vvEPA
www.epa.gov
Engaging Early in the Superfund Process, Enabling Cleanup and Reuse
THE FORMER SPELLMAN ENGINEERING SITE IN ORLANDO, FLORIDA
Introduction
Jacksonville
Spellman
For years, one of the most important pieces of undeveloped land
near downtown Orlando remained largely vacant due to ground
water contamination. The 26-acre Lake Highland property, part of
the northern gateway to the city's Central Business District, was
owned by the City of Orlando (City) for the use of the Orlando
Utilities Commission (OUC). Thanks to the early and sustained
engagement of the community, local and state governments, and
EPA, new recreation facilities have been built for a local school.
Other acreage is serving as a catalyst for infill development.
EPA, the Florida Department of Environmental Protection
(FDEP), the City, OUC, surrounding neighborhoods and Lake
Highland Preparatory School (LHPS) have been working
together in support of a coordinated approach to the cleanup of
the Former Spellman Engineering site and the redevelopment of
the adjacent Lake Highland property. The property's significant
value presented the City and OUC with the opportunity to use
proceeds from its sale to help fund the site's cleanup, while
keeping the site off of EPA's National Priorities List (NPL). The
project lias provided positive outcomes for all parties involved.
EPA and FDEP's priority remains the protection of human health
and the environment, which is being expedited through the
process. For the City and OUC, the site's cleanup protects public
health while the adjacent property's redevelopment will provide
new land uses to address community needs. For the surrounding
Park/Lake Highland and Lake Formosa neighborhoods, the site's
cleanup addresses local health and safety concerns, removes a
community "eyesore," and results in the Lake Highland property's
redevelopment in a manner consistent with community goals and
priorities. For LHPS, the site's cleanup provides an adjacent land
area for both new and expanded school facilities.
Today, the school's O'Meara Family Sports Center includes a new
ball field, practice fields and parking, with future expansion plans
calling for a gymnasium and maintenance facilities. The Dinky
Line segment of the Orlando Urban Trail, a paved recreational
trail, now extends through the area. The City and OUC are
also exploring opportunities for mixed-use redevelopment near
Central Florida's new SunRail commuter rail line and other
planned public transit facilities. The site's ground water cleanup
The Former Spellman Engineering site is located in Lake Highland, the
northern gateway to downtown Orlando.
system was buried underground, allowing for remediation while
at the same time optimizing the area for reuse.
This case study explores the working relationships and
innovative settlement agreements that have led to the cleanup of
the Former Spellman Engineering site and reuse of the adjacent
Lake Highland property. For example, in 2008, EPA and the City
signed the nation's first Contiguous Property Owner agreement,
in which the City agreed to voluntarily implement the site's
estimated $ 12.9 million remedy. LHPS also worked with the City
to finalize the project's Sale and Purchase agreement and with the
City, EPA and FDEP to finalize Bona Fide Prospective Purchaser
and Brownfield Site Rehabilitation agreements that addressed
potential liability concerns and facilitated the property's reuse.
The following pages trace the evolution of cleanup and reuse
efforts, highlighting local planning efforts and coordination with
EPA and FDEP in the 1990s and 2000s, as well as ongoing cleanup
and reuse activities in 2011. The case study provides information
and lessons learned to parties interested in Superfund site reuse
and how to address remedy and reuse considerations early in the
Superfund process.
I
Local school facilities now include a new ball field and practice fields, with additional land uses planned for the area in the future.
U.S. Environmental Protection Agency
Superfund Redevelopment Initiative

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Site History, Contamination and Remediation
From 1963 to 1969, the Spellman Engineering Company used trichloroethylene, a common degreasing solvent also known
as TCE, to clean electronic components at its facility. TCE discharged during that time contaminated ground water in the
vicinity of the facility, including the adjoining Lake Highland property.
In 1992, ground water underlying the Lake Highland property was determined to have been contaminated by TCE. The
City proactively sought opportunities to work with EPA and FDEP to address the site. Due to community concerns over
site stigma and the duration of the cleanup, the City of Orlando also requested that EPA not list the site on the NPL. The
City and the local community indicated a strong preference for a third-party cleanup using a property divestiture, cleanup
and redevelopment approach. EPA supported this approach, while maintaining that the NPL listing process would move
forward if project milestones were not attained.
Since there was no viable responsible party identified,
the City conducted a series of voluntary investigations at
the site from 1992 to 2004 that defined the extent of the
TCE contamination plume, evaluated the potential risks
associated with the contamination and evaluated cleanup
alternatives. Key findings included:
•	No human exposure to contaminated ground water
was occurring.
•	The ground water plume underlay approximately 40
acres.
•	Migration to the Floridan Aquifer potentially
threatened nearby municipal supply wells.
•	Contamination could be addressed through an
engineered remedy.
The investigations also determined that the area could be
redeveloped during cleanup activities and could be cleaned
up to meet EPAs unrestricted use/unlimited exposure
criteria.
EPA selected a remedy for the site's contamination in its
2004 Record of Decision. The final remedy, modified in
2010, includes a combination of soil and ground water
treatments, including electrical resistance heating, chemical
oxidation, enhanced bioremediation and monitored natural
attenuation.
The location of the Former Speilman Engineering Company facility.
In 2008. EPA and the City signed the first-ever Contiguous
Property-Owner agreement. In exchange for EPA resolution Cofnrnuni ¦> 'rig,
of potential liability concerns, the City agreed to implement the site's estimated $12.9 million remedy. The agreement
included a covenant not to sue, which eased liability concerns, and waived EPA oversight costs. Implementation of the
site's remedy began in 2011, with completion of cleanup activities anticipated in 2015, to be followed by a period of post-
remediation monitoring. Funding for post-cleanup activities will be in addition to the estimated cost of the site's remedy.
Throughout all the planning and cleanup activities, EPA and FDEP staff met regularly with local stakeholders to share
information and updates and to incorporate community feedback into the plans. Close coordination of the community's
reuse priorities with the cleanup planning has enabled the parties to use the site during the cleanup process.

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Project History
Site Location Map
East-West Expressway jj , J
NORTH
Lake Highland Property	O Former Spellman
Engineering Facility
1990s-2004
Assessing Contamination, Planning for the Future
Reuse planning for the area began in earnest in the mid-1990s,
several years after the discovery of ground water contamination
emanating from the Former Spellman Engineering facility.
"Initial assessments indicatedthatthe ground waterplume did not
pose an immediate threat to human health or the environment,''
recalled David Keefer, EPA's previous site project manager. "It
was also clear that the plume was slowly spreading. This was a
problem that was only going to get bigger and more expensive
to clean up." First, however, the characteristics and extent of
the contamination had to be determined. FDEP served as the
site's lead agency during this time.
"Identification of the contamination slowed down what
otherwise might have been rapid redevelopment," noted Park/
Lake Highland Neighborhood Association President Cathy
Kerns. "With the assessment of the area going on, and banks not
willing to lend money for development until the contamination
had been addressed, there was time to plan."
From the outset, the City and OUC were interested in finding a
creative solution that would use redevelopment to help finance
the site's cleanup. "There was an opportunity to capitalize
on the value of the Lake Highland property as a way to help
fund the site's cleanup, with the goals being a faster cleanup
and avoiding the potential stigma associated with EPA listing
the site on the NPL," recalled Assistant City Attorney Kyle
Shephard. "Everyone in the community was looking to avoid
that outcome."
"Our goal was to utilize a City and OUC asset to satisfy several
community needs. We needed to help EPA commence a cleanup,
but we also wanted to encourage transit-oriented infill that was
sensitive to the surrounding historic neighborhood, while also
helping provide athletic opportunities to an important downtown
educational institution," said Orlando Mayor Buddy Dyer. "We
also managed to alleviate long-challenging parking problems
for the nearby shopping district and establish a segment of the
Dinky Line Trail. Fortunately, we found a capable and willing
partner in this process with EPA."
While the City conducted a series of voluntaiy investigations,
community reuse plans for the area evolved from affordable and
single-family residential development to mixed commercial,
residential and recreational land uses. "It became clear that land
uses would likely be unrestricted following cleanup, given that
everyone is on municipal water," said Cathy Kerns. "EPA and
FDEP have done a good job of providing regular site updates
over the years. We were able to build site information into our
planning efforts."
In 2000, a city-sponsored Steering Committee developed the
OUC/Lake Highland Development Plan. The Committee,
which included representatives from local neighborhood and
business associations, LHPS, the City, OUC and the City's
Downtown Development Board worked together to create the
Plan. The Plan was adopted based on extensive community
input and approved by the Downtown Development Board's
Design Review Committee in August 2000.
The Plan took into consideration existing site conditions,
infrastructure availability and surrounding land uses. The
Plan proposed single-family and multi-family residential
development for the eastern portion of the Lake Highland
property and commercial retail and office land uses and/or a
middle school construction for the western portion. Areas were
designated for recreation fields and recreation support facilities.
Additional elements of the planning process included a traffic
analysis and development of drainage and landscaping plans
and design standards.
The Plan and its accompanying "Planned Development" (PD)
zoning, finalized in 2001, stated that "the OUC/Lake Highland
Development Plan area shall be developed as an urban, mixed-
use, pedestrian and transit accommodating infill/redevelopment
project that embraces the best practices of sustainable
development and Traditional Neighborhood Design."
In the interim, nearby LHPS expressed interest in leasing a
6-acre portion of the property for sports fields and signed a

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five-year lease in 2002. "The school had always been interested
in the property north of Lake Highland," said LHPS Board
Chairman Randall Rex. "The school was land-locked. At the
time, we had to go outside of the community to lease space
for softball, baseball and practice fields. The school had a
significant need for new sports-related facilities. The lease
provided the school with an interim option that worked well."
By late 2003, the school's O'Meara Family Sports Center had
opened on the central part of the property.
Also in 2003, EPA assumed responsibility as the lead agency for
the site's cleanup. "FDEP and EPA have worked well together
at the site," said FDEP project manager George Houston.
"Following the site assessments conducted by the City, when
we understood the scale and scope of the contamination, it
was clear that the federal Superfund program would be a vital
partner for the site's cleanup."
EPA and FDEP's coordination with the City led to the site's
2004 Record of Decision, which provided a powerful impetus
for the site's coordinated cleanup and redevelopment to move
forward. The feasibility study conducted prior to the issuance
of the Record of Decision determined that the area could be
redeveloped during cleanup and that the site could be cleaned
up to meet EPA's unrestricted use/unlimited exposure criteria.
"The Record of Decision set the stage for the site's cleanup
and redevelopment," said Bill Demnan, EPA's current project
manager at the site. "All parties were looking for creative
approaches and solutions to be able to move forward. At the
end of the day, everyone knew that EPA would have to list
the site on the National Priorities List if no other way forward
could be found."
"All parties were looking for creative
approaches and solutions to be able to
move forward."
- Bill Denman, EPA Project Manager
2005 - 2009
Working through the Process...
With the site's Record of Decision in place, the City and OUC
identified an approach for beginning the cleanup without EPA
having to list the site on the NPL. They planned to pursue a
public/private partnership approach to clean up and develop
the area, using the sale of Lake Highland property parcels
to fund the cleanup. Initial property appraisals indicated that
sale proceeds could cover and perhaps even exceed the cost
of the site's estimated $12.9 million cleanup. The City could
also insist on high-quality planning and development of the
property.
"Owning such a valuable piece of property, with its beautiful
location on the shores of Lake Highland and proximity to
downtown Orlando and great surrounding neighborhoods,
meant that the taxpayers of Orlando stood in a strong
bargaining position with any prospective purchaser," recalled
Byron Brooks, the City's Chief Administrative Officer. "We
could ensure high-quality development while earning a return
that could help pay for the cleanup."
In November 2005, the City and OUC signed a joint resolution
callingforthe "divestiture, cleanup and redevelopment of certain
city-owned property near Lake Highland in Orlando, Florida."
The resolution established a Joint Review Committee (JRC), a
six-member group composed of three OUC staff members and
three city staff members, to oversee the process. The resolution
also recognized the importance of community involvement,
establishing a Neighborhood Advisory Committee (NAC) to
provide "meaningful input from community leaders, the local
business community, [and] residential communities adjacent
to the Property ... [that] will be critical to the success of the
redevelopment and remediation project."
t
	1
Lake
	 REDEVELOPMENT PROJECT
For its part, EPA agreed to refrain from listing the site on the
NPL. "EPA and FDEP supported the City's approach" said
EPA project manager Bill Denman. "At the same time, we
were clear that the process had to yield results. For us, a timely
cleanup was the key outcome."
With significant time and resources invested, the City and
OUC were anxious to move forward as well. "Our goals were
to ensure the site's cleanup, in compliance with EPA and FDEP
orders, and redevelopment consistent with neighborhood
priorities," recalled Assistant City Attorney Kyle Shephard.
"This was the next step in the process and as with any planning
process in Orlando, community input was critical." As the
JRC considered which property parcels might be included in
a request for development proposals, the NAC met twice in
2006, hosting a public meeting to gather community input.
"The community had worked hard on the Development Plan for
the area. It was important that our priorities for compatible local
land uses were reflected in any RFP [request for proposal],"
said Cathy Kerns, who also served as a member of the NAC.
"Ensuring neighborhood quality of life was critically important
in any development scenario."

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In May 2006, however, the process took a new and unexpected
turn. A neighborhood organization stepped forward with a
proposal of its own.
...Adjusting to Changing Conditions...
LHPS notified the City in May 2006 that it would exercise
an option within its lease agreement with the City to acquire
the 6-acre area it had leased since 2002 for recreational
facilities. The school also later proposed, in conjunction with
a development partner, the Missouri-based Enviromnental
Liability Transfer (ELT) company, to purchase the Lake
Highland property parcels, clean up the entire site and develop
the rest of the 26 acres. Since a private third-party was willing
to assume responsibility for the site, the need for a proposed
Request for Proposals (RFP) process was eliminated. With 6
acres at the center of the property no longer available for sale,
and the local real estate market increasingly under pressure
from a slowing national economy, the City and OUC had to
consider alternatives to their original divestiture plan.
"It was a promising time," recalled Gordon Spears, Vice-
President of the Lake Formosa Neighborhood Association.
"While we were looking to hear more from the school about
its longer-term plans for the area, it seemed like the school's
redevelopment proposal could fit well with community
priorities."
To reflect these changes, the City and OUC issued a restated
joint resolution in September 2007, appointing the City as the
lead agent to work with LHPS on a sale and purchase agreement
and with EPA and FDEP on agreements to address site liability
and lien issues. Discussions continued into mid-2008, when
changing conditions once again forced parties to adapt.
This time, the news was more challenging. ELT had withdrawn
as the project's development partner. "It was an issue of dollars
and cents," recalled LHPS' Randall Rex. "At the end of the
day, [ELT's] risk premium was too high for the school to be
able to continue with the project." After several years of effort,
the breakdown marked the end of third-party cleanup and
redevelopment efforts at the site.
Timeline of Events
1940s - 1980s: Orlando Utilities Commission (OUC) uses
properties adjacent to the site as operations
and maintenance center
1963 -1969: Spellman Engineering Company uses
trichloroethylene (TCE) to clean electronic
components, contaminating ground water
in vicinity of facility, including adjoining
Lake Highland property, a 26-acre area
owned by City
1990s - 2000: Reuse plans developed for Lake Highland
property
1992:	TCE detected in ground water
2000:	City's Downtown Development Board
approves community's OUC/Lake
Highland Land Use Plan (later amended in
2001); site zoned for Planned Development
2002:	Portion of Lake Highland property leased
to LHPS for use as a recreation area
2003:	EPA assumes responsibility as lead agency
for the site's cleanup
1992 - 2004: The City conducts voluntary site
investigations, in coordination with EPA
and FDEP
Sept. 2004: EPA issues Record of Decision, selecting
remedy for site
Nov. 2005: City and OUC issue Joint Resolution for
divestiture of Lake Highland property to
expedite site's cleanup and redevelopment
2006:	OUC and City empanel Joint Review
Committee (JRC) and work with
Neighborhood Advisory Committee
(NAC) to incorporate community feedback
regarding site cleanup and redevelopment
Sept. 2007: The City and OUC amend Joint Resolution
to adapt to changing market conditions
Jun. 2008: Private party cleanup approach does not
move forward. City pursues voluntary
cleanup approach, with LHPS to acquire
portion of Lake Highland property
Oct. 2008: First-ever Contiguous Property Owner
(CPO) Agreement signed by City and EPA;
CPO includes covenant not to sue and City
agrees to implement site's remedy
Oct. 2008: Key parties simultaneously sign Sale
and Purchase and Bona Fide Prospective
Purchaser agreements
Sept. 2009: Updated Brownfield Site Rehabilitation
Agreement (BSRA) signed by City, LHPS
and FDEP
Sept. 2010: EPA modifies site remedy, issuing
Explanation of Significant Difference, and
approves final cleanup work plan
2011:	Site cleanup underway
Jan. 2011: LHPS opens new ball field and practice
fields on Lake Highland property
5

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EPA's message to the City and OUC remained clear and
consistent. "We emphasized the urgency of the site's cleanup
moving forward, one way or another," said project manager
Bill Demnan. "Everyone had been working together in good
faith on an alternative to placing the site on the NPL. In 2008,
it looked like that was perhaps the only remaining option."
However, the parties remained optimistic that another way
forward was possible. The key parties had built strong working
relationships, as well as trust between them. In addition.
EPA had made significant progress in developing new tools
and agreements necessary to facilitate site cleanup and
redevelopment.
Soon, it was the City and LHPS' turn to provide the breaking
news.
...Reaching Resolution
In summer 2008, the City announced that it would take the
lead and voluntarily clean up the site, while selling 18 acres
of the Lake Highland property for recreational reuse to LHPS.
In turn, LHPS announced that a separate entity, OS Complex,
Inc., would be created to acquire and lease the acreage to the
school. The announcements followed several weeks of intense
discussions with EPA and FDEP. ''When the City agreed to
voluntarily clean up the site, it was with the understanding
that EPA would help guide us through the next steps, through
what needed to be done to address the City's concerns and
federal and state cleanup requirements," recalled Assistant City
Attorney Kyle Shephard.
EPA site attorney Karen Singer coordinated closely with
EPA's Office of Site Remediation Enforcement (OSRE) and
staff from the U.S. Department of Justice (DOJ) to develop an
efficient process for moving forward. "Making [the project]
a reality required expertise across a range of areas," said Ms.
Singer. "We were reviewing model agreements, financial
assurance requirements, and EPA guidance on agreements with
municipalities and the Superfund Brownfield Amendments to
develop the type of agreements that would be quickly approved
by EPA and DOJ management and meet the needs of all parties."
"At the Spellman site, EPA was able to use its settlement tools
designed to help address the Superfund liability concerns
of parties willing to clean up and redevelop contaminated
properties. We recognized the need to tailor these tools to
address the site-specific concerns of multiple stakeholders at the
site," explained OSRE attorney Susan Boushell. "EPA worked
together with the local government and landowners to develop
agreements that would provide the liability protections and
comfort needed to foster the protective cleanup and sustainable
reuse of the property,"
The key issue was how to take advantage of the opportunity
presented by a contiguous property owner w hich volunteered to
Lake Highland Preparatory School
A private school situated on a 26-acre campus, LHPS is
located on Lake Highland, directly across from the Former
Spellman Engineering site.
Founded in 1970, the school currently enrolls approximately
2,000 students, pre-kindergarten through 12th grade.
clean up adjacent contaminated property . EPA project manager
Bill Demnan hosted weekly conference calls with other EPA
staff, FDEP. the City, LHPS and site contractors to address the
situation. During these calls, regulators and local stakeholders
provided site updates, addressed ongoing issues and challenges,
and identified and assigned tasks for completion before the
next call.
"There was a remarkable energy and atmosphere of creativity in
the group," recalled Bill Demnan. "People shared a willingness
to work through issues and find solutions because everyone
The Bigger Picture: EPA and Reuse
Efforts to address future land use considerations at the
Former Spellman Engineering site fit in well with emerging
nationwide interest in the revitalization of contaminated
areas, including Superfund sites. With the creation of EPA's
Superfund Redevelopment Initiative in 1999 and its Land
Revitalization Agenda in 2003, EPA's Office of Solid Waste
and Emergency Response launched a new EPA initiative
focusing on promoting land reuse and revitalization at
contaminated sites.
In 2002, the Small Business Liability Relief and Brownfields
Revitalization Act also became law. The Act was designed
to make the acquisition and redevelopment of contaminated
properties like Superfund sites easier by addressing the
liability concerns associated with these sites EPA's Office
of Site Remediation Enforcement lias a team devoted to
facilitating and implementing these liability protections.
6

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Site Parcels and Status (2011)
LAKE FORMOSA
LAKE VANHOE
LAKE H GHLAND
Lake Highland Property Parcels
Former Spellman Engineering Facility
North Orange Avenue Business District
Lake Highland Preparatory School
North Orange Neighborhood
Lake Formosa Neighborhood
Park Lake/Highland Neighborhood
Orlando Central Business District
1,000
Feet
O
NORTH
Parcel
Acreage
Tract A
5.76
Tract B
18.17
Tract C
0.82
Tract D
1.13
Tract E
0.41
Status
Parcel owned by City of Orlando. Redevelopment in planning stages.
Parcel owned by LHPS and partner OS Complex, Inc. New ballfield
located on parcel, with additional recreational facilities planned.
Parcel owned by City of Orlando. Redevelopment in planning stages.
Parcel owned by City of Orlando. Redevelopment in planning stages.
Parcel owned by City of Orlando. Redevelopment in planning stages.
could see the benefits and potential outcomes. Everyone had an
interest in making the site's cleanup and reuse possible."
This period of intense federal, state and local collaboration
and problem-solving extended over several months, producing
three interlinked agreements to resolve liability that were
signed on the same day in October 2008.
• Contiguous Property Owner (CPO) Agreement: In the
first agreement of its kind in the nation a non-liable
adjacent property owner (the City) agreed to voluntarily
clean up a Superfund site. The City agreed to conduct the
cleanup selected in the site's 2004 Record of Decision,
committing to spend approximately $12.9 million
to fund the cleanup. EPA's southeast regional office
coordinated closely with EPA Headquarters as well as
the U.S. Department of Justice to develop and approve
the agreement, which provided the City with a covenant
not to sue for the cleanup work or any response costs,
including oversight costs. A covenant not to sue is a
provision promising that EPA will not bring any future
legal actions against agreement signatories regarding a
site and the specific matters named.
Property Sale and Purchase Agreement: OS Complex,
Inc. and LHPS agreed to purchase the 18-acre Tract B
property for $2 million from the City. The proposed
Dinky Line Trail was rerouted as part of the agreement,
from a former rail line crossing the site to the edge of the
Tract B property.
Bona Fide Prospective Purchaser (BFPP) Agreement:
OS Complex, Inc. and LHPS completed the required
all appropriate inquiries and qualified as BFPPs. In
exchange for their significant financial contribution to the
cleanup, EPA entered into a BFPP Agreement with both
parties, waiving any site liens and providing covenants
not to sue. The covenants mean that the parties will
not be liable under Superfund for their activities in the

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future, assuming that they continue to meet the ongoing
BFPP obligations, including taking reasonable steps to
stop continuing release, prevent any threatened future
release, and prevent or limit human, environmental or
natural resource exposure to any previously released
hazardous substance.
Orlando City Council also approved a fourth agreement, an
updated Brownfield Site Rehabilitation Agreement (BSRA), in
October 2008. Signed in September 2009, the updated BSRA
conveyed the site's original BSRA agreement, which resulted
from the earlier third-party cleanup negotiations, from LHPS to
the City. The updated BSRA enabled the City to receive state
voluntary cleanup tax credits to help offset a portion of the
site's cleanup costs.
"Putting the agreements together and coordinating their signing
was a complex process," said Assistant City Attorney Kyle
Shephard. "But we had a clear road map and local, state and
federal partners willing to share their expertise. City staff and
our partners shared a dedication and commitment to see this
through."
Together, the coordinated agreements made the difference. Key
parties remained patient, weathering delays, uncertainties and
rapid changes in previously agreed upon plans. Following the
signing of the agreements in October 2008, the site's cleanup
and redevelopment were back on track.
2008-2011 +
Coordinating Cleanup and Reuse...
Since late 2008, the project's key parties have been working
hard to coordinate cleanup and redevelopment.
The City signed a fixed-price contract with long-time site
environmental consultant ARCADIS to implement the
majority of EPA's selected remedy. After ARCADIS satisfies
the contract requirements, the City will then be responsible for
any additional cleanup activities needed, including long-term
monitoring. The City has been pursuing opportunities to recoup
site cleanup costs. For example, the City's updated 2009 BSRA
with FDEP qualified the City for voluntary cleanup tax credits
that permit the deduction of up to $500,000 per year in site
cleanup costs and provides state liability protections.
"The site's cleanup and reuse protect
public health and provide community
benefits, and will pay for itself over the
long term."
- Assistant City Attorney Kyle Shephard
"The City of Orlando understands that cleaning up the site and
recouping cleanup costs is a long-term process," said Assistant
City Attorney Kyle Shephard. "More importantly, it is the right
tiling to do. The site's cleanup and reuse protect public health
and provide community benefits, and will pay for itself over
the long term."
In terms of reuse, OS Complex, Inc. and LHPS developed
detailed plans for a new ball field, practice fields and parking
on Tract B, with future planned uses to include a gymnasium
and a maintenance facility. The school parties were also able
to coordinate with ARCADIS to integrate reuse plans with
cleanup planning. The site contractor designed the site's
bioremediation system so that all piping and equipment would
be buried underground, underneath LHPS' new ball field
complex and connected to a single delivery line. This design
has permitted optimal recreational use of the area while ground
water contamination is being remediated. "The site contractor
has gone above and beyond with their work at the site," said EPA
project manager Bill Denman. "Cleanup and reuse have been
seamlessly integrated." Finally, the school parties discussed
their plans with neighborhood organizations, addressing most
community concerns, including the development of a non-
intrusive field lighting system designed to minimize glare.
Community meeting, 2008.
EPA and FDEP continued to closely monitor the site's
cleanup plans. The site contractor submitted a remedial action
work plan, an environmental health and safety plan and
sampling and analysis plans in 2009. In September 2010, EPA
modified the site's remedy with an Explanation of Significant
Difference (ESD) following extensive field design work. The
ESD incorporated electrical resistance heating to address
contaminants in fine-grained soils and the ground water plume.
The site's cleanup work plan was also finalized in September
2010. Implementation of the site's remedy began in early 2011,
with completion of cleanup activities anticipated in 2014, to
be followed by a period of post-remediation monitoring. The
construction of the new LHPS ball field and practice fields was
8

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completed in late 2010; the first baseball game was played on
site in January 2011.
"The school's ability to begin improvements during the
implementation of the cleanup was a wonderful bonus to the
neighborhood." said City Commissioner Robert Stuart. "It
meant that a long-vacant and unattractive property could be
brought back to life far more quickly than anyone anticipated.
The school's new athletic complex is a neighborhood asset
instead of an eyesore."
Indeed, persistence may yet yield additional benefits. With the
City already at work on the neighboring SunRail commuter rail
system, some mixed uses - homes, commercial space, parking
- may be located on remaining Lake Highland property parcels
in the foreseeable future, addressing the long-standing local
priorities reflected in the community's 2000 Development Plan.
Not only will the new development help support the City's new
transit options, it will also complement the surrounding mix of
land uses and add to the tax base within the City's downtown
tax increment financing district.
...LookingBack, Looking Forward
The City's voluntary cleanup approach followed the eventually
unsuccessful multi-year pursuit of a private third-party
cleanup. Since cities rely on taxpayer dollars for their funding,
it also meant there would be a need to somehow recoup site
cleanup costs from property sales, tax credits and other
sources. This successful cleanup and redevelopment project
clearly demonstrates the importance of combining flexibility,
creativity, problem-solving skills, and the ability to draw on
a wide range of expertise with strong, continuous efforts to
engage the community and coordinate between numerous
government agencies.
For the community. LHPS's acquisition of Tract B and
subsequent recreational redevelopment lias provided a visually
appealing, low-impact facility in place of vacant lands. It lias
also meant that the mix of uses outlined in the community's
2000 Development Plan for the area will not happen exactly
as planned. Some see this as a missed opportunity, while
others see longer-term value in past community initiatives.
"The [planning] process was still useful," said Lake Formosa
Neighborhood Association representative Gordon Spears. "We
forged important political relationships and it put us on the
radar screen as neighborhoods that cared about the area. The
school's recreation area is there now as well, which was part
of the plan. Keep in mind, too, [that] our number one goal has
always been the site's cleanup. Our persistence has paid off."
"The school's ability to begin
improvements during the
implementation of the cleanup was a
wonderful bonus to the neighborhood."
- City Commissioner Robert Stuart
"The Lake Highland project proves that even highly complex
environmental challenges, involving numerous public
and private stakeholders, can be resolved by committed
partnerships," stated Mayor Dyer. "We are also reminded
that smart land use planning principles are key to advancing
environmental protection, and this is why EPA and local
governments are natural partners."
Looking back, the project has been guided and spurred by a
spirit of innovation, creativity and exploration; coordination
among local, state and federal partners; local government and
community leadership; technical, legal and financing expertise;
and supportive state and federal policies and incentives. The
outcome is the successful cleanup of the Former Spellman
Engineering site and recreational reuse at the Lake Highland
property.
(EgLake Highland dt

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Former Spellman Engineering:
The Story in Pictures
Pre-Cleanup
Cleanup Design and Implementation (2011)
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In Reuse (2011)
Downtown	Lake Highland	Lake	Dinky Line	Lake
Orlando	Preparatory School	Highland	Trail	Ivanhoe
Former Spellman	New	New	New Practice
Engineering Facility Ball Field Parking Area Fields
Entrance to the LHPS Mark O'Meara Family Sports Complex.
New ball field in action, 2011

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Lessons Learned
Participants agree that a combination of significant factors have
contributed to the project's successful outcomes.
•	The site's proximity to community resources and
location near downtown Orlando meant that cleanup and
redevelopment were high priorities.
•	The City and OUC consistently pursued the site's
cleanup and redevelopment over the long term. The
City's willingness to voluntarily clean up the site
following unsuccessful private third-party attempts
ensured that EPA did not need to list the site on the NPL.
•	The local community came together to develop reuse
plans that informed cleanup and redevelopment
planning. Community members also provided feedback
to key parties throughout the process.
•	LHPS was an engaged, motivated partner that developed
feasible plans and brought together the technical, legal
and financing expertise needed to develop its recreational
facilities.
•	EPA and FDEP understood community priorities in the
context of the site's cleanup, supporting the City's efforts
while emphasizing a timely site cleanup.
•	Coordination of the site's cleanup design with the design
of the new LHPS ball fields meant that cleanup and
redevelopment could move forward at the same time.
•	All parties involved were patient and flexible,
recognizing that cleanup and redevelopment are complex
processes reliant on available resources, multiple parties,
site contamination and other factors.
The Bigger Picture
While these site-specific conditions created an ideal climate
for successful reuse outcomes, there are also a range of
broader lessons learned that can help guide similar projects at
contaminated lands across the country.
EPA works closely with communities, site owners and other
stakeholders to support reuse outcomes that are compatible
with site cleanups.
The Agency places a high priority on supporting the return of
contaminated sites to productive andbeneficial uses. In Orlando,
the City and LHPS were able to work with EPA and FDEP
and the community to identify cleanup and redevelopment
opportunities. When the originally planned private third-party
approach to address the site did not work out, the agencies
worked with local stakeholders to identify an alternative way
forward that supported the cleanup and desired reuse outcomes.
EPA and Reuse: Lessons Learned
Since the inception of the Superfund program, EPA has been
building on its expertise in conducting site characterization
and remediation to ensure that contamination is not a barrier
to the reuse of property. Today, consideration of future use is
an integral part of EPA's cleanup programs, from initial site
investigations and remedy selection through to the design,
implementation, and operation and maintenance of a site's
remedy.
"At older sites, EPA did not focus on taking reuse
considerations into account early in the cleanup process,"
reflected EPA's Matthew Mankowski, a former project
manager at Superfund sites. "Today, that has changed.
Superfund cleanups can be very creative and flexible in
allowing for future site uses, but that information needs to be
plugged in early to be as effective as possible."
At the Former Spellman Engineering site, future land use
considerations were able to inform city contractor ARC ADIS'
design of the site's remedy. The site's bioremediation system
was designed so that all piping and equipment would be
buried underground, underneath LHPS' new ball field
complex, and connected to a single delivery line. This design
optimized recreational use of the area while remediation
continued.
EPA also works with site stakeholders to consider how future
land use considerations can inform the implementation and
long-term stewardship of site remedies as well as cleanup
planning. At some sites, for example, reuse considerations
can inform the future location of ground water monitoring
wells and other operation and maintenance equipment that
might inadvertently hinder redevelopment efforts. At other
sites, detailed site reuse plans have provided additional
benefits that save time and reduce redevelopment costs. For
example, future utility corridors or building footers can be
installed in coordination with site cleanup activities.
While EPA provides tools and resources to support
Superfund reuse, communities and public and private
sector organizations make it happen.
EPA's mission is to protect human health and the enviromnent.
EPA relies on engaged community stakeholders to bring their
future land use goals and priorities to the table so that this
information can be incorporated into the remedial process,
linking cleanup and redevelopment. "The City showed initiative
by voluntarily undertaking site investigations and then the
site's cleanup," said EPA project manager Bill Denman. "And
with the community's Development Plan in place, we [EPA and
FDEP] had a good understanding of local reuse priorities."
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Voluntary cleanups at contaminated lands like Superfund
sites are a powerful tool that can protect human health and
the environment without requiring site listing on the NPL.
EPA and state and local agencies can identify opportunities
for stakeholder leadership during initial site investigations,
feasibility studies and baseline risk assessments. As in
Orlando, voluntary cleanups work extremely well when local
governments own contiguous, non-source properties which
will retain significant value after cleanup, the cleanup costs are
not prohibitively greater than the value of the property, and site
cleanup does not significantly restrict potential future site uses.
In addition, faster and lower-cost cleanups may be possible at
some sites. When efforts fail to find either responsible parties
or volunteers who will clean up a site, NPL listing remains one
of EPA's most effective tools for addressing the nation's worst
hazardous waste sites.
For EPA site teams, early engagement with regional office
management, Headquarters staff and other federal agencies
can be key to ensuring timely responses for necessary
reviews and approvals, particularly when considering new
tools and approaches.
Coordination for the Former Spellman Engineering site led
to the site's interlinked agreements, including the ground-
breaking CPO agreement that enabled a non-liable adjacent
property owner (the City) to voluntarily clean up a Superfund
site. EPA's southeast regional office coordinated closely with
EPA Headquarters as well as the U.S. Department of Justice to
develop and approve the agreement, which provided the City
with a covenant not to sue in return for cleaning up the site.
needed for the contractor's approach, while also updating the
remedy to reflect current enviromnental conditions.
Projects at contaminated lands can be complex undertakings
that require diverse expertise.
The project required significant legal, technical, financial and
policy expertise. The City and the school parties each brought
in specialized expertise as needed throughout the process.
In addition, by continuing to work with the same long-time
enviromnental consultant, the parties benefited from the
continuity the consultant provided, as well as its expertise and
experience facilitating redevelopment projects across Florida.
Build on past experience.
Parties at the Former Spellman Engineering site charted
new territory in addressing stigma and other site issues.
Today, thanks to the changes to CERCLA when the bona
fide prospective purchase (BFPP) provisions of the 2001
Brownfields Revitalization Act were added, the availability
of enviromnental insurance and newly-developed EPA tools
like the site's CPO Agreement and Ready for Reuse (RfR)
Determinations, resources for redevelopment are more widely
available. Prospective purchasers can contact EPA site teams to
learn more, or see the Resources section on the next page for
additional information.
Conclusion
Local governments can play a unique leadership role in
cleanup and redevelopment projects.
As the organizations responsible for their communities' general
welfare, local governments are particularly well-positioned to
host redevelopment proj ects, bring together diverse stakeholders
to discuss site cleanup and reuse opportunities, and use
planning tools and incentives to foster positive site outcomes.
In Orlando, when the third-party approach proposed for the site
became unviable, the City's willingness to voluntarily clean up
the site enabled the project to move forward.
The design of site remedies can reflect and incorporate
plans for a site's reasonably anticipated future land use.
Site contractor ARCADIS designed the site's bioremediation
system so that all piping and equipment would be buried
underground, underneath LHPS' new ball field complex, and
connected to a single delivery line, allowing for site remediation
while optimizing the property's land area for recreational use.
EPA's 2010 ESD for the site provided the technical flexibility
The recent history of the Former Spellman Engineering
Superfund site illustrates how early engagement, community
leadership, collaborative partnerships and flexible long-term
planning can protect human health and the enviromnent and
enable site reuse. Today, the City's voluntary cleanup of the
site is underway. At the same time, LHPS has been able to
return 18 acres of the Lake Highland property to productive
use, providing much-needed sports fields and parking. Looking
longer term, the City and OUC are exploring opportunities for
remaining portions of the property to encourage mixed-use
redevelopment near public transit facilities.
In Orlando, Florida, the local government lias led a complex
redevelopment project that lias brought the community together
with diverse organizations and partners. In turn, the City and
EPA's shared initiative lias led to a voluntary cleanup of the site
and new opportunities, providing one of the leading examples
of how early engagement in the Superfund process can lead
to the protection of human health and the enviromnent and
redevelopment success.
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Engaging Early in the Superfund Process, Enabling Cleanup and Reuse
THE FORMER SPELLMAN ENGINEERING SITE IN ORLANDO, FLORIDA
Sources and Resources
Sources
Images and maps for this case study were obtained from EPA Region 4, FDEP, the City of Orlando, LHPS and site visits.
Resources
EPA CERCLIS site profile, including site decision
documents:
cumulis.epa.gov/supercpad/cursites/csitinfo.
cfm?id=0406763
City of Orlando Former Spellman Engineering site web
page:
www.citvoforlando.net/Spellman
EPA Superfund Redevelopment Initiative:
www.epa.gov/superfund/programs/recvcle
Lake Highland Preparatory School:
www.lhps.org
2001 Brownfields Revitalization Act and BFPP
information:
www.epa.gov/brownfields/aai/aaicerclafs.pdf
Park/Lake Highland Neighborhood Association:
www.pllina.com
Lake Formosa Neighborhood Association:
www.lakefonnosana.org
Enviromnental insurance information:
www.epa. gov/brownfields/insurance
United States
Environmental Protection
Agency
EPA Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
November 2011

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