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Former Crawford Power Plant site - Hilco Development Partners Chicago
BACKGROUND
From 1924 to 2012, Crawford Power Generating Station operated as a coal-fired power plant at 3501 South Pulaski Avenue in the South Lawndale community of Chicago between the Little Village neighborhood and the Chicago Sanitary and Ship Canal.
In 1999, Midwest Generation acquired Crawford and the nearby Fisk coal-fired powerplant; at their peak, the two stations produced power for nearly one million homes. In 2012, Midwest Generation began decommissioning of Crawford. These activities included removal of coal and coal ash, removal of hazardous substances, emptying and cleaning chemical and oil storage tanks, and draining, cleaning, and removing select transformers. Decommissioning ended in 2013. In 2014, NRG Energy purchased the site.
In 2017, Hilco Redevelopment Partners purchased the site to redevelop it into a 1 million square foot warehouse and distribution center to be called Exchange 55.
The former power plant is located in an Illinois EPA-designated area of Environmental Justice (EJ) concern. Areas of EJ concern are determined by Illinois EPA based on census block group data identifying higher concentrations of low-income and minority populations where a disproportionate environmental burden may occur.
SITE ASSESSMENT AND CLEANUP
In July 2018, Hilco enrolled the former power plant site in the Illinois EPA’s Site Remediation Program with the intent of receiving a Comprehensive No Further Remediation (NFR) letter.
SRP Remedial Applicants are required to define the extent of contamination on-site. Hilco identified four Recognized Environmental Conditions:
1. A limited number of polynuclear aromatic hydrocarbons (PNAs) present on site in excess of Illinois Tier 1 Industrial/Commercial Soil Remediation Objectives.
2. Arsenic, lead, and mercury present in excess of Illinois Tier 1 Industrial/Commercial ROs.
Available data indicates one isolated hazardous lead concentration (RCRA toxicity characteristic hazardous) within the former riverbed in the North section of the site.
3. One sample from the west portion of the former riverbed had a detection of benzene exceeding the soil component of the Class II groundwater ingestion exposure route.
4. On the South section of the site, one sample collected by the power house had a Total Petroleum Hydrocarbon concentration above the default soil attenuation capacity.
Through subsurface investigations and analytical testing, Hilco identified the following Contaminants of Concern (COCs):
North Section COCs: Volatile Organic Compounds (VOCs), PNAs, Metals
South Section COCs: PNAs, Metals, Polychlorinated Biphenyls (PCBs)
East Section COCs: PNAs, Metals
In March 2019, Illinois EPA conditionally approved the Phase I Environmental Site Assessment and Response to Illinois EPA Comments on the Comprehensive Site Investigation Report.
In July 2019, Illinois EPA conditionally approved the Response to Illinois EPA Comments on the Supplement to Comprehensive Site Investigation Report, Remediation Objectives Report & Remedial Action Plan.
In July 2019, Illinois EPA approved REVISION 1 - Sampling & Analysis Plan in Response to IEPA Letter Dated July 3, 2019.
Based on current soil and groundwater sampling data collected from within the site boundaries, it does not appear on-site soil and groundwater impacts have migrated to the neighborhoods north of the site. All samples were analyzed by an accredited laboratory.
For Further Technical Detail on Site Cleanup Activities
The reports submitted by Hilco and the review letters issued by Illinois EPA are available for public viewing using Document Explorer.
Search by Bureau ID: 0316005761.
The returning record says Midwest Generation LLC, click on that link, then click on Site Remediation – Technical
SITE DEMOLITION AND ASBESTOS REMOVAL
Illinois EPA administers the National Emission Standards for Hazardous Air Pollutants for Asbestos (“Asbestos NESHAP”) program for regulated asbestos during demolition, renovation, and disposal. Owners and operators subject to the Asbestos NESHAP are required to submit a Demolition/Renovation/Asbestos Project Notification Form 10 working days in advance of commencing a regulated asbestos demolition or renovation project.
Beginning in 2018, Hilco and their partners have submitted 12 notification forms, both originals and revisions. The current notification form, received in June 2019, specifies the following Asbestos-Containing Material (ACM) to be removed:
Regulated ACM to be removed:
- Surface area (sq. ft): 430,000
- Pipes (linear ft): 211,000
Non-friable ACM to be removed:
- Surface area (sq. ft): 25,000
On the June 2019 notification form, demolition and renovation end dates are both listed as December 20, 2019.
Under a delegation agreement with the Illinois EPA, the City of Chicago Department of Public Health conducts inspections to ensure compliance with the Asbestos NESHAP requirements, including notification, emission control, and disposal.
If you experience dust problems or have other complaints concerning operations at the site, please call the City of Chicago’s 311 system. Using this reporting method enables the calls to be tracked and the caller gets a number to check on the complaint.
Hilco maintains its own webpage to inform the public of ongoing site activities, including demolition status, under the tab Community Updates.
PUBLIC OUTREACH
On October 16, 2018, Illinois EPA received a letter from Chicago Legal Clinic, Inc. on behalf of the Little Village Environmental Justice Organization (LVEJO). The letter requested that the Illinois EPA develop a public participation strategy that includes the following elements:
1. Promptly providing all tangible information that is part of the SRP process, both in a local repository and on-line;
A repository has been established at Toman Branch, Chicago Public Library, 2708 South Pulaski Road, Chicago.
2. Working with LVEJO to conduct local public information meetings at key intervals during the site remediation process (upon completion of the site investigation report, upon completing of the remediation objectives report, upon receipt of the remedial actions plan), including providing Illinois EPA staff members to participate in these meeting;
On August 6, 2019, Illinois EPA participated in a public outreach meeting in Little Village organized by LVEJO.
3. Establishing a means for public comments and questions to be directed to the Illinois EPA staff members who will oversee site remediation activities;
Illinois EPA’s EJ Coordinator, Chris Pressnall, has been established as the primary point contact. He may also be contacted at 217-524-1284. In addition, Todd Hall, the SRP project manager, may be contacted at Todd Hall.
4. Developing fact sheets in both English and Spanish at key intervals in the remediation process to describe important activities that are being undertaken at the site and to address significant public comments and concerns;
5. Identifying a primary point of contact at the Illinois EPA for the public to contact with the questions and concerns about the design and implementation of site remediation activities;
As discussed above, Illinois EPA’s EJ coordinator, Chris Pressnall, has been designated as the primary point of contact. In addition, Todd Hall, the SRP project manager, may be contacted at Todd Hall.
On May 3, 2019, Chicago Legal Clinic sent a letter to the Illinois EPA with questions regarding the remediation. The SRP project manager reviewed the questions and incorporated some of the questions into a June 13, 2019 response to the April 2019 Supplement to Comprehensive Site Investigation Report, Remediation Objectives Report and Remedial Action Plan document.
On August 15, 2019, LVEJO sent a letter to the City of Chicago, copying Illinois EPA and other entities. The letter asked a series of questions.
On October 2, 2019, Illinois EPA issued its response letter answering questions 12-27.