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Chattahoochee Brick Company Site Remediation
Scope of Work
April 21, 2026
Introduction
The City of Atlanta is seeking an environmental remediation contractor to conduct remediation activities
at the Chattahoochee Brick Company (CBC) site. This cleanup is funded with a FY23 Bipartisan
Infrastructure Law (BIL) EPA Brownfield Cleanup Grant with a grant period of October 1, 2023, to
September 30, 2027. The remediation must meet the grant requirements specified in Cooperative
Agreement 02D61223 with the Environmental Protection Agency (EPA) and ensure compliance with the
State of Georgia Environmental Protection Division (EPD) Georgia Brownfield Program requirements.
The City of Atlanta may amend or extend this contract beyond the initial terms to accommodate the terms
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and conditions of future EPA grants awarded to the City of Atlanta or additional funds from other sources
allocated to this project, provided a market survey conducted by the City of Atlanta indicates that the
prices the contractor proposes are reasonable at the time the work will be performed.
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The Chattahoochee Brick Company Site Background
The CBC site, located at 3195 Brick Plant RAoad in the Chattahoochee neighborhood in northwest Atlanta,
is composed of three parcels totaling 75.4 acres. The site has been vacant/unoccupied since 2010. Gas line
easements and sewer lines exist on the south, east, and northeast sides of the site. Concrete foundations
of former on-site structures, paved areas, and roadways are present throughout the site. The paved areas
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are surrounded by wild regrowth of weeds, trees, and other vegetation re-establishing natural wetlands
and meadows.
In 2022, the City ofD Atlanta purchased the site and placed it under the purview of the Departments of
Watershed Management (DWM) and Parks and Recreation (DPR). Site remediation, floodplain restoration,
conversion to a public park with greenspace, recreational trails, park facilities, a memorial to convict
leasing, and preservation of the remnants of pre-1909 buildings present during the convict leasing period
are all anticipated. Visioning and planning for the site reuse are currently underway.
Chattahoochee Brick Company Site Previous Assessments and Remediation
The Chattahoochee Brick Company and General Shale manufactured brick from the 1890s to the 2010s.
After Brickmaking operations ceased and the buildings were demolished in the 2010s, General Shale
offered the site for sale. In 2016, Lincoln Terminal intended to build a 24-hour rail-to-truck terminal
including several large bulk fuel storage tanks at the site. In 2020, Lincoln Terminal partnered with Norfolk
Southern Railway Company (NSRC) to build the Chattahoochee Thoroughbred Bulk Transfer (TBT) Facility
to move ethanol, oil, and commodities between trains, trucks, and pipelines.
Prior to and during the course of the development planning, several Environmental Site Assessments
conducted as part of the leasing and development process identified four Areas of Concern (AOC) with
one or more contaminants present in soils at concentrations greater than the GA Environmental Protection
Division (EPD) Type 3 Risk Reduction Standards (RRS). Lead was identified in soils in all AOCs, while two
other metals, three SVOCs, and/or one VOC were identified in the AOCs. The contaminants of concern
(COCs) include:
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* AOC-1: An area approximately 24,400 square feet in size and located on a ridge with 15 to 30 feet
of fill. Contaminants of concern (COCs) include lead, cadmium, benzene, non-aqueous phase
liquid (NAPL), methane, and VOC vapor encroachment.
* AOC-2: An area approximately 8,000 square feet in size, which was identified as having high lead
concentrations in soil.
* AOC-3: An area approximately 183,000 square feet in size, located in the floodplain. COCs include
elevated lead, methylene chloride, and bis(2-ethylhexyl) phthalate concentrations in soil.
* AOC-4: An area approximately 192,000 square feet in size, located in the floodplain. COCs include
lead, arsenic, cadmium, and benzo(a)pyrene.
A Prospective Purchaser Corrective Action Plan (PPCAP), dated September 23, 2020, summarized the
previous assessments conducted at the site. The property was entered into the GA EPD Brownfield
Program in November 2020. The CAP cleanup standard consisted of a Type 5 RRS that allowed for the
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impacted soil to remain in place above non-residential clean-up standards at a depth below a 1-foot of the
surface barrier.
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In 2021, with remediation underway, NSRC cancelled its project due to community opposition. PPCAP
Amendment No. 1 was submitted to GA EPD to revise the soil corrective action plan, to propose RRS for
worker protection to be used under a property-wide Type 5 remedy. The revised cleanup plan included
excavation and disposal of impacted surfacAe soil (0-1 feet below the ground surface [bgs]) in exceedance
of Type 3 and Type 4 RRS to limit exposure to soils beneath the cap. Areas of remaining impacted soils
would be capped with a surface barrier (cap) of a minimum one-foot thickness of clean soil and/or crushed
brick. A brightly colored demarRcation barrier was placed beneath the cap. A Compliance Status Report
(CSR) dated December 30, 2021, states that the overall property was brought into compliance for non-
residential use through the implementation of a Type 5 capping remedy for soil across the entire site. A
total of 17,558 tons of impacted soil was excavated and sent for off-site disposal during the referenced
removal action. D
EPA Brownfield Cleanup Grant
The City of Atlanta's EPA FY23 Brownfield Cleanup Grant application (EPA Cooperative Agreement
#02D61223) was selected for an award with a project period October 1, 2023, to September 30, 2027. The
City of Atlanta issued a Procurement for a Qualified Environmental Professional (QEP) to develop and guide
the remediation of the Chattahoochee Brick Company (CBC) Site. CHA Consulting, Inc. (CHA), the selected
QEP, developed the cleanup plan and will oversee brownfield remediation of the CBC site.
Based on assessment and remediation documentation prepared by others, CHA prepared a Historic Site
Characterization Activities, Conclusions, and Recommendations (November 2024) summarizing the
previous Environmental Site Assessments, Corrective Action Plan (and amendment), the Compliance
Status Report, current status and remaining contamination, identified areas for additional investigations
and recommended retaining the Type 5 remedial approach to meet the Type 1 RRS in the 0 to 1 foot
surface soils. This report is included in the project manual as information for bidders.
CHA then performed a pre-design investigation consisting of collecting and analyzing soil samples at
various locations throughout the site to attempt to delineate the limits of required excavation and off-site
disposal of soils and presented its results and recommendations in the Design Phase Investigation and Soil
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Characterization Report for the Chattahoochee Brick Company Site (October 7, 2025). The report is
included in the project manual as information for bidders.
This investigation was completed to assess the environmental status of the CBC site relative to known
exceedances of the Type 1 RRS in surface soils previously not investigated. Activities completed included:
A. Collecting delineation soil samples around soil boring SB-18 for lead and polychlorinated biphenyl
(PCB) analysis.
B. Collecting delineation soil samples around four parent sample locations in Area of Concern (AOC)
AOC-1, and four parent samples located outside the designated AOCs for specific parameters
historically found to exceed the Type 1 RRS.
C. Collecting surface soil samples in AOC-2 for evaluation of surface soils in comparison to the Type
1 RRS.
D. Collecting delineation samples offset from previously completed excavation boundaries in AOC-3
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and AOC-4 for lead analysis in comparison to the Type 1 RRS.
E. Collecting bulk density soil samples to assist in developing remedial disposal costs.
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Additional design phase investigation was conducted to delineate the SB-18 and Tree Area in AOC 4 was
completed in March 2026
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The results, summarized below, determine the limits of the soil removal for the purposes of the design of
the EPA-funded site cleanup.
* AOC-1: CHA estimates 2R30 cubic yards of soil impacted with Contaminants of Concern (COC) above
the Type 1 RRS require excavation and off-site disposal in this area of concern.
* AOC-2: CHA estimates 60 cubic yards of soil impacted with COCs above Type 1 RRS require
excavation and off-site disposal in this area of concern.
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* AOC-3: Soil samples collected from surficial soil (0-1 foot bgs) offset from the central area of the
AOC, south of the petroleum pipeline easement and north of the southern excavation limits
exceeded the Type 1 RRS for lead, indicating that additional remedial soil excavation is required in
the central area of AOC-3 extending toward the west property boundary and petroleum pipeline
easement. CHA estimates approximately 520 cubic yards of soil impacted with COCs above the
Type 1 RRS require excavation and off-site disposal in this area of concern.
* AOC-4: Soil samples collected from surficial soil (0-1 foot bgs) offset from the southeast and
southern excavation limits exceeded the Type 1 RRS for lead, indicating that additional remedial
soil excavation is required in the southern and southeast area of AOC-4 extending to the property
boundary/Proctor Creek in the southeast area of the Subject Property. CHA estimates
approximately 2,680 cubic yards of soil impacted with COCs above Type 1 RRS require excavation
and off-site disposal in this area of concern. Note that this estimate includes the removal of
impacted soils in a ~0.65-acre area located within a wooded fenced areas located in the Southwest
corner of the property.
* Boring SB-18 Area: CHA estimates that approximately of 2,500 cubic yards of additional soil with
PCBs may require removal from the subsurface soils surrounding SB-18. An additional design
phase investigation was conducted on March 2026 to determine the limits of the excavation and
determine what percentage of this volume will require disposal as hazardous waste under the
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Toxic Substances Control Act (TSCA) due to the presence of PCB concentrations greater than or
equal to 50 parts per million (ppm).
* Boring GP-6 Area: CHA estimates 80 cubic yards of soil impacted with COCs above Type 1 RRS
require excavation and off-site disposal in this area of concern.
* Boring GP-12 Area: CHA estimates 60 cubic yards of soil impacted with COCs above Type 1 RRS
require excavation and off-site disposal in this area of concern.
* Boring SB-30 Area: CHA estimates that 170 cubic yards of surface soil impacted with chromium
above the Type 1 RRS require excavation and off-site disposal.
* Bulk Density Sampling: the bulk density of the on-site soil/materials ranged from 1.2 to 1.6 grams
per cubic centimeter (g/cm3).
In summary, CHA estimates approximately 3,800 cubic yards or an estimated 5,700 tons of soil require
excavation and proper off-site disposal to bring surface soils Tinto compliance with Georgia EPD Type 1
residential RRS in the areas shown in the attached map. In addition, CHA estimates that approximately
2,500 cubic yards of additional soil with PCBs may require removal from the subsurface soils surrounding
SB-18. F
EPA FY23 Brownfields Cleanup Grant Scope of Work
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EPA Project Officer Substantial Involvement - The EPA Project Officer will be substantially involved in
overseeing and monitoring this Cleanup grant. The City of Atlanta, QEP, and the contractor will have regular
meetings with the Project Officer to discuss compliance with the work plan. The Project Officer will be
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notified as soon as problems, delays, or adverse conditions are known that might delay the ability to meet
the outputs/outcomes in the Scope of Work. The Contractor will work closely with the City of Atlanta
Project Manager, the QEP, and the EPA Project Officer in the successful implementation of CBC Cleanup
Grant Scope of Work Tasks, as described below:
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Task 1: Project Management and Reporting
Task 2: Community Involvement
Task 3: Brownfield Cleanup Planning
Task 4: Cleanup Implementation and Completion
Task 1- Project Management and Reporting
The Contractor will work with the QEP and the City of Atlanta Project Manager to complete the Program
Management and Reporting requirements listed in this section.
A. Kick-off Meeting: The City of Atlanta Project Manager, the QEP, the EPA Project Officer, and the
Contractor will participate in a project kick-off meeting to review the remediation scope, roles,
responsibilities, and schedule. Additional team meetings during the contract period are
anticipated.
B. Final Performance Reporting/Closeout report: In accordance with EPA regulations 2 CFR Parts
200.344, a Final Cooperative Agreement Performance Report is required within 120 days after the
expiration or termination of the approved project period. This report will include a summary of
the activities completed with EPA funds, performance outcomes/outputs, description of problems
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encountered, comparison of actual accomplishments with the anticipated ones, project schedule
and milestones, and the budget summary during the entire grant project period, including the last
quarter. The Contractor will provide information regarding the remediation to be included in the
Final Performance Report, including but not limited to waste disposal manifests/bill of lading,
OSHA training certificates for all staff, and certified payrolls for all prime contractors and
subcontractors to verify Davis Bacon Compliance.
Task 2: Community Involvement
Community Involvement is an essential component of the City of Atlanta's (City) Environmental Protection
Agency (EPA) Brownfields Cleanup Grant. As required by the Cooperative Agreement, the community must
be informed of the funded cleanup activities per a site-specific Community Involvement Plan (CIP). The
CIP provides specific opportunities for the public to be informed and provide comments on the proposed
cleanup options that will be considered for the site. The Contractor will participate in the community
engagement activities listed below. T
A. Community Meetings: Community meetings will be held prior to, during, and immediately
following the completion of the cleanup activFities. Community meetings will be held near the CBC
site. The Contractor will attend and present information about the CBC remediation at said
community meetings.
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Task 3: Brownfield Cleanup Planning
A. Federal Cross-Cutting Requirements: EPA requires compliance with Federal Cross-cutting
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requirements including but are not limited to OSHA Worker Health & Safety Standard 29 CFR
1910.120; National Historic Preservation Act; Endangered Species Act; and Permits required by
Section 404 of the Clean Water Act; Executive Order 11246, Equal Employment Opportunity, and
implementing regulations at 41 CFR 60-4; Contract Work Hours and Safety Standards Act, as
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amended (40 USC 327-333) the Anti-Kickback Act (40 USC 276c) and Section 504 of the
Rehabilitation Act of 1973 as implemented by Executive Orders 11914 and 11250.
1. National Historic Preservation Act-Section 106: As part of compliance with the National
Historic Preservation Act, New South Associates, a subcontractor to CHA, completed the
Cultural Resources Assessment, Chattahoochee Brick Company Site Brownfield Investigation.
After reviewing the archaeology of the CBC and the areas requiring remediation, their
recommendation for AOC-2 is: This AOC is located in the former Industrial area, and
remediation may impact industrial resources. Archaeological monitoring is recommended.
The monitor should record industrial features that may be exposed, but these features would
not require further treatment. The monitor should be alert to the potential presence of pre-
contact features, which would require documentation and evaluation. In addition, given the
unknown location of the "temporary cemetery" as well as the potential for unmarked graves
on the property as a whole, a human remains response plan will be prepared before
remediation should human remains inadvertently be discovered. None of the AOCs are in
locations where cemeteries are believed to have been present, and they do not require
special treatment. The Contractor will work with the QEP and New South to implement the
Human Remains Discovery Plan. The plan will be included in the project manual/bid
documents and will identify what steps to take to be observant of human remains and
subsequent actions should they be encountered.
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2. Compliance with the Davis-Bacon Act of 1931: The remediation must comply with Davis-
Bacon (DB) Act prevailing wage requirements and associated U.S. Department of Labor (DOL)
regulations for all construction, alteration, and repair contracts and subcontracts awarded.
All laborers and mechanics employed by contractors and subcontractors are covered by Davis
Bacon requirements for all construction work performed at the CBC site. Recent and
applicable wage rates are available at the U.S. Department of Labor (as posted on
https://www.dol.gov/whd/programs/dbra/)
The QEP and/or its subconsultant will work with the Contractor to verify that it and any
subcontractors comply with DB provisions. A sufficient number of employees will be
interviewed to verify that the appropriate wage rates are being paid by contractors and
subcontractors. Interviews will be recorded in Standard Form 1445. Certified payroll
documentation must be provided by all on-site workers. The QEP will review payroll data for
DB compliance and attach certified payroll documentation to a final DB Compliance report.
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Task 4: Cleanup Implementation and Completion
A. Completion of Cleanup Activities: The Contractor will prepare and follow its own OSHA-compliant
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Health and Safety Plan and Environmental Management Plan and will provide it to QEP and City
for review. The QEP will monitor the site cleanup that will be conducted by the remediation
contractor.
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a. Task: Prepare Health and Safety Plan Prior to beginning corrective action work, site-
specific Health and Safety Plans (HASPs). These documents will outline potential hazards,
the level of peRrsonal protection to be used, and the procedures to be followed for
monitoring and emergency situations at the Subject Property. It is assumed that the
fieldwork will be performed in Level D personal protection (i.e. steel-toed boots and hard
hats). The contractor's personnel and subcontractors shall meet the requirements of the
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Occupation and Safety and Health Administration (OSHA) Standard 1910.120.
B. Excavation and Off-site Disposal of Contaminated Soils (this is from recent ABCAs):
Contaminated soils as identified in the Design Phase Investigation and Soil Characterization Report
for the Chattahoochee Brick Company Site (October 7, 2025) and summarized below and
illustrated in the map will be excavated, characterized for disposal, and properly disposed of off-
site at a properly permitted facility. As previously indicated, based on the delineation activities
performed at the Site, CHA estimates that approximately 3,800 cubic yards or an estimated 5,700
tons (based on a bulk density range of 1.2 to 1.6 grams per cubic centimeter) of soil require
excavation and off-site disposal across AOCs and additional corrective action areas.
* AOC-1: 230 cubic yards
* AOC-2: 60 cubic yards
* AOC-3: 520 cubic yards
* AOC-4: 2,680 cubic yards
* Boring SB-18 Area (PCBs): 2,500 cubic yards (currently assumed that at least 100 cubic
yards will require management as TSCA hazardous waste)
* Boring GP-6/ Boring GP-12/Boring SB-30 Areas: ~310 cubic yards combined
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Contaminated Soil Disposal Records: Remediation and transport of excavated soil shall be completed
in accordance with federal, state, and local rules and regulations, specifically, regulations 49 CFR,
Subtitle B, OCGA 391-3-19, 46- 11 and City of Atlanta Code of Ordinance Chapter 74 and 150. Approval
from the disposal facility for acceptance of waste materials shall be obtained in writing before
transporting excavated soil from the Subject Property. The Field Team Leader or field sampling team
will record the following to document proper disposal of contaminated soil leaving the Subject
Property:
* Waste Profile(s) and associated profile number(s) from the receiving landfill(s)
* Waste manifest numbers.
* Disposal ticket numbers and associated tonnage
* Transporter company and truck number
The following actions are part of the site remediation:
1. Obtain final land disturbance permit in coordination with CHA.
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2. Installation of site controls at the Site, including the survey and marking of utilities and
predetermined excavation areas, installation of temporary construction fencing and erosion
controls around the perimeter of the propoFsed excavation areas and associated staging areas.
Additionally, the perimeter of the proposed excavation area will be protected to reduce the
potential for surface water from draining into the excavation.
3. The construction of a temporaAry soil containment pad(s) and decontamination pad, as
appropriate.
4. Tree removal in the ~.65 acre wooded fenced area at the Southwest corner of the site per process
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to be determined.
5. Excavation of contaminated/source soils delineated in each AOC and sampling location as detailed
in the Design Phase Investigation and Soil Characterization Report (October 7, 2025) for the
ChattahoochDee Brick Company Site and direct loading of material in dump trucks, dump trailers,
and/or roll-off containers for proper off-site disposal at a Subtitle D (non-hazardous waste) landfill.
6. TSCA soils near the former boring SB-18 with PCB concentrations greater than or equal to 50 ppm
will require off-site disposal at a properly permitted Subtitle C (hazardous waste) landfill.
7. The contractor shall collect waste pre-characterization samples before commencing with the
excavation activities and obtain written authorization for the selected disposal facility to accept
the waste, the material requiring off-site disposal will be directly loaded into dump trucks/trailers
for transport to a Subtitle D (non-hazardous) or Subtitle C (hazardous) landfill/disposal facility, as
appropriate.
If unplanned materials are encountered during the excavation activity, the material will be placed
on temporary soil containment pads while awaiting characterization and approval by the disposal
facility. Soils requiring off-site disposal and temporarily staged on-site will be covered with
polyethylene sheeting that is properly secured.
While not anticipated, any soil requiring dewatering before transport to the disposal facility will
also be placed on a temporary containment pad and covered until it is shipped off-site. Water that
accumulates on the containment pad, if any, will be placed into drums for waste characterization
and off-site disposal.
8. Confirmation soil sampling will be performed by CHA.
9. Placement of demarcation barrier in excavated areas.
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10. Clean fill will be imported into the Site and placed in the excavation to match the surrounding
grades. Clean fill will demonstrate compliance with Georgia Type 1 RRS for surface soils.
11. Following the completion of the backfilling areas, The disturbed areas will then be seeded and
mulched to establish vegetative cover.
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