Denver Federal Center Regulatory Compliance

The U.S. General Services Administration (GSA) is required to perform a site-wide assessment of Denver Federal Center (DFC) according to Colorado Department of Public Health and Environment (CDPHE) Compliance Order on Consent No. 97-07-18-01. In response, GSA Region 8 Environmental Programs Group (EPG), implemented a Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) in accordance with the Federal Facilities Act (FFA). During the RFI, DFC was divided into 19 Investigation Areas (IAs) by geography and industrial processes.

SSP&A performed a detailed investigation that revealed contaminated soil remains at concentrations exceeding levels protective of residential/unrestricted use but are intertwined with subsurface utilities or in lenses that extend under buildings and roadways. GSA and CDPHE determined that complete removal of this contamination to unrestricted use levels is not technically possible or economically feasible.

In addition to the investigation and remediation activities, SSP&A assisted GSA with development of compliance procedures for operations under a Site-Wide Notice of Environmental Use Restriction (Restrictive Notice) to be placed on the entire DFC property. Restrictions are placed on future use of portions of the DFC that have engineered features or in-place administrative controls to protect human health and prevent exposure of workers, tenants, and visitors to residual soil or groundwater contamination. Restricted areas containing contamination on the DFC facility that have a cover to eliminate exposure are designated as Environmental Use Restriction Areas (EURAs). SSP&A is the prime contractor assisting GSA with mapping, documentation, and management of the EURAs, providing custom database services and updates to the GSA Site-Wide Database Management system, EDVARS, in accordance with the Consent Order.

Concurrently, SSP&A has assisted GSA with development of the DFC Materials Handling Plan (MHP), which guides work practices that involve disturbance of soil, groundwater, or subsurface features, or that generate waste. As part of the MHP, SSP&A developed the Operation and Maintenance Plan (OMP) that details the inspection and maintenance of EURAs to ensure that the cover is operating as intended and provides a process to notify GSA of required maintenance or prohibited activities that should be discontinued. The OMP, approved by CDPHE, outlines the process for establishing, modifying, and closure of an EURA.