Environmental Engineering
RCRA Remedy Design Eliminated $1 Million in Unnecessary Remediation Costs – Sedalia, Missouri
This 136-acre transportation site was placed under the Resource Conservation and Recovery Act (RCRA) program due to lead and asbestos impacted soil, and volatile organic compounds (VOCs) impacted groundwater. Upon inheriting this project, The Forrester Group prevented more than $1 million in unnecessary remediation costs by re-engineering and renegotiating the soil and groundwater remedies recommended by the previous consultant with the EPA and the MDNR. This included eliminating a synthetic liner and sand base for the liner in the landfill and also eliminating the need for one of two groundwater recovery trenches.
We obtained approval for a landfill to contain the lead and asbestos-impacted soil and VOC-impacted sludge. The landfill was designed as an alternative capping system utilizing slopes, soil type, and vegetation to minimize infiltration without synthetic liners or sand drainage systems. State-of-the-art 3-D civil engineering software was used to design the earthwork cut and fill and site drainage.
The Forrester Group managed construction of the landfill and subsequently obtained closure for soil. Completion of this work required coordination and negotiation with a number of agencies relating to hazardous wastes, stormwater, air, and asbestos regulations. We are also meeting agency requirements that will lead to risk-based closure for groundwater.
CERCLA RI/FS and Remediation Approach Reduced Costs and Prevented Emergency Removal Order – Ogden, Utah
The Forrester Group conducted a Remedial Investigation/Feasibility Study (RI/FS) and interim corrective action at this 3.5-mile-long active rail transportation and maintenance complex. Potential issues included multiple plumes, impacts to drinking water, off-site migration of light non-aqueous phase liquids (LNAPL) and dense non-aqueous phase liquids (DNAPL) hydrocarbons, and groundwater impacted with a variety of chlorinated volatile organic compounds (CVOCs), including vinyl chloride. One plume covered an area of approximately 60 acres, and another plume covered an area of approximately 4.4 acres.
As part of the RI/FS, The Forrester Group’s work included plume delineation, source investigations, and a groundwater fate and transport assessment. The Forrester Group also managed the implementation of interim and final remedial measures.
The project team worked extensively with regulators to resolve known concerns. Team members also negotiated solutions that reduced overall remediation costs (while still providing enduring solutions) and provided proactive responses to minimize regulatory intervention. The advocacy plan also persuaded U.S. EPA Region VIII to withhold a proposed Emergency Removal Order to excavate contaminated sediment at an impacted pond. This prevented potential environmental impacts and more than $50M in unnecessary remediation costs.
Remediation Eliminates Need for Long-Term Recovery Efforts – Salem, Illinois
The previous consultants for this Illinois railroad site had developed a Remedial Action Plan (RAP), but it failed to provide a clear pathway to a No Further Remediation (NFR) letter. The Forrester Group’s site management strategy for addressing the light non-aqueous phase liquids (LNAPL) eliminated the need for ineffective long-term diesel recovery efforts and long-term groundwater monitoring.
Under the supervision of the Illinois Environmental Protection Agency (EPA) Site Remediation Program (SRP), we identified and addressed data gaps in the existing SRP documents, satisfying the concerns of the SRP Project Manager. We also revised the RAP to establish an agency-agreed pathway to an NFR letter.
We engineered specifications for closure of an oily impoundment using soil solidification, excavation, and disposal methods; decommissioned a concrete maintenance pit; and installed four LNAPL recovery trenches, each several hundred feet in length. To address residual LNAPL, we injected an innovative chemical, Biosolve, into the soil and groundwater.
Start to Finish Action Plan Delivered Results Within One Week at TCE, PCE, Vinyl Chloride-Impacted Site – Wichita, Kansas
The Kansas Department of Health and Environment (KDHE) ordered our client to investigate and clean up this Wichita, Kansas, chemical storage and distribution facility site under the Comprehensive Investigation/Corrective Action Study process. In response The Forrester Group developed and implemented a comprehensive site investigation and negotiated the subsequent corrective action plan.
This site is in an industrial zone within a large cleanup area being managed by the City of Wichita, Kansas. The City’s investigations indicated that our client’s facility could have been a possible source of TCE, PCE and vinyl chloride impacts to the groundwater.
We designed a limited excavation plan to remove soil with concentrations above the Kansas soil-leaching to groundwater standard and installed a groundwater monitoring network following the soil excavation. Soil excavation and site restoration was completed within one week without business interruption.
Concrete Cap Eliminated Excavation/Removal Costs at Toxaphene/VOC-Impacted Brownfield Site – Arkansas
The traditional approach to addressing pesticides (primarily toxaphene) and volatile organic compounds (VOCs) – impacted soil at this Arkansas site would have been excavation and soil removal. However, based on our knowledge of the contaminants, site use plans, and regulations, The Forrester Group found a solution that reduced the potential costs for this approach by 60 percent.
We designed and negotiated a cap remedy with the Arkansas Department of Environmental Quality (ADEQ) under a voluntary Consent Administrative Order. Based on the results of a characterization study, we designed the remedy, which eliminated health risks by pouring a concrete/asphalt cap over the 32,011 square foot impacted area.
We also worked with our client and the city of England to donate the capped site to the city where it is now the site of a public skate park and recreation area.
Penalties Prevented at EPA-Targeted Stockyard – Missouri
An EPA inspection found unauthorized discharges into a stream that originating from a southwest Missouri cattle livestock auction facility. In response, EPA issued a Finding of Violation and Order for Compliance for Clean Water Act Violations.
Following receipt of the order, the livestock facility owners hired The Forrester Group. Through a demonstration of responsiveness and good faith efforts, The Forrester Group worked collaboratively with both U.S. EPA Region 7 and MDNR, and the issues were addressed with no fines or penalties. The corrective action was also implemented without disruption to our client’s business operations
Responses to the regulatory issues included implementation of an Interim Measures Plan and Waste Management Plan. We developed engineering plans and specifications, which included excavation of two large basins and piping collection systems for storm water retention and installation of a center-pivot irrigation system for management of storm water. The engineering plans included a detailed cut/fill, site grading, and drainage analysis. We also designed the irrigation system to provide water for growing Bermuda grass, which is then fed to livestock on-site, thus reducing costs for off-site feed.
Tier III Cleanup Level Negotiation and Remediation Design Reduced Costs from $250K to $60K – Afton, Illinois
The Forrester Group managed the engineering and remediation of a lead-impacted site that is owned by a petroleum additives manufacturer in Afton, Illinois. When we assumed responsibility for this project, it was under scrutiny by the EPA and under consideration for an enforcement order. The Forrester Group negotiated with the regulators to move the project under the Illinois EPA Site Remediation Program (SRP), which avoided the enforcement order and gave our client greater flexibility in developing the remediation program.
We negotiated Tier 3 cleanup levels with the Illinois EPA lead toxicologist and the project manager and obtained their agreement to a remediation approach that reduced the client’s costs from the originally estimated $250K down to $60K. A simple and straightforward design plan was prepared and approved. The dig and haul remediation program was completed on time, without incident, and within budget in 2005.
Process and Environmental Fate Study Refuted Pesticide/Herbicide Release Claims – Nitro, West Virginia
Our client owned a West Virginia facility which had historically manufactured pesticides and herbicides. Local residents claimed damages due to presumed releases of manufacturing residues to the environment (air, soil, and water). The residents’ technical experts in the case generated estimates in support of the local residents’ claims.
The Forrester Group organized a team of internal and external experts that re-evaluated the technical basis for the presumed releases of manufacturing residues. By utilizing our combined understanding of chemical processes and environmental fate of pesticides and herbicides, we demonstrated in our expert testimony that releases of concern from the facility were much less than the residents’ technical experts had estimated and, in fact, were minimal.