CAP) a potential underground storage tank (UST) was identified in a 1917 fire insurance map. The tank was depicted to the south of the 300 E Mountain Avenue property within the City of Fort Collins-owned sidewalk. As part of a limited Phase II Environmental Site Assessment (ESA) conducted for the Site, on November 28, 2023, a ground penetrating radar (GPR) survey was completed to investigate the absence or presence of this tank. This survey identified a reaction resembling a possible UST located below the sidewalk adjacent to the south of the Site in the approximate location of the tank depicted on the 1917 fire insurance map. Historical documentation regarding the potential tank is attached. A Site map depicting the site conditions and anticipated location of the tank is included as Figure 1. Two additional GPR surveys have since been conducted at the Site neither of which could successfully reproduce the findings of the original GPR. Therefore, the status of the UST system, including size, contents and closure is unknown. This potential UST has also been identified as a potential point source of tetrachloroethene (PCE) contamination in groundwater. As part of the CAP, monitoring well PMW-2R was completed in a presumed down-gradient position in close proximity to this potential UST. This monitoring well (PMW-2R) detected high levels of PCE, potentially associated with a release from the UST system. Recently, on March 21, 2025, a second potential UST was encountered during the drilling activities. This potential UST was encountered on the southwest portion of the Site at approximately 6 feet below ground surface.
2.0 Project Understanding This UST removal(s) will be performed in accordance with generally accepted professional practices as related to the nature of the work accomplished, at the time services are performed. The objective is to locate, remove and provide an assessment regarding the environmental conditions near the tank(s), if present. Investigating and removing the tank(s) prior to site redevelopment will help prevent any delays in the startup of the Site redevelopment and disturbance of the tank(s) during subsurface work in the area. National Inspection Services will provide field personnel, monitoring equipment, materials and field management to assist with the proper removal and documentation of the tank(s). National Inspection Services will manage this project in a manner to assist the Client with the closure of the issue. The intent of the above work is to assist the owner with the tank removal and to make sure the removal and disposal are performed in a manner that is compliant with local and state requirements for such work. Based on the known environmental conditions present at the Site, NIS will coordinate all efforts in communication with the CDPHE and City of Fort Collins.
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3.0 Scope of Work The following scope of work will be completed to achieve these objectives: 3.1 Pre-removal Activities:
• A meeting will be scheduled with the City of Fort Collins engineers and other representatives to discuss the scope of the project including the history and ownership of the tank, assumed location, required permitting, site restoration and procedures.
• National Inspection Services will obtain all necessary right-of-way and traffic control permits for the removal activities.
• National Inspection Services will communicate with OPS staff to review planned activities prior to the tank removal.
• Preparation and administration of 10-Day Notice to Remove Tanks and notice to Permanently Close Tanks. Obtain a permit from the Poudre Fire Authority to remove the tank.
• A pre-removal meeting will be held at the site with the contractor and City representatives to assure that the procedures and requirements are understood. 3.2 Site Preparation & UST Removal
• Prior to any intrusive activities at the Site, the locations of underground utilities in the investigation area will be assessed using both a public and private utility locate. Additional information regarding site utilities will also be reviewed.
• The concrete sidewalk will be saw cut and removed to access the tank. All concrete will be recycled and documented.
• Soil will be removed using an excavator to expose the top of the tank which will then be cleared off using hand tools.
• The Site will be managed under a soils management plan (SMP). All excavated soils will be managed in accordance with the SMP, which will include �ield screening soil for non-speci�ic volatile organic compounds (VOCs) using a photoionization detector (PID). Visually impacted soils and soils that register above 50 parts per million (ppm) on the PID will be removed and stockpiled on plastic sheeting for characterization prior to disposal. Protocol for handling of potentially impacted soils is discussed in detail below.
• It is unknown if the tank contains product. Prior to removal of the tank, any remaining product will be sampled and analyzed for Toxicity Characteristic Leaching Procedure (TCLP) VOCs, TCLP Resource Conservation and Recovery Act (RCRA) 8 metals, and polychlorinated biphenyls (PCB) screen. The contents will be pumped from the tank and
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disposed of at a certified disposal facility. This activity will be documented with a waste manifest and field notes.
• Based on local soil and groundwater data collected during the CAP, it appears the tank may be a potential source of chlorinated solvent contamination and could potentially contain spent solvents from the former dry cleaning operations therefore, once the tank is pumped, additional sampling of the product may be required by the pumping contractor for disposal purposes.
• Once the tank is determined to be empty, NIS will excavate and prepare the tank for transportation to a disposal facility. The tank will be recycled and a certificate of destruction will be obtained.
• If the tank does contain product, depending on the type of product, prior to removal, dry ice will be utilized to purge explosive gases from the tank. Dry ice will be continuously added until vapor readings within the tank are at 10% or less of the lower explosive limit (LEL) or less than 5% oxygen, as measured using a multi-gas meter. The tank opening will be secured and the tank vented above the tank to safely vent the fumes. After the tank is inert, the tank and piping will be removed from the ground and transported off-site for recycling or disposal. 3.3 Potentially Impacted Soils/Groundwater
• After the tank(s) and any associated product lines have been removed, the soils will be �ield screened for non-speci�ic volatile organic compounds (VOCs) using a photoionization detector (PID). Visually impacted soils and soils that registered above 50 ppm on the PID will be removed and stockpiled on plastic sheeting or in a lined roll off container for characterization prior to disposal. All stockpiled soils will be disposed of off-site based on CDPHE guidelines under the approved SMP.
• It is assumed no more than 20 yards of soils will be loaded and transported off-site for disposal. The actual volume will depend on site conditions.
• Soils that are encountered and segregated will require additional sampling and analysis in order to obtain approval from the CDPHE and Waste Management for disposal. Stockpiled soils will be stored in a lined dumpster on the site or other approved location while waiting for disposal approval.
• If the soils are deemed hazardous, additional transportation and disposal requirements will be needed to meet CDPHE requirements.
• If groundwater is encountered during excavation, a sample will be collected and analyzed for constituents based on OPS requirements.
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3.4 Confirmation Sampling
• National Inspection Services will collect a minimum of three (3) samples from the tank excavation(s) and submit for laboratory analysis. Soil samples will be analyzed for the following: - VOCs by U.S. EPA Method 8260B; - RCRA 8 Metals U.S. EPA Methods 1311/6010/7470; - Total petroleum hydrocarbons (TPH) diesel range organics (DRO) U.S. EPA Method 8015; - TPH gasoline range organics (GRO) U.S. EPA Method 8260B; - If elevated levels of TPH (above 500 mg/kg) are encountered, additional analysis of polycyclic aromatic hydrocarbons (PAHs) U.S. EPA Method 8270 will be performed. Additional soil and/or groundwater sampling may be required based on the contents of the tank(s), potential releases or other environmental factors determined at the time of the excavation. 3.5 Site Restoration
• National Inspection Services will manage the restoration of the site, including the import, placement and compaction of clean �ill. Following the back�ill and compaction, the site will be restored by the General Contractor as part of the redevelopment activities.
• Based on our conversation with the City of Fort Collins, since the site will be redeveloped, the concrete panels that are removed will only require temporary concrete restoration efforts and do not need to meet construction standards.
4.0 Tank Removal Documentation Field Records - A record of the sampling event will be kept in a dedicated �ield notebook for the site and will include �ield observations and �ield notes. UST Closure Report - A report will be prepared to document the project. The report will include a summary of the tank removal activities, con�irmation sampling data, disposal documentation, a photographic log of the removal and subsurface conditions, and other key information. The documentation will be submitted to the OPS with a goal of achieving a No Further Action (NFA) determination from the state. The NFA is written con�irmation from the OPS that we have completed the project in accordance with the applicable regulations and no additional efforts are required.
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5.0 Schedule The tank removal(s) will be coordinated with the City of Fort Collins and the client. National Inspection Services will submit the 10-Day Notice to Remove Tanks and notice to Permanently Close Tanks and obtain the necessary permits from the Poudre Fire Authority and City of Fort Collins to remove the tank. We anticipate no more than two days to complete the tank removal and associated confirmation sampling activities. An UST Closure Report will be submitted within 30-days of receiving the analytical data from the laboratory.
Facility Layout SCALE: 1” ~ 65 FEET
300 E Mountain Ave.
Fort Collins, CO
National Inspection Services POB 270774 Fort Collins, CO 80527-0774 Phone 970.482.1976
www.nationalinspection.net
Telecom
Electric
Water
INFERRED
GROUNDWATER
FLOW
Sewer scanned by
GPR – not able to
camera scope.
Potential
USTs
300 E Mountain Ave., Fort Collins, CO
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Potential Tanks
STATEMENT OF QUALIFICATIONS
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Joseph W. Aiken
office: (970) 482-1976 | e-mail: aikco@aol.com
Summary
Mr. Aiken has 35 years of management and technical experience in the assessment and remediation
of Brownfields and other environmentally impaired real estate. He has extensive experience with
redevelopment of these types of properties, including managing the environmental elements of the
redevelopment of the former Lowry Air Force Base and the former General Chemical site in Denver
(winner of the 2012 USEA Phoenix Award for excellence in Brownfield redevelopment). Mr. Aiken’s
expertise includes integration of environmental cleanup with redevelopment; environmental
investigation and selection of remedial technologies to best address site conditions; remedial cost
estimation; and, modeling of liabilities/costs to obtain environmental insurance and negotiate
environmental liability transfer programs.
Mr. Aiken has been involved with preparing property inventories for numerous real estate portfolios
and with assessing the environmental risks and remedial options associated with the properties. Mr.
Aiken also has substantial experience with the management of complex environmental cleanup
programs, including regulatory negotiations to achieve environmental closure related to
contaminants such as metals, asbestos, petroleum contamination, groundwater impacted by
chlorinated solvents, radiological issues, and other contaminants. He has extensive experience with
public interactions and has been involved with hundreds of public meetings related to real estate
with environmental contamination. Mr. Aiken also currently holds a Colorado Real Estate Broker
license.
Mr. Aiken has received a patent for an innovative remediation technology for the in-situ treatment of
chlorinated solvents and has worked as an expert witness on a case associated with a historic landfill
that was discovered on a property after a property transfer. Specific technical experience includes
remedial design; evaluation and development of environmental remedies including treatability
studies, feasibility studies, and development of environmental technologies; and remedial cost
estimation and quantification of environmental liabilities for real property. He has managed project
teams and subcontractors, managed large remedial programs (in excess of $30 MM), and he has
extensive experience with RCRA, CERCLA, UST, and Voluntary Cleanup Programs.
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Current Activity
JA Environmental Consulting, LLC 2013 – Present
General Manager
National Inspection Services, LLC
Environmental Manager
Mr. Aiken started a private consulting firm specializing in environmentally-impaired property and
he works with National Inspection Services as their Environmental Manager. Mr. Aiken is a Colorado
Division of Oil and Public Safety (OPS) Recognized Environmental Professional (REP No. 61) and is a
Colorado Real Estate Broker (inactive license). He is using the real estate license to network within
the real estate community and to interact with owners of real property who have environmental
issues.
Activities Mr. Aiken is involved with include evaluation of environmental issues associated with
environmental property impairments, development of cost estimates used to quantify the
environmental liabilities associated with various types of environmental issues; evaluation of
remedial technologies for property cleanup; interactions with city councils, city employees,
regulatory agencies, and the public; and the oversight of assessment and remedial actions. Several of
the key projects Mr. Aiken is or was involved with include the following:
Transaction Consulting/Investigation/Remediation, Confidential Brownfield
Property, Fort Collins, Colorado. A 20-acre property that was used for manufacturing for
over 70 years was recently sold and is being redeveloped as a medical campus. During the
property transfer, environmental impacts from metals, solvents, and petroleum were
discovered. Mr. Aiken assisted the seller with the property transaction including site
investigation, the estimation of environmental mitigation costs, providing advice regarding
the remedial action approach, and managing the remediation and closure process. Mr. Aiken
prepared and negotiated a Colorado Voluntary Cleanup Program (VCP) application, assuring
that the program qualifies for the Colorado Brownfield Tax Credit program. Mr. Aiken
managed the additional investigation required under the VCP and implemented groundwater
remediation including source removal, in-situ bioremediation of plume using Emulsified
Vegetable Oil (EVO) to stimulate anaerobic biotransformation, and natural attenuation
monitoring.
Decommissioning of Gasoline Station, Fort Collins, Colorado. Provided all services to
decommission an abandoned gasoline station as part of a liability assumption program. The
gas station was under a purchase and sale agreement to an interested corporate party, but
the corporate standards prevented the party from purchasing land that was contaminated. J.
Aiken assisted a third-party investor with a liability assumption approach whereby the third
party purchased the property with a promise to sell it to the corporate buyer once an NAD
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was obtained from the state regulators. J. Aiken developed the cost estimated and scope of
work that allowed the transaction to occur, performed remediation and decommissioning
activities, including demolition of all structures, site investigation, tank removal, and soil
removal, and ongoing monitoring. Mr. Aiken prepared the closure documentation and
obtained regulatory closure for the site; in addition, Mr. Aiken prepared the documentation
required to obtain reimbursement for remedial activities from the state underground tank
fund.
Brownfield Consulting - City of Aurora, Colorado. Provided consulting services to a
municipality with respect to an 8-acre brownfield property that was vacant for over 30 years
and was impacted by asbestos, chlorinated solvents, and petroleum issues. Provided a
historical review of the site environmental conditions, remedial cost estimates, assessment
of the environmental risk, and advice regarding the structure of the transaction. Mr. Aiken
met with the property seller and his consultants, reviewed available information for the site,
and worked with the City Manager, his staff and the City Council to evaluate a fair purchase
price, the contractual indemnities that minimized risk to the City for the remediation,
asbestos abatement, demolition and other environmental issues for the site, and assisted
with obtaining insurance coverage for the property. Also provided oversight of the site
abatement and demolition.
Transaction Consulting, Fort Collins, Colorado. Provided consulting services for a
confidential property transaction associated with a shopping center that was the location of
two former dry cleaning operations. Groundwater impacts were present and the site was
under a remediation and monitoring program. Services included negotiation of ongoing
scope and approach with CDPHE, discussions with the buyer’s environmental consultant
regarding future cleanup scope and approach, and assessment of closure using the Low
Threat Closure approach. Also worked with the Johnson-Ettinger model and field data to
address potential indoor air issues. Currently preparing an in-situ treatment plan using
emulsified vegetable oil to stimulate anaerobic biodegradation of solvents in groundwater.
WDEQ Orphan Site Dry Cleaner Program, Wyoming. Provided consulting services
associated with the assessment of chlorinated solvents and petroleum issues at a number of
properties in Sheridan, Wyoming. Activities include oversight of site assessment using the
Color-Tec rapid assessment tool and more conventional investigation methods, the
assessment of risk using the Johnson-Ettinger model to assess indoor air risk, and the
development of a remedial options evaluation.
Table Mountain Research Center, Golden, Colorado. Currently serving on the Board of
Directors for a Brownfield property. The TMRC was used from the early 1950s as a mineral
processing research and development center and the property is impacted primarily with
chlorinated solvents, uranium, yttrium, and other constituents. TMRC is a non-profit
organization that has been trying to sell the property to a developer for reuse for several
years. Mr. Aiken has provided his expertise to the TMRC Board specifically in the areas of
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environmentally-impaired real transactions, the radioactive site assessment and termination
of the radioactive materials license, valuation of environmental liabilities, and with the
development of effective remedial approaches. He is currently assisting TMRC with finalizing
a sale to a new owner and with the preparation and implementation of a VCP to address
tailing liabilities.
Phase I Environmental Site Assessments - Confidential Commercial Client, Centennial,
Colorado. Managed the preparation of 45 Phase I Environmental Site Assessments as part of
a refinancing effort for a commercial client. The sites were all gasoline stations/convenience
stores that were located in Colorado and Nebraska. Many of the sites were in corrective action
programs associated with historical petroleum releases.
Miscellaneous Development Partners. Actively working with numerous property
development companies to locate, identify, assess, and acquire environmentally-impaired
real estate. Sites include former dry cleaner properties, former manufacturing sites, and
properties impacted with asbestos.
Recent Employment History (2004-2013)
International Risk Group, LLC 2004 - 2013
Manager of IRG Assumptions, LLC
Mr. Aiken managed all aspects of business acquisition and program execution for environmental
liability transfer and assumption projects. The International Risk Group was a Brownfield developer
and specialized in the acquisition, cleanup, and redevelopment of environmentally-impaired
properties, including individual sites and portfolios of properties. Activities included development of
potential clients and partners, preparing property inventories and environmental risk profiles,
selection of remedial approach and development of remedial budgets, participation in the
negotiation of contracts and insurance products used in the liability assumption/transfer projects,
and the management of IRG internal staff and outside contractors. Key project work is described
below:
Privatized Cleanup of the Former Lowry Air Force Base (Groundwater/Landfill). Lead
the acquisition of the first environmental privatization project for the U.S. Air Force, and
managed Lowry Assumption, LLC (LAC), an affiliated IRG special purpose entity, at the former
Lowry Air Force Base in Denver and Aurora Colorado. Initiated in 2002, the program scope
included the closure of a landfill, the cleanup of a 3.5-mile long chlorinated solvent plume,
and other environmental liabilities associated with the base operations. The liabilities were
transferred from the Air Force to Lowry Assumption for approximately $40 million. The
program was insured using a cost cap insurance policy, as well as a pollution and legal liability
policy. Mr. Aiken was involved with strategic planning of the environmental program,
integrating cleanup activities with the redevelopment, the completion of site investigation
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activities, selection of the technologies employed, and managing the regulatory and project
execution elements. Project activities included groundwater investigation, treatability
studies, chemical injection, groundwater monitoring, database management, risk
assessment, negotiation of cleanup objectives, extensive public interaction, and closure
documentation activities. The project included the preparation of a closure plan and the
successful capping/closure of an 80-acre former landfill at the site, as well as the onsite and
offsite remediation of the groundwater plume. CDPHE determined in 2012 that the cleanup
had achieved concentrations that are protective of human health and the environment. Mr.
Aiken also initiated the process of obtaining a Site Specific Standard from CDPHE for final
closure of the site.
Privatized Cleanup of the Former Lowry Air Force Base (Soils). Mr. Aiken was
instrumental in the successful acquisition of additional scope to the initial environmental
privatization at Lowry mentioned above. Following the success of the first phase of
privatization at Lowry, the Air Force requested that IRG develop a privatized program for soil
issues at Lowry. This program was initiated in late 2005 and is also insured with cost cap and
PLL policies. The value of this project add-on was $30 million. Mr. Aiken was involved with
investigation activities for asbestos in soils, PCBs, dioxin, radionuclides, petroleum and other
constituents. He was also involved with selection of remedial approaches and
implementation of remediation for asbestos in soils, lead in soils, petroleum in soils, and
other conditions. Project included building demolition, soil remediation, and interaction with
the regulatory agency to achieve closure at the site. To date, 28 No Further Action (NFA)
letters have been issued by CDPHE to close out major issues at the former base. Mr. Aiken
also managed the preparation of a CDPHE-approved Soils Management Plan (SMP) for the
site and the extensive construction oversight and remedial response, as necessary, in
implementing the SMP.
Redevelopment Services - Lowry. Involved with the redevelopment of environmentally
impaired property at Lowry. IRG purchased several parcels of property at Lowry as an
outcome of the second phase of privatization. One parcel, the former Building 667 was
impacted by asbestos in soils and has been successfully cleaned and redeveloped into
approximately 50 single family homes. The other parcel, a closed former landfill, is currently
being prepared for development by IRG and their partners. Mr. Aiken was involved with
planning, extensive public interactions, cost estimation of the infrastructure and
environmental considerations, interactions with regulatory and Air Force environmental
decision makers, permitting, and site preparation activities for redevelopment of the former
landfill.
Acquisition and Closure of Nine Former Chemical Properties (Swiss North American
Properties). Participated in the development and negotiation for a property and liability
transfer where IRG took title to nine former chemical properties, as well as the contractual
responsibility to bring all facilities to environmental closure. Initial activities included the
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preparation of a property inventory for 23 sites ranging from chemical manufacturing plants
to formulation and distribution centers. This was followed by assessment of environmental
conditions for the properties and the estimation of environmental cleanup costs for each of
the properties. The inventory process resulted in 9 properties being selected for transfer as
part of an impaired-property real estate portfolio. Funding sources for closure activities came
partially from the former owner and partially through the sale of properties. Mr. Aiken was
involved with the selection and investigation of these sites, selection of the remediation
technology for the sites, and managing the implementation of the remedies. The sites
included cleanup of chlorinated solvents in groundwater and soil, petroleum issues, and
asbestos. To date, all of the properties have been granted NFAs and/or are environmentally
closed and have been sold.
Private-Public Partnership and 2011 Phoenix Award Winner (General
Chemical/Denver). Managed the cleanup of a former smelter/chemical manufacturing plant
in Denver, Colorado. IRG took ownership of a 34 acre property in Denver along with the
responsibility to perform a Voluntary Cleanup Program at the site. Mr. Aiken was responsible
for developing a remedial action plan for the site and integrating that plan with the site
preparation activities for the future development (including the design and construction of a
major storm water outfall into the South Platte River). He was responsible for managing
demolition, groundwater treatment and monitoring, soil excavation, capping, and closure
documentation. The cleanup included numerous issues such as addressing groundwater that
had a pH of 3, metals in soil and groundwater, asbestos in soils and building components, the
excavation of an on-site landfill, and petroleum contamination. The cleanup was
accomplished, redevelopment completed, and ownership transferred to the City and County
of Denver. This project received national recognition when it was awarded the 2011 Phoenix
Award for excellence in redevelopment of brownfield properties as well the 2011 Brownfield
Renewal Award.
Confidential Uranium Mining Company (Casper, Wyoming). Evaluated the restoration
alternatives, costs, and scope associated with restoration of soils and groundwater for 12
sites that were formerly used for uranium mining and milling. The sited included several in-
situ mines located in northeastern Wyoming, an open pit uranium mine in central Wyoming,
and several sites located in Texas and Illinois. Mr. Aiken developed a remedial approach to
clean up the groundwater at all of the sites and developed detailed cost estimates to quantify
the liability associated with the cleanup.
Expert Witness – Asbestos Issue (Confidential Client). Performed expert witness services
associated with a major asbestos cleanup project in Colorado. Mr. Aiken reviewed site data,
and rendered expert opinions on the performance of the assessment and cleanup of an
asbestos-containing landfill at a former manufacturing plant.
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Additional Employment History
MACTEC Development Corporation (MDC) 1997 - 2004
General Manager/Senior Program Manager
MDC was a MACTEC business unit that focused on environmental liability transfer and assumption
associated with environmentally-impaired properties. Mr. Aiken’s activities included business
development, proposal preparation, client relations, and management/technical participation in
project work. Technical activities included investigation of sites, selection of remedial technologies,
remedial cost estimation, preparation of insurance submittals for obtaining environmental
insurance, and other aspects of liability/risk assessment and transfer. Work included liability
transfer and assumption activities on individual properties as well as portfolios of properties, and
included full liability assumptions with property transfer, transfer of liabilities, fixed-price cleanup
with cost cap insurance and other approaches. Specific projects are listed below.
Former Lowry Air Force Base. Managed business development activities as well as the
technical performance of project work for the privatization of a major environmental cleanup
at Lowry Air Force Base. Developed a guaranteed cleanup approach and cost for a 3.5 mile
long chlorinated solvent plume and the closure of a landfill. The cost was guaranteed using
cost cap insurance as well as a pollution and legal liability policy. (See above for further
details).
Burlington Industries – Remedial Cost Modeling. Assessed remedial costs at a 100-year-
old former cotton mill. The cost evaluation was based on limited environmental information
and was used to facilitate a property transfer and brownfields redevelopment program. A
conceptual model was developed for the site and a statistical analysis was performed to
develop a level of confidence in the remedial cost estimates for insurance purposes.
Coffin Butte Landfill – Managed the full-scale implementation of an innovative treatment
technology for treating leachate at the Coffin Butte Landfill in Corvallis, Oregon. The
application was the first time that Direct Osmosis technology was used for leachate treatment
and was the largest application of the technology at 40,000 gallons per day. Coordinated the
construction of the building, the fabrication of the equipment and the installation and startup
of the process. The system was able to reduce the leachate volume and the water removed
met the discharge requirements of the trout stream that was used as a discharge point. The
concentrated leachate was mixed with waste fly ash and placed in the landfill for disposal.
Unocal – Liability Transfer Cost Estimate (17 Properties). Estimated the costs of
mitigating environmental issues at 17 former agrichemical sites. Activities included detailed
cost estimates for sites where sufficient data existed and cost modeling for sites where
minimal data existed. Work product was used to produce a liability transfer offer.
Miscellaneous Sites. Involved in many other liability transfer projects including:
coordination of insurance personnel working with a design/build team on a project to
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redevelop four old landfills as golf courses and residential/ commercial properties;
evaluation of environmental conditions and remedial costs for a portfolio of 22 properties
formerly or currently used for formation, packaging, and distribution of chlorinated solvents,
pesticides, and other organic chemicals; development of an Environmental Risk Management
Plan for the redevelopment of Cecil Field in Jacksonville, Florida; evaluation of environmental
conditions for 60 retail gasoline sites as part of a property transfer; assessment of
environmental remediation costs for the assumption of the former Gates Rubber property in
Denver, Colorado (chlorinated solvent cleanup); and, evaluation of environmental
remediation costs associated with 65 facilities (laboratories) as part of a corporate
acquisition.
ENSR Consulting & Engineering 1988 – 1997
Senior Program Manager/Business Development Manager
Managed client interactions and business development activities for ENSR’s Chicago operations prior
to relocating to Colorado. In Colorado, responsibilities included business development for the
Colorado operations, national account responsibilities for Burlington Northern Railroad and Phelps
Dodge Mining, and direct project activities. Program management activities covered a broad range of
projects including the following:
Cyprus Amax - Expert Witness. Worked as an expert witness in a case involving cleanup of
a former zinc processing facility. Included evaluation of approaches and costs of groundwater
cleanup and expert testimony related to this superfund site.
Holland & Hart (Denver) - RCRA Corrective Action. Assisted law firm with investigation,
risk assessment, and corrective action study for RCRA site in Denver. Developed remedial
costs for negotiation with site operator.
TEXACO - Fillmore Superfund Site (California). Managed the preparation of a feasibility
study for a major refinery superfund site. The report consisted of preparation of an
Alternatives Screening Document, a Detailed Analysis Document, and a final feasibility study.
Recommended a no-action approach based on natural degradation evidence and limited site
risks. Negotiated approach with agencies and achieved a Record of Decision that allowed 2-
year monitoring program to prove natural degradation was occurring.
AMOCO Pipeline - Gasoline Pipeline Terminal Feasibility Study/Remediation Design
and Implementation (Indiana and Michigan). Managed preparation of feasibility studies
for two significant pipeline spills. Responsibilities included determining cleanup objectives,
and developing, screening, and evaluating remedial alternatives. Projects included significant
negotiations with state agencies and extensive interaction with and direction of contractors
in preparing data summaries, figures, and groundwater modeling input to feasibilities
studies. Assessed operation of interim groundwater treatment system at Michigan site,
designed/ installed system modifications, and provided (O&M) of ongoing treatment.
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Confidential Client (Illinois) - Negotiation of Site Remediation (RCRA). Successfully
negotiated innovative financial approach to addressing client's environmental concerns.
Approach allowed client to allocate funds on a yearly basis to address significant
environmental issues, including removal and disposal of several thousand drums of waste;
soil and groundwater investigation and remediation; and ongoing compliance issues.
Negotiated plan allowed client the financial strength to continue operations while addressing
agency needs over a 10-year period.
Confidential Client - Petroleum Refinery Remediation - To avoid RCRA corrective action
at petroleum refinery, initiated program to treat sludge in impoundments. Performed
treatability testing and initiated active in-situ bioremediation. Sludge was successfully
treated and residues were disposed of as special waste. Performed Groundwater modeling to
illustrate that impoundment did not impact groundwater. Program saved millions of dollars
over cost of treating waste as hazardous.
Wood Treating Superfund Site (Colorado) - Remedial Investigation/Feasibility Study
(RI/FS). Involved in planning and implementation of RI/FS program at Superfund site in
Colorado. This work included preparation and negotiation of work plans with Colorado
Department of Health, oversight of remedial investigation and risk assessment activities, and
preparation of feasibility study, submitted with limited action recommendation.
Confidential Manufacturing Facility - Corrective Action Study/Preliminary Designs
(North Carolina). Managed preparation of RCRA Corrective Action Study for large electronic
containing solvents and petroleum hydrocarbons. Also managed preparation of preliminary
designs for remediation systems to treat groundwater containing chlorinated solvents and
petroleum hydrocarbons.
Confidential Manufacturing Facility – Chlorinated Solvent Remediation (Illinois).
Designed and managed a treatability study for the in-situ remediation of chlorinated solvents
at a major manufacturing plant. Treatability test results resulted in the design and
implementation of an innovative treatment system that included steam injection and
biotransformation of the chlorinated solvents. Received a patent for the technology in 1990.
Burlington Northern Railroad (Minnesota) - Risk Assessment/Feasibility
Study/Remediation. Managed risk assessment, feasibility study, design report, and
remedial construction oversight for closed rail maintenance facility. Project included
excavation of waste pits containing construction debris, oily wastes, solvents, sandblast
sands impacted by metals, piping and other equipment, and trash and landscape waste.
Hazardous wastes included PCBs, lead, arsenic, cadmium, and PAHs. Negotiated remedy with
state regulatory agency and participated in public affairs and community education activities.
Superfund Landfill Sites - Feasibility Studies (Wisconsin and Michigan). Provided
technical oversight for preparation of CERCLA feasibility studies for two Superfund landfill
sites. Studies included preparation of Alternatives Array Document to evaluate remediation
technologies for solid waste, groundwater, and adjacent wetlands containing organics and
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metals; negotiations with state and U.S. EPA officials regarding direction of feasibility study
projects; and completion of detailed analysis of alternatives.
Confidential Client (Wyoming) - Uranium Mill Tailings Leachate/Groundwater
Treatment. Completed the assessment and testing of treatment technologies for leachate
and impacted groundwater from uranium mill tailings. Preliminary assessments of
technologies and costs and treatability testing was performed.
Citgo (New Jersey) – Assessment of Environmental Cost and Liability. Developed and
implemented a cost model to assess the value of the liability associated with all of Citgo’s
storage and processing facilities. This was being done as part of a large asset sale and helped
to define the sales price of the facilities.
Woodward Clyde Consultants - Assistant Project Manager 1985 – 1988
Susanin Equipment Company - Water/Wastewater Treatment Sales 1984 – 1985
Ionics Inc. - Eastern US Area Sales Manager 1981 – 1984
Permutit - New England Area Sales Manager 1979 – 1980
Nichols Engineering - Technician 1978 – 1979
Education
B.S., Natural Resource Management - Rutgers University, 1977
Graduate Study, Ecology - Rutgers University, 1979
Graduate Study, Environmental Engineering - Illinois Institute of Technology, 1987
Patents/Licenses
Received patent (U.S. Patent No. 5,279,740) for a groundwater remediation system that employs
steam injection and bioremediation to remove chlorinated solvents from the subsurface, 1990
Received a Colorado Real Estate Brokers License, 2015
STATEMENT OF QUALIFICATIONS
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Noah M. D’Antonio
President, National Inspection Services
office: (970) 482-1976 | e-mail: noah@nationalinspection.net
Summary As President of National Inspection Services (NIS), Mr. D’Antonio operates a commercial and environmental due diligence firm that has served clients in Colorado and nationwide for 50+ years. National Inspection Services conducts property condition assessments (PCAs); Phase I environmental site assessments; Phase II subsurface environmental investigations; site characterizations and remediation; tank investigations and removals; ground penetrating radar surveys; asbestos inspections and abatement; industrial hygiene projects; building construction oversight and more. Mr. D’Antonio directs all business operations from client relations to technical projects. He leverages more than 15 years of experience in environmental due diligence, industrial hygiene, building inspections, and construction management and oversight to ensure that each client’s unique needs are met.
Environmental Due Diligence and Consulting Mr. D’Antonio has a diverse background serving commercial and private equity clients. He has conducted hundreds of Phase I Environmental Site Assessments and Real Estate Transaction Screens for commercial, residential, and industrial properties throughout the United States. He has conducted environmental site assessments on various portfolios for gasoline stations, shopping centers, and automotive repair facilities. In addition, Mr. D’Antonio has managed and conducted dozens of Phase II subsurface investigations including surface and subsurface soil and groundwater sampling, soil gas sampling and analysis, ground penetrating radar surveys, and underground storage tank (UST) investigations and closures. Mr. D’Antonio has completed various site-wide characterization studies, utilizing sub-slab vapor and indoor air sampling and risk analysis, and long-term groundwater monitoring. Mr. D’Antonio has managed various projects through the Colorado Voluntary Cleanup and Redevelopment Program (VCP), written and implemented materials management plans, and has experience in construction oversight, excavations, hazardous waste oversight, landfill sampling, and remedial activities. He has partnered on numerous projects associated with the remediation of
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chlorinated solvents in soils and groundwater and has experience with PFAS sampling in soils and groundwater. Mr. D’Antonio is proficient in the industrial hygiene practice and is a Colorado Certified Asbestos Building Inspector. Currently, he manages a group of inspectors who conduct lead, mold and asbestos inspections and remediation projects throughout Colorado. Mr. D’Antonio specializes in assisting potential building purchasers through due diligence inspections prior to purchase. Select projects include:
• Colorado Voluntary Cleanup and Redevelopment Program (VCP) Groundwater
Treatment (PCE Remediation), The Foundry, Loveland, CO. Oversaw the remediation of a former dry-cleaning property as part of a redevelopment project in the downtown area. Assisted with the preparation of a VCP Application for the site, site investigative activities, implementation of soil and groundwater treatment effort to address chlorinated solvents in groundwater, and preparation of the completion report. This site received a No Action Determination (NAD) from Colorado Department of Public Health and Environment (CDPHE) after drinking water standards were achieved.
• Murphy USA Portfolio – Managed a Phase I and PCA portfolio for nine gasoline stations throughout Minnesota for a potential purchaser. NIS assisted the client through all aspects of their environmental due diligence for the purchase of the facilities and identified building deficiencies in the various structures.
• Gas Station Release and Closure, Fort Collins, CO – Completed a Site Characterization Report (SCR) for a suspected release at a gas station that was reported due to a failed hydrostatic test on a spill bucket. Four monitoring wells were installed at the site and benzene was detected in groundwater above the Colorado Department of Labor and Employment Division of Oil and Public Safety (OPS) Tier 1 Risk-Based Screening Level (RBSL). Two additional monitoring wells were installed in 4th quarter of 2023 and slug testing was conducted during the 1st quarter 2024. Quarterly groundwater monitoring continued through site closure in October 2024. NIS is currently assisting with the petroleum storage tank reimbursement.
• Demolition Services and Corrective Action at Old Town Site, Fort Collins, CO – Managed the demolition of a former theater building in downtown Fort Collins abutting a historic structure. Special considerations were put into place during demolition for protection of the historic structure during demolition activities. The overall scope of work included the initial asbestos inspection, asbestos abatement oversight, permitting and demolition services. The site also operated as a former dry-cleaning facility and a chlorinated solvent release was discovered in 2023, which also included the discovery of a vapor condition with the abutting building. The site is being managed by NIS under a State Corrective Action Plan (CAP) and includes the installation of a vapor mitigation system (VMS) installed within the historic structure to keep the building protective of human health.
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• Environmental Oversight, Henderson CO, – Contracted by the client to monitor and document the environmental conditions at an industrial site during the vacating of the site by a problematic tenant. Several known environmental conditions were reported at the site including areas of significant oil spillage and improper management of hazardous wastes stored. NIS documented the remedial activities completed by the tenant to allow for a smooth transition of tenants.
• PCE-Contaminated Property, Golen, CO – Remedial oversight of a contaminated industrial facility where PCE had been historically documented in groundwater. After several years of groundwater monitoring, a groundwater remediation plan was implemented which included the installation of more than 200 injection points of emulsified vegetable oil (EVO) throughout the property. PCE was significantly reduced within a few quarters of monitoring and the site recently received a no action determination and approval for site redevelopment.
• East Colfax Site Redevelopment, Denver Colorado – Installed permanent groundwater monitoring wells and implemented a series of EVO injections at the site prior to redevelopment as part of a VCP. This site remains under a quarterly groundwater monitoring plan.
• Nueva Vida Mobile Home Park, Fort Collins, CO – Conducted the asbestos inspection to demolish two dilapidated structures at one of Colorado’s first community-owned mobile home parks. Procured a licensed general abatement contractor for the removal of all asbestos containing materials and oversaw the abatement. Managed all regulatory permitting and clearances.
• Gasoline Station Decommissioning, Campus West Shell, Fort Collins, CO – Managed the decommissioning of an abandoned contaminated gasoline station. Performed site remediation and decommissioning activities, including demolition of all structures, site investigation, tank removal, and soil removal, and ongoing groundwater monitoring. Drafted underground tank closure documentation and obtained regulatory closure for the site.
• Brownfield Site – Willow Street, Fort Collins, CO – Conducted various site investigation activities including soil test pits, and soil and groundwater sampling at a former manufactured gas plant. As part of the Colorado VCP, prepared and implemented a Materials Management Plan (MMP) to manage contaminated soil and groundwater during construction activities. The MMP included pumping and disposal of impacted groundwater during caisson installation and excavation and disposal of impacted soils.
• Powerhouse II, Fort Collins, CO – Completed multiple Phase I and Phase II site investigations along with the removal and closure of an unregistered aboveground storage tank.
• Property Transfer, Fort Collins, CO. Partnered with the client to determine the current environmental status of the property and make recommendations to the seller to ensure that a clean property was transferred. Recommended tasks including asbestos abatement, groundwater and soil sampling, and site cleanup conducted to general industry standards.
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• Fairfield Drive, Fort Collins, CO. Investigated the former nursery operations at a site to determine if the past use as an orchard and nursery impacted the soils. The site was a vacant field to be built with residential apartments and playground. Mr. D’Antonio worked closely with the Colorado Voluntary Cleanup Program (VCP) managers to ensure all sampling and analytical data were collected as required by the State. In 2023 NIS implemented a Materials Management Plan (MMP) during site excavation activities to manage potentially asbestos containing soils.
• Environmental Brownfields Consulting, Fort Collins, CO. Provided environmental assistance to a development team tasked with the design and installation of a new parking lot on an environmentally impaired property. Developed a soils management plan and provided environmental planning and construction oversight of the parking lot.
Building Inspection Consulting Mr. D’Antonio leverages his background in construction management to identify significant deficiencies and cost savings for clients prior to closing a complex property transaction. He has conducted and reviewed more than 250 Property Condition Assessments (PCA) in accordance with the ASTM 2018-15 standard at commercial, industrial, retail, and multi-tenant sites. His inspections have documented building deficiencies in excess of $350,000. Mr. D’Antonio and his team thoroughly evaluate each property for site grading/drainage, pavement and flatwork performance, mechanical systems and overall building performance. Mr. D’Antonio assists and advises clients through recommendations for structural engineering reviews, professional roof evaluations, electrical component assessments, and recommendations by other contractors. He regularly manages inspections for retail and commercial, industrial and multi-family properties.
Certifications and Memberships
• AHERA Certified Building Inspector
• OSHA 40-Hour HAZWOPER
• ASTM Member #: 2421961
Education M.S., Geoenvironmental Studies, Shippensburg University 2008 B.S., Geoenvironmental Studies, Shippensburg University 2006