Site Assessment & Remediation
CHALLENGE A petroleum refining and distribution company had seen little progress moving their project towards closure with the regulatory agency. Report deadlines were outstanding and remediation systems were not operating efficiently delaying cleanup timeframes. The company’s goal was to achieve regulatory report milestones and successfully implement a long term remediation plan.
The project site was an active operating petroleum bulk storage terminal that had been in operation since the 1950’s. There were multiple releases over many years of different petroleum fuels including leaded and unleaded gasoline and cat-naphtha. Numerous site assessments had been performed. More than 51 monitoring and recovery wells had been installed to delineate a light non-aqueous phase liquid (LNAPL) plume. The LNAPL plume was approximately 15 acres in size, with downgradient dissolved phase contaminant plume approximately 0.25 miles from the source area, impacting a designated major aquifer. The plume still remained undelineated in the downgradient direction, preventing the preparation and submittal of the required regulatory report known as the Affected Property Assessment Report (APAR). The report was required by the Texas Risk Reduction Program (TRRP), under the Texas Commission on Environmental Quality (TCEQ) guidelines.
APPROACH In order to complete the delineation process, EarthCon conducted a fast-track assessment of the historical data and developed a plan for the installation of three additional monitoring wells. EarthCon installed and sampled the wells; compiled 25 years of historical data collected by numerous environmental consulting firms and prepared and submitted an APAR to the TCEQ. The existing remediation system operation time was increased by performing multiple modifications. Data collection and management procedures were implemented to track and document fluid and hydrocarbon recovery, equipment maintenance schedules, and manage compliance requirements associated with treated effluent and air emission discharges. Following approval of the APAR by the TCEQ, EarthCon met a stringent deadline set by the TCEQ for the preparation and submittal of a three-component Remedy Standard A, Response Action Plan (RAP) for long-term clean-up of the site. The RAP was approved by the TCEQ.
BUSINESS SOLUTION EarthCon’s remediation compliance and operations strategy met TCEQ’s regulatory deadlines and the client’s project milestones. Estimated cleanup timeframes were also reduced. An industry-specific engineering technician with strong troubleshooting and problem solving skills was dedicated to this project to perform day to day operations which resulted in increased productivity at the site and increased system runtime.
EarthCon developed a complex RAP within the framework set forth by the TCEQ. The result was minimal additional modifications of the interim recovery systems and significant long term savings to the client. EarthCon’s extensive knowledge of the TCEQ’s TRRP Texas Administrative Code (TAC) 350 rules, put a system in place to achieve clean-up goals in less than 15 years with low annual operation and maintenance costs, rather than the estimated 30+ years if the project had remained under the initial program.
Remedial Action Workplan – Scrapyard Decommissioning
CHALLENGE A client was preparing to decommission a former scrap metal recycling facility in operation in the Port of Stockton, Stockton, CA since the early 1970’s. Facility activities included sorting, consolidating, cutting and/or hydraulically compressing and stockpiling recyclable metals. For more than a decade, the site also operated a shredder to process items such as cars and appliances. The upper three to five feet of the 13 acre site contained significant amounts of scrap metal and debris mixed with soil.
The client needed to return the site back to the property owner in usable condition, meet industrial use criteria, and control project costs. EarthCon was contracted by the operator to prepare and implement a Remedial Action Workplan (RAW). Project oversight was provided by the California Environmental Protection Agency, Department of Toxic Substances Control (DTSC).
APPROACH EarthCon worked with the client and the DTSC to develop a remedial strategy that addressed the removal and disposal of “hot spot” soils impacted with metals, TPH, VOCs, PNAs, and PCBs and screening/reuse of the remaining material. This approach was selected because limited site assessment activities conducted by the client and the property owner suggested widespread impact from facility operations. In addition, the amount and variety of buried scrap metal and debris would have prevented grading and geotechnical certification for future reuse. Due to the large amount of buried debris at the site, all soil required excavation and screening to separate recyclable metal, trash, rocks, and soil.
Approximately 6,400 tons of recyclable metal were recovered, yielding approximately $1,550,000 for the client. Roughly 10,000 cubic yards of soil exceeded site-specific reuse criteria and was disposed offsite as California Hazardous Waste. The remaining soil, rocks, and clean import fill were blended to produce an engineered backfill product that was used to bring the site back to grade. Reuse of site materials saved disposal costs and the expenditure for import fill.
In addition to soil management, decommissioning activities involved the identification and removal of all concrete slabs, vaults, sumps, utilities, and drainage piping. Following completion of backfill activities, the site was graded for drainage, storm drains were installed, and a track pan for a new railway development was installed.
BUSINESS SOLUTION EarthCon’s remedial strategy was to excavate and screen the metal and debris laden soil from the entire site, segregate the most impacted materials for disposal, and use the remaining material to backfill and grade the site for future reuse. Utilizing this strategy, approximately 80,000 cubic yards of material that would otherwise have been disposed was used as backfill in accordance with the risk-based industrial use scenario negotiated with the DTSC. In addition, approximately 6,400 tons of recyclable metal were recovered, yielding roughly $1,550,000 for the client.
Remediation Design & Implementation
CHALLENGE The State was aware of an issue at the retail operation and EarthCon was contracted to conduct a Preliminary Site Assessment. During that assessment, 8.53 feet of free phase gasoline was observed in monitoring well MW-1. Based on the findings, MDEQ requested that EarthCon develop a Turnkey Remedial Action Package (TRAP) to address the petroleum soil and groundwater contamination. The TRAP was submitted, approved the following month and EarthCon installed a dual phase groundwater remediation system one month later.
APPROACH The facility was a small, corner gas station with tight quarters, a narrow alley way in the back, and a busy intersection with vehicle traffic along both sides with access to the pump islands and the store. EarthCon was tasked with installing a remediation system with minimal disruption to the existing gas station business and ensure a rapid remediation of the free-phase product in order to provide a more marketable property to the future owners.
BUSINESS SOLUTION EarthCon’s remediation strategy helped the client reduce their monthly remediation system use rate by 50% and maintain a system monthly run time of greater than 90%. The solution involved the redesign, installation, operation and maintenance of a trailer-mounted dual-phased used remediation system housed in a sound dampening enclosure to recover contaminated soil vapor, free-phase fuel and contaminated groundwater. The remediation system was located such that vehicle access to the store and pump islands was not impeded. Trenching was conducted during a period of ownership transition to minimize impacts to traffic flow. EarthCon worked with neighboring property owners to install off site monitoring wells. EarthCon technicians conducted monthly monitoring of the remediation activities, maintenance on the remediation system and conducted groundwater sampling. EarthCon project managers and senior engineers worked with MDEQ throughout the process to communicate remediation progress and generate the No Further Action letter for the site. Approximately 1,500 gallons of fuel was removed from the recovery wells over a three year period of remediation. The site was granted No Further Action status in 2010.
Brownfields — Assessment & Remediation
CHALLENGE A developer wanted to purchase a three-acre parcel in downtown Atlanta, Georgia for mixed-use redevelopment. To obtain a Limitation of Liability (LOL) under the Brownfield’s program, the client hired EarthCon to prepare a Brownfield corrective action plan (CAP). Due to delays in the sales and financing negotiations, the property closing was moved towards the end of the approved CAP’s site assessment/remediation activities schedule. This delay placed the project on a fast track schedule to have all assessment/remediation activities completed and obtain the Limitation of Liability (LOL) before scheduled construction activities could begin.
BUSINESS SOLUTION Within 90 days EarthCon was able to complete the entire project from inception to receipt of the Brownfields limitation of liability letter. The GA EPD featured this project in their 2009 State of the Environment report.
The approved CAP included site-specific clean-up criteria which led to EarthCon being able to pin-point areas of the site requiring soil remediation, and expedite delineation and excavation. To demonstrate that contaminated soils at depth were actually related to existing groundwater contamination, EarthCon prepared additional data submittals and met with Georgia EPD personnel to obtain same-day approval. This agreement allowed deeper soils to remain in place resulting in significant cost savings and kept the project on schedule. Further coordination took place between EarthCon and the client’s demolition contractor to conduct asbestos and TCLP testing of onsite materials and schedule assessment and remediation activities around ongoing demolition. The compliance status report was prepared for submittal and agency approval was received within two weeks.
Engineering & Design
Leachate Issues – System Analysis, Design & Construction
CHALLENGE A global paper and packing company was preparing to close a mill site. The company was seeking options to reduce the long-term Operations and Maintenance (O&M) costs associated with a landfill that had handled mill wastes. At the same time, the cost reduction options needed to comply with the State’s post-closure regulations. The regulations typically require on-site leachate treatment five years after closure. EarthCon was contracted to conduct initial O&M and evaluate leachate management alternatives. The landfill is in a remote area from any client operations or resources, and low temperatures and high snow levels are dramatic during the winter months. Therefore, an on-site leachate storage system would require heating and insulation and a telemetry system for remote monitoring on a 24/7 365 day basis, as well as local O&M support personne.
APPROACH EarthCon’s feasibility study resulted in the acceptance by the regulators of a leachate management alternative that provides less expensive long-term off-site hauling and disposal at the regional POTW. EarthCon’s alternative effectively included an on-site leachate volume reduction component as well as off-site leachate disposal in support of the post-closure cost reduction strategy. This alternative reduced up to 75% of the site’s leachate management costs for a typical alternative of designing and constructing an on-site leachate treatment system. That alone is projected to save the client hundreds of thousands of dollars in capital and operations costs over the length of the post-closure period. In addition, the alternative provided a 75% lower construction cost over other potentially feasible on-site treatment options that were evaluated. It also provided a superior relative resource use and sustainability index, as well as a long-term O&M cost reduction of potentially more than 50%. The alternative successfully achieved the regulatory flexibility thresholds established by the agency for off-site disposal to the POTW as the final leachate management solution. In summary, the approximate savings and cost reductions achieved by the approved leachate management alternative are:
- 75% reduction in the overall long-term post-closure cost versus on-site leachate management ($1,500,000 over 15 years);
- 75% reduction in one-time construction costs versus on-site treatment alternatives ($400,000); and
- 50% reduction in the routine O&M costs for the post-closure care period ($90,000/year).
The engineering evaluation was conducted by EarthCon in 2009, the recommended alternative was proposed to the client and regulatory agency in 2010, designed by EarthCon in 2011, constructed by Pantheon with construction oversight by EarthCon in 2012, and accepted by the agency as the final leachate management solution for the landfill in 2013.
BUSINESS SOLUTION EarthCon’s solid waste engineers identified an integrated leachate management approach. It was comprised of leachate generation, groundwater, and precipitation data collection as part of the routine O&M activities. In addition, EarthCon evaluated on-site and off-site leachate management alternatives in a feasibility study. The project also included the design and construction of the recommended and agency–approved alternative.
The feasibility evaluation looked at the existing leachate collection piping, impoundments, and off-site hauling and disposal operation in comparison to targeted improvements to this off-site disposal system, and numerous on-site leachate management technologies. A recommendation was made to close the leachate collection impoundments and construct a closed above-ground storage tank system. The design of this alternative reduces the total leachate hauling and off-site disposal volume by eliminating the collection of precipitation and avoids the more costly construction of an on-site leachate treatment system. The tank system design was prepared by and the competitive bidding process managed by EarthCon on the client’s behalf.
Pantheon, a sister company of EarthCon, was awarded the construction phase of work with construction oversight provided by EarthCon. During the competitive bidding and contracting process, complete independence between EarthCon, Pantheon, and the other bidders was maintained to achieve client purchasing requirements. Once the award was made to Pantheon, our working familiarity with each other enabled more effective project communication and management, while still maintaining an effective client/contractor relationship.
Vapor Intrusion Mitigation Design & Installation
CHALLENGE One of the largest retail pharmaceutical companies in Canada was in the process of timely expansion. As part of their due diligence effort, the client contacted EarthCon to conduct a Phase I Environmental Site Assessment. The project involved the redevelopment of a 40+ year old, 16,000 square foot building that had previously undergone numerous renovations. Most recently, the property had been used as an auto dealership and the results of the environmental assessment indicated petroleum product impact in the underlying soils. The Client asked EarthCon to address the potential for vapor intrusion into the store’s air space from the underlying impacted soils while staying within their three-month construction schedule.
APPROACH A decision had been made to maintain the original building structure. Therefore, any new design and install would need to be retrofitted. The structure contained multi-level slabs – one at ground level and another at basement level. The Client was on an aggressive construction schedule and multiple parties were involved in communications related to the design and implementation of the construction. The team included the owner, architect/designer, general contractor and sub-specialty contractor.
BUSINESS SOLUTION EarthCon developed and implemented a seamless vapor intrusion system design/install to meet the client’s opening schedule deadline. Project highlights included mitigation system design and permitting, along with successful interactive communications with the construction team to help the client achieve their store opening.
Groundwater/Surface Water Contamination Issues
CHALLENGE A client’s landfill liner systems and multi-layer final cover system were compromised. Ground and surface water contamination was encountered.
BUSINESS SOLUTION EarthCon’s investigation, design and permitting of alternative liner systems helped to control the escape of leachate and reduce the cost of post closure care by more than 50%.
Methane Issues– Methane Control System Design/Implementation
CHALLENGE Landfill had numerous vegetation kills, high methane readings in perimeter methane monitoring points, and sporadic readings in methane venting system. This led to regulatory questions regarding the effectiveness of the site’s overall methane control system.
BUSINESS SOLUTION EarthCon’s investigation led to a methane control system design and implementation that was approved by the regulatory agency and eliminated the requirement for further off-site investigation and monitoring.
EHS Compliance, Litigation Support, Permitting & Training
Environmental Health & Safety (EHS) Compliance
CHALLENGE An international energy company was operating numerous natural gas facilities in Alabama, Mississippi, New Mexico and Texas and ramping up construction efforts at newly acquired properties. With no in-house Environmental resources, the company turned to EarthCon for Environmental Health and Safety (EHS) inspection and training resources.
APPROACH Located on one of the country’s largest natural gas pipelines, the underground storage facilities required a stellar health and safety team to identify and avoid hazards. EarthCon’s EHS professionals conducted walk-through inspections of fire and safety equipment as well as noise monitoring. Monthly employee EHS seminars were conducted at multiple sites and based upon conditions, EarthCon developed customized safety curriculum, including quizzes to provide proactive steps to avoid accidents and mishaps. As part of the drilling operation inspections activities, safety violations were observed and EarthCon immediately shut down operations until the situation was remedied.
BUSINESS SOLUTION EarthCon’s integrated EHS programs have helped the client identify real hazards, as well as avoid catastrophic hazards and EHS violations. The customized EHS programs and facility visits have instilled a culture of safety at the various sites. On many occasions, the client has asked EarthCon to repeat lessons-learned sessions. One example is when an EarthCon professional noticed that grating and railing were missing from a mud-mixing container on a 16-wheel drilling rig, and he halted drilling. Another incident was when a contractor drilling water had a kickback that sent 1,200 feet of pipe into the air. No one was injured, but EarthCon’s EHS professional was on site to take photos at the time of the incident. He documented the hazards that occurred as a result of a drilling contractor’s mishap. The client used these photos as evidence and documentation in court proceedings. Due to our successful EHS performance on this contract, the client invites EarthCon to its annual EHS workshop, where we are the only consulting firm to offer EHS input to leading executives.
O&M Compliance Support
CHALLENGE A global paper and packing company was seeking an efficient means to implement an effective Operations and Maintenance (O&M) program at a closed former wood treating facility. The facility’s post-closure care permit set forth requirements for a groundwater recovery and treatment system to remove residual creosote from the subsurface and treat the groundwater to acceptable standards to allow for ultimate discharge to a municipal POTW. In addition to recovering and treating contaminated groundwater, the facility was required to routinely prepare and submit numerous compliance-related reports each year. These included timely submission of Groundwater Monitoring Reports, Waste Minimization Reports, Tier II Reports, Waste Summary Reports, Biennial Reports, and Waste Certifications to the state’s lead environmental agency. EarthCon was selected to help the client address these issues through a cost-effective approach.
APPROACH After reviewing the client’s goals and post-closure care permit, EarthCon’s professionals took on the role of the facility’s operational and regulatory “caretaker.” This enabled the client’s staff to concentrate on more pressing issues associated with operating facilities. An O&M program was developed and implemented to align with the company’s overall goals and meet all conditions of the post-closure care permit while maintaining regulatory compliance.
Before EarthCon’s involvement, the site had historically been pumping and treating thousands of gallons of groundwater daily using a total fluids removal approach with a maintenance-intensive biological treatment system. EarthCon developed a more cost-effective alternative and worked with the regulatory agency to implement a Monitored Natural Attenuation (MNA) approach for groundwater along with focused DNAPL recoveryc.
BUSINESS SOLUTION EarthCon’s approach helped the client reduce groundwater treatment and associated waste disposal costs by approximately $50,000 a year. At the same time, EarthCon’s regulatory compliance support helped the client avoid fines and other costly enforcement actions. The program has been successful for more than nine years.
Expert Witness – Soil Sampling Interpretation for Litigation Support
CHALLENGE An oil producing company was facing a civil lawsuit for $651,000 in environmental damages. The case involved a claim that approximately 1.13 acres of the approximately 170 acre property was heavily contaminated with petroleum-based product, and the claim was backed up by their Consultant’s sampling report. The remote property was adjacent to historic (50 year old) producing oil wells and including heavily overgrown woodlands and wetlands. The case was remanded to the Mississippi Oil and Gas Board for investigation and ruling on a request for the damages. EarthCon was brought in to review the data, provide an alternate plan and participate as an Expert Witness.
Access to the property, as well as onsite activities were subject to the scrutiny of the complainant. Repeated trips to the remote site were necessary to collect duplicate samples from complainant’s sampling activities.
APPROACH After a review of the complainant’s consultant report, EarthCon discovered serious errors in the legal complaint support documents. EarthCon subsequently performed a systematic soil sampling event in accordance with EPA sampling protocol, and demonstrated that the complainant’s data was biased and invalid.
BUSINESS SOLUTION EarthCon’s findings helped the client negotiate an agreed order with the Oil and Gas Board for a $15,000.00 remediation of visibly contaminated soil and elevated chloride concentrations. This agreed upon remediation was appealed by the complainant. The Mississippi Oil and Gas Board denied the claims of the Complainant, and ruled unanimously in favor of the EarthCon client.
Litigation Support – Technical Review
CHALLENGE A large natural resource corporation sold a photochemical mixing facility to a specialty products corporation in Florida. As part of the property transaction, the seller had agreed to reimburse the purchaser for “minor” environmental remediation and monitoring costs required by the Florida Department of Environmental Protection (FDEP) as part of closure of the existing underground storage tanks. Following the property transaction, the new owner proceeded with an extensive environmental investigation and remedial excavation, and submitted work plans to FDEP for a groundwater monitoring network in the shallow and deep aquifers. Following completion of these activities, the new owner demanded reimbursement of past expenditures and projected future costs in excess of $1,000,000.
APPROACH EarthCon personnel were retained to evaluate the remedial investigation and hazardous waste disposal activities conducted at the facility by the new owner. Our activities included a site visit, evaluation of different disposal options, and thorough review of investigation data collected at the facility since the property transfer. Through careful reconstruction of the different phases of the environmental investigation, it was determined that at several key decision points, the new owner had elected to install additional boreholes, or conduct unnecessary soil removal that were not warranted for site closure. In addition, we were able to identify alternative disposal facilities, which resulted in significantly lower costs. Finally, we were able to negotiate a greatly reduced scope of work with the (FDEP) for the groundwater investigations, which reduced the number of permanent monitoring wells from eleven to five.
BUSINESS SOLUTION After submittal of several technical reports and the subsequent negotiations, the purchaser agreed to a negotiated settlement and release of liability. These activities resulted in the client saving in excess of $600,000.
Site Characterization — NPL Site Under CERCLA Superfund Program
CHALLENGE A former industrial manufacturing facility in the southeastern United States had been placed on the National Priorities List (NPL) under the Federal Superfund program. During the course of completing the Remedial Investigation (RI), four inorganic analytes (metals) and chlorinated volatile organic compounds (CVOCs) were detected in groundwater above groundwater cleanup standards. In response, USEPA issued a Record of Decision (ROD) requiring a site-wide groundwater remedy for the metals at an estimated cost of over $20,000,000 and implementation of a separate remedy to address CVOCs in an isolated area of the property at an estimated cost of $3,000,000.
APPROACH EarthCon personnel were retained by the PRP to evaluate alternatives to the remedy for metals in groundwater. After bifurcation of the Remedial Design process to allow the CVOC and metals remedies to track separately, a focused investigation of metals concentrations was conducted to determine representative metals concentrations in groundwater. The focused investigation included the design of refined purging and sampling protocols to reduce artificial entrainment of soil particles that might contain naturally-occurring metals. Additionally, the groundwater recovery and treatment program for CVOCs specified in the ROD was reevaluated in order to determine whether treatment of groundwater was necessary prior to discharge to the publicly-owned treatment works (POTW).
BUSINESS SOLUTION The $250,000 focused study resulted in the determination that metals were not present in groundwater and that remediation was not necessary. After significant negotiations, USEPA and the state agency concurred and the $20,000,000 remedy was vacated. In addition, an Explanation of Significant Difference (ESD) was developed to eliminate the treatment of recovered groundwater impacted by CVOCs. As a result of direct discharge of the recovered groundwater, the portion of the groundwater remedy for the CVOCs was cut in half (approximately $1,500,000).
Pulp & Paper Manufacturing Company Site Management Program
CHALLENGE A former wood treating facility hired an international consulting firm, who generated 200 tons of hazardous waste as part of a corrective action on the property. The client had to pay a large tax assessed by the State when the waste was disposed. EarthCon was hired to provide Site Management Program (SMP) services for the facility’s portfolio. These tasks included the management of a wide range of site portfolio issues to help the client stay in compliance, manage risks and allocate appropriate environmental reserve funds.
APPROACH During the course of EarthCon’s Site Manager’s project review, he identified opportunities for savings in the State’s hazardous waste tax code. Additional research paid off when he discovered an exemption that afforded significant tax savings. After notifying the Department of Revenue personnel of the applicability of the exemption, the client’s consultant and the disposal firm who collected the taxes on behalf of the state were also informed.
BUSINESS SOLUTION EarthCon’s review helped the client immediately recover more than $8,000 in taxes that were mistakenly assessed. We implemented steps to help the client receive additional future tax reductions, estimated at an average annual savings of $5,000 to $10,000 over the course of the following five years.
International Manufacturing Company Site Management Case Study
CHALLENGE A project manager for a large, international manufacturing company was seeking a means to reduce their management burden across a portfolio of closed landfill sites. Having overseen the management of these sites for several years, the client felt that all the cost savings had been captured by their current consultants, but decided to try EarthCon’s Site Services approach.
BUSINESS SOLUTION EarthCon transitioned the sites from multiple consultants and delivered nearly $60,000 in reduced annual costs during the first year under the SMP, with more savings opportunities still being evaluated and implemented. The client was delighted with EarthCon’s results and expressed that their expectations were exceeded. The program gave them more time to deal with higher priority matters now that their legacy sites were under a comprehensive management program that produced real savings and maintained compliance.
Forest Products Company SMP Case Study
CHALLENGE The client was seeking a way to reduce the reserves and management commitments he was carrying for a portfolio of sites. The most important criterion in his selection process was the ability to reduce the costs of managing these sites while maintaining compliance. His portfolio included closed industrial waste landfills, active and closed wood treating facilities, an active resin manufacturing plant and an active paper mill. The sites had a variety of soil and groundwater contamination issues. There were state and Federal agency requirements for long-term monitoring, reporting and inspections under hazardous waste, solid waste, and petroleum-release remediation regulations. In addition, a number of sites had remediation systems in place using a range of treatment technologies.
BUSINESS SOLUTION For the past nine years, EarthCon has been managing these sites, and every year the cumulative costs have decreased while handling all site requirements at times including scope increases. During 2010, the client’s project costs were reduced by $201,000 (10.16%). In 2009, EarthCon’s Site Management Program reduced the client’s costs by $195,000 (9.57%).