Solving Complex Environmental Problems #14 BSTI’s Ingenuity Saves Client Substantial Costs after a PFAS Release

A client experienced an accidental release of fire suppression foam containing C6 PFAS compounds in one of their facilities and was paying exorbitant fees to emergency response clean-up crews. Aqueous film forming foam (AFFF) was released into floor drains that normally led to the sanitary sewer. In this emergency event, diversion valves were actuated to protect the sewer system and divert the impacted water to an exterior emergency retention basin. Unfortunately, the event happened on a windy day, and as a result the foam was subsequently spread to surrounding areas, including other storm drains that ultimately emptied to a nearby stream. Emergency response included manpower and multiple vacuum trucks to remove the foam from the sewers and stream nearly a ½ mile away. Recovered water was transferred back to the facility and staged in numerous temporary 20,000-gallon storage tanks. After a few weeks, the response footprint was reduced to just the localized sewer system.  However, the client was obligated to continue with recovery efforts on a 24 / 7 basis at costs in excess of $18,000 per day until a permanent solution to the problem was in place.

BSTI was enlisted into this project by one of our partner companies to see if we could design and implement an automated solution to the costly manual water collection program.  Within less than 24-hours of visiting the site, we responded with a solution for an automated recovery system designed to remove the expensive vacuum trucks offsite as soon as possible. Because of our remediation experience and can-do attitude, we were able to procure, fabricate and deploy recovery pumps and control systems within days.  Measures were also implemented to reduce/prevent storm water from being introduced into the affected sewer network which lessened the volume of impacted water being containerized. Within less than one week of system deployment, the client was able to remove the manual crews and vacuum trucks from the site. The immediate benefit to the customer is that they now have a reliable automated recovery system in place for the same cost of just two days of vacuum trucks.

BSTI was subsequently asked to design and operate a treatment system for the containerized PFAS-containing water.  That, however, will be the subject of another installment of Solving Complex Environmental Problems.

If you have questions about this subject and wish to contact us, contact Tony Finding at tfinding@bstiweb.com.

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Solving Complex Environmental Problems Post #12, Keeping Well-Informed with Dynamic Regulatory Changes Helps Client and Project Succeed

The Problem

A multi-unit residential building in an urban setting was in the process of being purchased in a real estate transaction. A review of historic environmental reports and documents identified a former underground heating oil storage tank (UST) that existed under the basement concrete slab. The UST was closed-in-place, but historic investigation and soil sample analyses verified the presence of heating oil-related impacts at levels above regulatory limits for residential properties in soils at the site. 

Due to the concentrations of heating-oil compounds detected in soils, the site would have had to ultimately enter the state’s regulatory cleanup process. To navigate this process, BSTI developed a comprehensive field investigation for defining the extent and degree of apparent impacts to soils. What further complicated matters was the excessive depth (> 17 feet) of impacted soils in a basement with limited access and overhead space. Structural evaluation, confined space work and probable shoring of the future excavation and sampling area would be necessary and expensive.

The Pivot

Prior to implementing the remedial investigation and regulatory notifications, BSTI scientists proficient in the state’s regulatory process thought to investigate if any rule changes were possibly forthcoming.  We were pleasantly surprised when we identified a very recent update to the state’s voluntary cleanup program that applied to our project. Specifically, a public bulletin from two weeks prior contained a proposed increase in the residential medium specific concentrations (MSCs) for the two (2) heating-oil compounds that were problematic at our site.  After verifying the proposed changes and the rule making process with the regulatory agency, BSTI generated a professional opinion that summarized these significant changes and provided expert guidance to the stake holders.  The result was that no further action would be necessary should the promulgation of the new MSCs go into effect.  BSTI also provided rationale based on the where the proposed MSCs were in the rule making process that added comfort that the new MSCs would likely be adopted.

The Benefit

By wisely evaluating historical documents, current regulatory and project conditions and knowledge of future regulatory changes on the horizon, BSTI was able to swiftly bring about the best possible outcome for the client, project stakeholders and real estate transaction without additional characterization, remediation and environmental closure activities. Overall, BSTI saved the client over 90% of projected total costs by finding a desirable “off-ramp” for the stakeholders on both sides of the transaction. In addition, the total expected time to bring closure to the site was reduced by possibly as much as 6 to 12 months. While discovery of historical environmental liabilities is alarming, BSTI’s practical approach to the project, familiarity with the state’s regulatory framework and promulgation of proposed regulations and pro-active strategic planning, the historical impacts were favorably resolved for our client with no lingering post-closure responsibilities. BSTI’s Project Manager for this project is Ethan Prout, P.G.  Ethan can be contacted at eprout@bstiweb.com.  Visit www.bstiweb.com for more information on our capabilities.

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Solving Complex Environmental Problems Post #7 Astute pivot in remedial strategy saves client significant time and money

The Problem

An office building owner switched their fuel source from heating oil to propane resulting in the removal of their 1,000-gallon heating oil underground storage tank (UST). As excavation of the UST proceeded, signs that the tank had been leaking became evident. The unearthed steel tank showed holes and pitting from corrosion. Stained soils, oily residue and strong odors were discovered. In addition, standing water with a heavy oily sheen was observed within the excavation trench, prompting a regulatory reporting event. Sample analysis verified the presence of heating oil-related impacts at levels above regulatory limits for commercial properties in both soils and water.

Due to the levels of target compounds detected in soils and water, the site entered the state’s regulatory cleanup process. To navigate this process, BSTI developed a comprehensive field investigation for defining the extent and degree of apparent impacts to soils and groundwater. During the assessment however, BSTI geologists determined that the water observed within the tank excavation was not, in fact, groundwater. Rather it became clear during well drilling that the water in the excavation was a localized feature, and the actual shallow water table resided much deeper.

Soil was removed to a point below the contamination level

The Pivot

Based on the information obtained in the field, BSTI realized that we could shift cleanup strategies to take advantage of a streamlined regulatory process when dealing with only soil impacts related to tank releases. BSTI could expedite closure for the site if it could be shown that soils had been remediated, groundwater was not adversely affected, impacts did not migrate offsite, and the cleanup process was completed within three months of the release discovery. To pursue this cleanup option, BSTI fast-tracked a soil excavation and disposal scope and completed the regulatory documentation within days of the three-month deadline. Ultimately, cleanup targets were achieved, and the site received full liability protection for the release without any restrictions to future intended site use.

The Benefit

By astutely connecting field observations and knowledge of the regulations, BSTI was able to rapidly shift the remedial strategy to bring about the best possible outcome for the client. Overall, BSTI saved the client over 50% of projected total costs by taking advantage of the streamlined cleanup process. In addition, the total expected time to bring closure to the site was reduced by as much as two years. While discovery of a leaking tank is alarming, due to BSTI’s sound technical approach, familiarity with the regulatory framework, and pro-active strategic planning, the release was quickly and favorably resolved for our client with no lingering post-closure responsibilities.

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Solving Complex Environmental Problems #5 Anti-Fouling Agents to Reduce O&M Costs and Increase LNAPL Recovery

BSTI was the provider of in-situ remediation services for a large-scale subsurface release of diesel fuel at an electrical generating station. Water table depression pumps were installed in four large-diameter recovery wells to control the migration of diesel fuel and to create a cone of capture in the aquifer to promote LNAPL recovery. BSTI personnel had learned over many years of LNAPL recovery projects that a steady and consistent aquifer drawdown is critical to both effective aquifer control and LNAPL recovery. Like many remediation systems, this one experienced severe inorganic and organic fouling in the water pump intakes, piping, and meters causing an increasingly diminished ability to move water and maintain the desired aquifer drawdown.

The initial (and typical) response was to shut down the system and perform maintenance that included pump disassembly and cleaning, water pipe cleaning and replacement and flow meter cleaning. Such maintenance was needed every two weeks and quickly became ineffective and inefficient.


Above: White aluminum oxide deposits on water pump

Field personnel noticed an inconsistency in the fouling problem across the four recovery wells and was able to link it to the existence of a large coal pile at one end of the project area.  Fouling was primarily caused by aluminum oxide and iron related bacteria but to a varying degree based on the proximity to the coal pile.  Because water chemistry was a strength, BSTI personnel and a specialty vendor were able custom design an in-field application of anti-fouling agents on an individual recovery well basis. The anti-fouling agents had to be custom formulated to be effective and compliant with State-mandated restrictions on the use of phosphate-based chemicals that could be introduced into the waterways of the State.

Above: Downhole view of recovery well.  Fouling control tubing is middle left.

BSTI then designed a simple delivery system for the anti-fouling agents to maximize effectiveness and minimize chemical costs.  Field staff set up automatic metering pumps at each recovery well to deliver the anti-fouling agent through tubing directly to the water pump intakes; thereby maintaining the proper dosage without overdosing the well and unnecessarily increasing chemical costs.  The cost for anti-fouling system was $32.00 per day for each recovery well.

Such a little step contributed to big results.  The shutdowns and maintenance associated with fouling control decreased from twice monthly to twice annually. O & M costs were reduced from greater than $65K per year for manual cleaning to less than $30K per year for the anti-fouling system.  More significantly, the anti-fouling system allowed the overall water table depression system to remain operational for long period of time (98% uptime); providing a consistent aquifer drawdown, effective aquifer control and maximum LNAPL recovery.  Over a period of ten years of system operation, $350,000 were saved and 385,000 gallons of LNAPL were recovered.  The project has since met all regulatory requirements and the remediation system has been dismantled.

For more information, contact Tony Finding at tfinding@bstiweb.com.

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The Person Who Asks the Best Question Always Gets the Best Answer

We have in our pockets a device that has instant access to nearly every piece of information known to mankind. So why is it so hard for me to cut through the clutter and get a somewhat applicable answer to a basic question? Geez, I just wanted advice on “growing tomatoes” (29,800,000 search engine results).

 

Tomatoes search - Best Question Always Gets the Best Answer

So recently I found myself proclaiming that the information age should be renamed the “too much information” age when my friend Mark chimed in. He reminded me that “the person who asks the best question always gets the best answer.” His simple statement hit me like a tidal wave. My problem was me! When I find myself struggling to find a good enough answer, I most certainly have not asked a good enough question. “What light conditions are optimal for growing indeterminate tomatoes indoors in the winter?” (230,000 results and the first five are really good ones!)

 

This simple concept has fundamentally changed the way I think. Consultants tend to boast that they have the right answers, but a truly valuable consultant should also have the right questions. This reminds me of something that I used to do for clients called “Defining the Bullseye,” but I’ll save that for another day.

 

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