1. 1
Brownfield Cleanup: Analyzing Remediation
Methods
By David Garcia
Submitted to Professor Rick Zimmer
Department of Urban and Regional Planning
University of Cal Poly Pomona
Spring Quarter 2011

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Table of Contents
Abstract 3
PurposeStatement 4
Literature Review 6
Methodology 15
Analysis 19
References 24
Appendices 27

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Abstract
Research will determine suitability of a particular Brownfield site, pursuant
to proper assessment and remediation methods. The premises is to decide
whether the specific location, selected by the Lead Agency, is adequate and
will not impose serious harm or danger upon public health, once remediated.
Potential stakeholders affecting project completion will be noted, especially
those relating to the economic, societal, and environmental impact of the site.
In addition, examining the usage of health-related statutes and legislation,
through guidance from Government Agencies like the EPA and CEQA.

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Purpose Statement
In the past decade, a great deal of attention has shifted toward the
redevelopment of Brownfield sites, defined by the Environmental Protection Agency
(EPA) as abandoned, idle or underutilized industrial and commercial facilities where
expansion or redevelopment is complicated by real or perceived contamination
( Meyer 2000 ). According to Peter Meyer, sites which lay situated along older,
dilapidated parcels of land pose inherent risk for developers. The degradation of such
properties remains intrinsic to communal identity for years, even decades, resulting in
unpleasantness and community stigma. Areas which were once eclectic centers of
commerce and industry, become blighted, disjointed, and perceived as unsanitary, due
to high concentrations of contaminated particles. As a result, land remains inhibited
from community plans, causing a process of decay. Idle, contaminated properties are
often located near commercial or residential settings, and may include:
• Abandoned Train yards
• Oil fields
• Landfill sites
• Gas Stations
The surrounding landscape, environment and ecology are afflicted
by Brownfield risk factors. Endangered species or habitats may require urgent care
and protection, especially those on the brink of extinction. Through habitat
conservation, the population may return to fruition. An area’s water supply may be

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compromised if Brownfields are left idle and unmanaged. Through filtration and
extraction of harmful chemicals like lead, alkaline and acid, water can be restored
to sanitary levels. Air quality may be the most vital element to consider, having a
lasting effect on the resident population. The potential for developing chronic,
respiratory conditions such as asthma, lymphoma and lung cancer can result from
weakened immune systems in connection with hazardous land.
Potential Stakeholders have a vested interest in redeveloping contaminated
properties. Many are active members of a city’s redevelopment agency, occupying
various positions within the local planning commission. Other stakeholder’s are
members of the general community, whose tax base allows for funding of projects.
Cohesion of socio-economic and environmental factors allows Brownfield
projects to define the region in which they exist. Coexisting with surrounding
commercial, residential or industrial areas, Brownfields come to symbolize change,
while providing vast economic opportunity.

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Literature Review
Due to the direct and indirect effect on land and property value,
consideration of contamination and solutions to it have emerged in significance in the
last decade ( Remediating Contaminated Land 2011 ). In recent years, new policies
and laws from the State and Federal Government, have assisted with proper
management and handling of contaminated site risks. For developers, it
is crucial to fully understand the terrain they are navigating. Every square foot must be
considered, both above ground and below. It is a delicate process requiring ample
research, scrutinized monitoring and strategic oversight . While virtually every state
allows consideration of risk in some fashion as part of their cleanup process, in most
jurisdictions, the manner by which risk is considered is still evolving ( Reott and Grayson
1998 ). Thus, developers must rely on similar case studies to decide on appropriate
action. The hazards and obstacles developers must overcome, are often,
insurmountable. For this reason, it is crucial that the Lead Agency familiarizes itself
with all major and underlying risk factors affecting health and future site potential.
Site Risks
Developers should consider the target area’s scope and existing conditions.
Location, size, and site configuration are just a few of the characteristics
associated with site risks. Location is primary – it cannot be changed. If the
property is small, however, there may be opportunities to combine it with adjacent
property as a means of maximizing redevelopment options ( Obrien and Gere ).
Location is vital, when decisions for appropriate action are made. Sites which

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lay along residential areas, can often times, be linked with existing infrastructure,
including water, gas, and electricity. In Pennsylvania, the city of Johnstown
enacted a site cleanup and remediation over a former Steel Company.
One of the main objectives for their plan, was tapping into existing infrastructure,
using careful precision and modification. Effectively, the Johnstown Redevelopment
Authority was awarded substantial grant money and earned the cooperation of various
creditors and investment agencies ( Brownfields EPA Region III 2002).
Plot and Land search tools are the ideal solution for any property developer.
One challenge of selecting a Brownfield property is the size of the plot. An old town
center petrol station or workshop might only occupy a relatively small footprint. But
because of economies of scale, most property developers are only interested in
building 30 or more units at a time ( Brownfield Development 2010). Although gas
stations carry a relatively light footprint and are smaller in comparison, Developers
may choose to go with a larger site, where profit can be maximized. This selection
method can sometimes create uneven balance and apportionment for Brownfield sites,
but ultimately, it’s the developer’s discretion.
New standards have been implemented to gauge which sites are best suited for
site selection. According to Evans Paull, the Northeast Midwest Institute has analyzed
various lot-sizes, to propose a common standard for Brownfield sites. The study
included average lot size, average investment and amount of jobs created:
o Mean site size: 5 - 6 acres
o Median site size: 3 – 4 acres

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o Mean site investment: $20 - $25 million
o Mean jobs created or retained (80 – 100 permanent full-time jobs
Exposure and Pathways
Exposure pathways can be defined as the manner by which a person or an
organism may be exposed to a chemical of concern or contaminant. A complete
exposure pathway consists of a source, a release from a source, a migration and
transport mechanism, an exposure medium (e.g., air) or media (in cases of intermediate
transfer), an exposure point, and an exposure route ( Mississippi Department of
Environmental Quality 2007). According to Dillon Consulting, exposure is illustrated
utilizing a Venn diagram, where overlap exists between Hazard, Receptor, and
Exposure Pathway. Key toxins and hazards include Petroleum, Hydrocarbon, Metals,
Chlorinated Solvents, Asbestos, and Mold. Receptors are unquestionably represented
by human populations including workers, residents, visitors, women, and children.
Elevation and surface features present other obstacles for developers to
overcome. The direction and position of land can sometimes cause spillage or
chemical release toward the direction of the grade. In addition, toxic vapor can seep
out of ground openings, posing new challenges and concerns. Absorption of toxic
substances along exposure pathways may occur by contact, ingestion or inhalation.
Types and usage of site can also determine the level and presence of contaminated
particles. Industrial sites tend to be the most hazardous and potentially volatile.
Industrial properties are typically contaminated with asbestos, heavy metals, volatile
organic compounds (VOCs), semi-volatile organic compounds (SVOC), and

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polychlorinated biphenyls (PCBs) from manufacturing operations at the property
(EPA 2010). By analyzing soil components and toxicity levels, developers can decide
what method of remediation to implement.
Financial Risk
Financial Risk is driven by the process needed to purify the site. Purification process
depends on types of contaminants present, toxicity level, and exposed pathways.
If a Brownfield has contaminated soil, the developer may choose to implement an
excavation and removal, or soil vapor extraction of the soil. Superfund sites, which
potentially are the most dangerous, may require greater technology and long-term
operation or maintenance, bringing uncertainty to investors . According to Risk and
Insurance analyst, Adam Bressler, lenders remain cautious about providing debt
financing on properties known for suspected contamination.
On a 565-acre site in Richmond Virginia, a former army Defense Supply Center
underwent treatment for on-site contaminants. A hydrocarbon removal was
conducted, with results indicating the presence of toluene, a solvent
which can cause neurological harm. Actual cost of the pilot study was $76,099,
consisting of $18,225 for capital equipment and $57,874 for operation and
maintenance. The unit cost of the pilot study treatment activities was $76/yd3, per
1,000 yd3 treated ( Office of Solid Waste and Emergency Response 2010 ).
Because of the multitude of risks stemming from Brownfield project, investors
and developers often buy Pollution Liability Insurance, which essentially, protects

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Brownfield-backers from third- party lawsuits. Offered by several insurance
companies, pollution legal liability insurance addresses the third party risk posed by
contamination, both pre- and post-remediation, among other things. An example of this
contingent risk includes possible claims by neighboring landowners and lessees
(Missouri Department of Natural Resources 2010). Our changing economy is leaving
local governments struggling to find new ways to provide economic growth and to
create jobs in an economic, social and environmentally responsible manner. The silver
lining of Brownfields is that they offer the opportunity to address multiple local needs.
Corroborating Site Risks and Remediation
Risk Management of Brownfield sites is often assessed utilizing a three-tiered
system, based on site characteristics. The tier system operates by analyzing human
and ecological risks, in a cause-and effect model. Decisions are made in each of the
three tiers to determine the best device for on-site remediation. Another approach
common to the study is the RAGS study. The Risk Assessment Guidance for
Superfund is used in collaboration with the EPA to address criteria incorporated into
the human health evaluation process. Base-line Risk Assessment uses qualitative and
quantitative analysis to describe exposure, toxicity, and risk characterization,
being compartmentalized into four major groups. The California Human Health
Screening Levels ( CHHSLs) is a useful tool, helping the Lead Agency assess
contamination, based on a list of 54 Hazardous Particles. Levels of Significance and
Thresholds must be followed during implementation of necessary mitigation measures.

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Tier System for Risk Management
The cornerstone of the Brownfields Program is a three-tiered risk-based process
for evaluating human health and environmental risks. These tiers are referred to as
Tier 1, Tier 2, and Tier 3 ( Mississippi Department of Environmental Quality 2002 ) .
The tiers are designed to allow the applicant to evaluate and determine appropriate
remedial options for site specific conditions. Tier 1 identifies site specific data, which
is then compared to a table of target amounts for on-site chemicals deemed to be
acceptable. Tier 2 gives the applicant the opportunity to perform a more
comprehensive evaluation of site-specific conditions. Revisions can be made to Tier 1,
in terms of how long-term remediation will be handled. Remediation goals can be
adjusted in accordance with any changes made to on-site data and specific
information. Tier 3 concerns the possibility of human health being jeopardized by trace
levels of contamination in connection with a set remediation goal. The ecology is also
considered using the same rubric. Land–use regulations are addressed in terms of
how to reduce or eliminate potential risk.
The State of Illinois utilizes a system referred to as TACO. The Tiered
Approach to Corrective-Action Objectives is a methods for deciding the precise amount
of remediation necessary for site cleanup. The TACO approach looks to conserve
expenditures, reduce heavy investment and find practical solutions toward
rehabilitating sites ( Illinois E.P.A 2007 ).

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Human Health Evaluation Process
In the current state, the California Human Health Screening Levels
provides a set of criteria for measuring site safety. The California Human Health
Screening Levels (CHHSLs or “Chisels”) are concentrations of 54 hazardous chemicals in
soil or soil gas that the California Environmental Protection Agency (Cal/EPA) considers
to be below thresholds of concern for risks to human health. The CHHSLs were
developed by the Office of Environmental Health Hazard Assessment (OEHHA) on
behalf of Cal/EPA, and are contained in their report entitled “Human-Exposure-Based
Screening” ( California Human Health Screening Levels 2005 ).
Steps for addressing immediate characteristics include identifying chemicals
of concern. The first step is recording CHHSL’s for chemicals occupying differing
forms of matter ( water, air, surface, sub-surface, etc. ) Also, measuring CHHSL’s to
determine cancerous and non-cancerous effects. Formulae are then implemented to
measure the amount of carcinogen present divided by the amount needed to cause
cancer overtime. Sites afflicted by toxic but immobile chemicals such as PCB’s, DDT,
and arsenic usually require a standard remediation. Other chemicals, whose
properties cause leeching into surrounding soil and groundwater, may require greater
detailed levels of extraction. In some cases, naturally occurring chemicals may exceed
state-regulated levels, however, Cal/EPA does not require the lowering of such
particles. An example of this is arsenic, which has a naturally higher concentration than
average-safe levels for residential, commercial and industrial use.

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Risk Assessment Guidance for Superfund
Helps provide various definitions used to address health concerns ranging
from cleanup expectations to the impact on human health. The Superfund program
seeks to locate, investigate, and clean up the worst hazardous waste sites throughout
the United States. In some cases, local governments may be held liable for
contamination at a site based on their role as a past or current owner or operator of a
contaminated site ( LGEAN 2010 ).
Cleanup Standards states a strong preference for remedies that are highly
reliable and provide long term protection. In addition to the requirement for remedies
to be both protective of human health, the environment and cost effective ( Office
of Emergency and Remedial Response 1989 ). The RAGS approach provides guidance
for selecting the proper remedy for site cleanup. The primary consideration
in selecting a remedy is that it be protective of human health and the environment, by
eliminating, reducing, or controlling risks posed across each pathway. Next, the lead
agency reviews any resulting public comments on the Proposed Plan, consults with the
support agencies to evaluate whether preferred alternatives are still appropriate,
and then makes a final decision. A record of decision (ROD) is written to
document the rationale for the selected remedy ( Office of Emergency and
Remedial Response 1989 ). An important procedure RAGS uses is data acquisition.
In general, types of data collected are identified and listed using full term as well as
the acronym. Most of the data is acquired during the course of remedial investigation/
feasibility study ( RI/FS).

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Baseline Risk Assessment
Baseline risk assessment focuses on quantitative and qualitative
variables, like natural hazards— such as catastrophic weather or seismic events
( Information Technology Sector 2009 ). In dealing with Brownfield projects,
Baseline risk often concerns potential for developing serious illness or disease
from on-site toxins. In a memorandum sent by John Clay, issues concerning
exposure to on-site chemicals are addressed, using both quantitative and qualitative
analysis. Where the cumulative site-risk to an individual based on reasonable
maximum exposure for both current and future land is less than 10, and non-
carcinogenic hazard quotient is less than 1, action generally is not warranted unless
there are adverse environmental impacts ( Clay 1991).

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Methodology
Premise
Initial assessment, proposed mitigation, and ultimate remediation may help
guide a contaminated site from obscurity to potential redevelopment. Utilizing
thresholds and screening levels, in accordance with quantitative/ qualitative
measures dependent upon human health, ensure the validity and integrity of the
Lead Agency toward rehabilitating the Brownfield site. Improving the Socio-Economic
and Environmental health of the area is a key priority.
Site Background
The study site chosen, a former Crown Coach facility in Downtown Los
Angeles, was suspected to contain substantial amounts of chemical and
biological hazards, affecting the immediate vicinity. Upon request by the
Los Angeles Community Redevelopment Agency, Camp Dresser and McKee Inc.
conducted a Phase 1 Environmental Site Assessment. The main objective of
the Phase 1 ESA, was to identify the presence of hazardous substances and petroleum
products on-site. Results and determinations of the Phase 1 Report were made in
accordance with information obtained by Camp Dresser and McKee. An interview was
later conducted with CRA Project Manager Dan Weissman. During a site
reconnaissance undertaken on March 14, 2008, the property was assessed for the
presence of solid waste, non-hazardous waste, polychlorinated biphenyls, air quality,
potential asbestos containing material, storage tanks, ground water, wastewater,

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and pesticide use ( Camp Dresser and McKee 2008 ). The property, encompasses
an area of 20.6 acres, being zoned as M3-1 and M3-2 ( heavy manufacturing and
industrial use. ) It is situated at an elevation of 225 feet above sea level, sloping
toward the south east. Previous uses of the site included manufacturing activities
until the late 1980’s, as well as being a small rail yard. In the early 1990’s,
early stages of soil excavation began, and in 1999, the property was entered into a
Voluntary Cleanup Agreement with Cal/EPA. Currently, the main lot is vacant and in
the process of remediation. ( Refer to Appendix B )
Historically, the site has been shared by many companies, with a heavy
emphasis on light-manufacturing. Between 1970 and 1984, Essick Manufacturing
Company occupied the buildings in the central and northwestern part of the facility,
which included five spray booths and one vapor degreaser. The Crown Coach
Facility originally operated a coach manufacturing facility, in the northern portion of the
site. The uses extended into railroad easements, coach building shops and railroad
lines which were once associated with the Amtrak rail yard on the east. Infrastructural
elements associated with the site include two sets of power lines crossing the property
from east to west, a sewer drain located at the southeast corner, as well as
groundwater wells and SVE equipment stored on-site and in close proximately to the
Amtrak facility. The subject property is currently owned by the state of California,
managed by the California Department of General Services. According to Project
Manager, Dan Weissman, CDM was unable to establish contact with past owners of
the site. Much of the site’s history was obtained via city records and past interviews.

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Various departments and agencies have assisted with site assessment and
analysis. The Department of Toxic Substance Control initially issued a No Further
Action Letter for the above 30-ft. layer of soil. Later, the DTSC stated the presence of
Volatile Organic Compounds was not properly delineated, and may have
recontaminated the top soil layer. Soil Vapor Extraction pilot studies were conducted on
various soil layers. The results indicated that an extensive SVE system could properly be
administered and utilized to purify ground-layer residuals. Additional tests included
borings being drilled at various locations on site, to evaluate underground sediment.
10 samples were collected for presence of petroleum hydrocarbons, in which only one
sample was found to contain a concentration of 68 milligrams per kilogram.
The presence of toluene and PCE were identified in over 50 percent of soil
samples, as well as trichloroethylene ( TCE ) along with the presence of 11 other
volatile and semi-volatile organic compounds. The Department of Toxic Substance
Control later concluded that maximum concentrations of 9,116 micrograms per
liter of PCE and 502 grams per liter of TCE were detected in a soil depth of 5-15 feet.
According to Camp Dresser and McKee, the presence of TCE and PCE were highest on
the Eastern Portion of the property. Their reports also concluded that estimated cancer
risk was around 6, which is considered acceptable by the EPA. CDA made note that any
type of redevelopment should incorporate ventilation and air ducts to effectively
remediate the risk of cancerous on-site particles.
In 2005, with oversight from the CRA, Soil Vapor Extractions were conducted
on shallow surface soil, within a 30 foot layer. A total of 29 pounds of Volatile Organic

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Compounds were collected and successfully removed during this period. Camp Dresser
and McKee concluded that since substantial amounts of VOC’s still remain in
deeper ground levels, lateral and vertical extension of the SVE system may need to be
implemented. In addition, a ground monitoring system would provide a backup
device, capable of detecting microbial contaminants on-site. Camp Dresser and McKee
also proposed tapping into the Amtrak Redondo Junction Facility, which borders the
subject property on the east, as a potential Renewable Energy Concept. In 2008,
Edward Song and Sibel Tekce of CDM, undertook a visual inspection of the property,
with questions being answered by Mr. Weissman, onsite. Non-Hazardous Wastes
were identified, including a long PVP pipe, an empty 55-gallon metallic drum, and
a partially embedded metal rod, which may have been connected with the site’s
previous railroad activity.

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Analysis
Variables
The following are a list of Qualitative and Quantitative measures critical toward
successful remediation of the study site, complying with CA. Human Health guidelines.
• Hazardous and Non-Hazardous Waste Substances
• Sub-Surface and Above Layer Soil
• Presence of Carcinogenic Particles
• Water Supply and Storage Tanks
∙ Transport Mechanisms and Exposure Pathways
• Existing Infrastructural Elements
• Topography
The variables were analyzed in terms of their on-site presence, hazardous
degree, and suitability level for cleanup. In addition, utilizing the 6th step in the
CHHSL’s Guide, which preserves human health by comparing on-site chemicals with
thresholds needed to cause harm. Given the sites’ history of manufacturing products
for the Crown Coach company, main hazzards and risks stem from historical usage of
machine shops, air-conditioning manufacturing, paint and spray booths. Over time,
much of the chemical contamination from such action, spewed beneath the soil.
Therefore, it was necessary to access the site’s subsurface layers and underground
water supply, which subsequently, may have been contaminated.

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As previously noted in the Site Background, shallow underground soil contained
the chemical liquid, toluene, often used in paint thinners and solvents. Left untreated
in large amounts, toluene can cause serious neurological harm, headaches, vision loss,
even death. On-site, the chemical was found in abundant concentrations in shallow
sub-surface layers. Through ventilation and Soil Vapor Extraction, the presence of
toluene will diminish over time. Safe levels of Toluene are around 100 ppm. A soil
extraction was also proposed in the Phase 1 document, to collectively remove any
remaining residual particles.
Other chemicals being remediated include trichloroethylene, ( TCE ) styrene,
grease, oil and tetrachloroethene ( PCE) whichis commonly used for degreasing
automobile parts. Pursuant to the sites’ product assembly history, the presence of
these toxic chemicals was highest along the eastern portion of the property. Based
on the findings, a complete soil removal was developed with a cleanup level of 10 ppm
of TCE. According to EPA Standards, safe levels of TCE are usually around 50ppm
(CHHSL 2005). Nearly 40,000 tons of VOC’s, lead, oil and grease was also removed
during this time. Recent implementation of deep surface SVE equipment, continues to
yield productive results.
Given the sites topography, with a general decline toward the southeast,
hazardous surface particles could move down the grade of the property, washing
away from the site, naturally depositing into sewage drains. This would help alleviate
and circumvent extensive remedial options, on areas where natural surface slope
exists. The main exposure mechanism and medium of concern is air. Wind can often

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blow toxic surface-residue across the site, creating new problems to manage.
( Refer to Appendix A )
During a site reconnaissance, undertaken by Camp Dresser and McKee,
No observable Storage Tanks were identified, either above or below ground. Storage
Tanks often cause leakage of hazardous chemicals, liquids or gas directly into surface
or sub-surface sediment. In addition, ground water can be severely comprised
if underground-storage tanks rupture or leak outward. This actualization was a
monumental relief for the Lead Agency, causing optimism and reassurance.
As previously noted in the Site Background, a cancerous risk of 1E-6 was
determined, based on chemical components, liquids and solutions whose properties
influence the creation of cancer cells. However, this threshold is deemed to be
reasonable by EPA Guidelines, and with proper vapor barriers and active ventilation,
this threat can be mitigated efficiently. Hazardous Wastes were either remotely
identifiable or non-existent. Non-Hazardous Wastes included pipes, metal rods, and
other objects possibly left over from manufacturing or railway activities previously
conducted on-site.
Evaluating the site’s current infrastructural- elements included Power Lines,
Sewage, Drainage, and an Amtrak facility offered as a potential renewable energy
concept. These utilities could help facilitate the remediation process of the site and
possibly invite ‘green’ energy sources to be used. The CRA has already given thought
toward utilizing the Amtrak grid located on the site’s Eastern portion.

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Similar Remediated Sites
Within the Phase 1 Document, other sites with similar backgrounds and located
within .5 mile radius from the Crown Coach site, were listed under the Comprehensive
Environmental Response, Compensation, and Liability Information System ( CERCLIS ).
National Aerosols Product Comp. is located along E 14th Street, .4 miles North West
of the subject property. This site has undergone a preliminary site assessment and
designated as low priority. The sites groundwater runs along a cross gradient from
adjacent properties, not constituting a major concern or health hazard.
Another site in close proximity, is the Western Lead and Metal Co. along
E 11th St. and .46 miles from the Crown Coach facility. This site constitutes a high
priority level for lead-based contamination. In response, an extensive soil extraction
was implemented, with nearly 2,500 tons being excavated and treated offsite, with
4-inch asphalt caps being placed over the main lot. Based on medium-level soil risk,
handlement of lead remedial activities and the propertys’ location, it does not
pose any inherent risk factors to the Crown Coach site.
Findings and Conclusions
Collaborating with Camp Dresser and McKee (CDM) the CRA continues to
oversee the current remediation process. Although much of the shallow surface layers
have been excavated and purified through soil and vapor extraction, deeper depths
remain susceptible to the presence of Volatile Organic Compounds. Deep-layer gas
monitoring will be used periodically, to check for upward migration of VOC’s.
The site has many assuring factors to enhance its credibility. Historically, there is no

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documentation of Herbicide or Pesticide Use on-site. The site lacks cultivation of
various trees , shrubs, bushes or weeds, indicating Herbicide usage would not have
been likely. Also, the presence of Polychlorinated Biphenyls was inconspicuous or
non-existent, fostering overall security of human health. The sites’ water supply
does not appear to be in grave danger, and through filtration, purification may
be possible. According to the Phase 1 Environmental Site Assessment, the subject
property was entered into a voluntary cleanup program, and listed as a low –level
priority. After recently speaking with Project Manager, Dan Weissman, the
time estimate is roughly two years for remediation completion, at which point, post-
remediation monitoring will likely occur. Through care, precision, and scrutinized
monitoring, this site will eventually be deemed safe, environment –friendly and
properly recognized as another Brownfield success story. In accordance, the CRA
has contacted a possible developer, Genton, demonstrating an interest in the sight’s
future potential, which at the present- time, remains unlimited.

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Appendix A- Soil and Groundwater Supply
Figure 1- A focusedmodel illustrating soil andgroundwaterconcernsin contaminatedproperties.

28. 28
Appendix B- Crown Coach Site Aerial
Figure 2- Anaerial viewof the CrownCoach Site facilitylocatednearEastWashingtonBlvd.