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By wisely evaluating historical documents, current regulatory and project conditions and knowledge of future regulatory changes on the horizon, BSTI was able to swiftly bring about the best possible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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Solving Complex Environmental Problems #4: Using Cutting Edge Science to Avoid Ongoing Remediation

BSTI uses a science-based approach to close a site with LNAPL, save our client money and re-start a stalled real estate transaction.

The Problem

A release from a 30,000-gallon underground storage tank resulted in a body of diesel fuel above and below the water table (commonly referred to as light non-aqueous phase liquid or LNAPL).  This condition created a regulatory compliance problem, a financial burden on the property owner and severely complicated a planned real estate transaction.

Based on a thorough site characterization, BSTI determined that potential mobility of the LNAPL body would be the primary driver to achieving closure with the regulatory agency.  A traditional approach was first adopted that used a product recovery pump to actively remove available LNAPL from the subsurface.  During the recovery process, BSTI tracked recovery rates, in-well liquid levels, and assessed the efficacy of the system.  After several months, diminished returns of product recovery had been established and dissolved contaminants in groundwater remained below screening criteria at downgradient and perimeter monitoring wells. Despite establishing a technical argument for the cessation of LNAPL recovery, the regulator initially requested that additional recovery efforts be deployed based on an antiquated and unscientific “rule of thumb” cleanup criteria of reducing LNAPL thickness to less than 1-inch.  LNAPL thickness has been the prevailing regulatory criteria for the past five decades and remains the closure criteria on the majority of LNAPL cleanup projects.

The Solution

Rather than accede to the regulator’s request for additional LNAPL remedial measures, BSTI employed a science-based approach to clearly establish that the LNAPL remaining at the Site presented an insignificant exposure risk to human health and the environment. Using data collected from the site, as well as following recently developed technical guidance (1), BSTI developed a sound LNAPL conceptual site model (LCSM). The LCSM utilized multiple lines of evidence, including a LNAPL Transmissivity analysis, showing that recovery efforts had indeed reached the point of diminished returns and additional remedial efforts were unlikely to appreciably diminish the remaining LNAPL body at the site. Moreover, an exposure pathway analysis revealed no direct link between the LNAPL and potential receptors. Through the development of a LCSM for the site, BSTI demonstrated an acceptable level of risk for the LNAPL remaining at the site which would avoid a potentially costly and enduring process of continuing to apply additional remedial measures.

BSTI’s request for closure was approved by the regulator and liability relief was granted to the client.

Benefits to the Customer

By avoiding the additional active remediation at the site, BSTI saved its client from venturing into a costly cleanup with an unclear endpoint. Due to the scientific demonstration of a non-mobile LNAPL body at the site and the low levels of dissolved COCs in groundwater, the site was able to be closed by attaining generic cleanup standards. As a result, the client was relieved of adherence to a long-term care and monitoring plan, a deed restriction, or an environmental covenant.  The planned sale of the property took place without lingering environmental concerns.

Illustration of the conceptual release model showing the directional plume of the petroleum release and the location of the primary monitoring well.

For more information, contact Tripp Fischer at tfischer@bstiweb.com .

  • (1) The Pennsylvania Department of Environmental Protection’s Revised Land Recycling Program Technical Guidance Manual (TGM) was finalized on January 19, 2019. The TGM provides guidance for implementing the Chapter 250 regulations promulgated pursuant to the Land Recycling and Environmental Remediation Standards Act (Act 2 of 1995). The current TGM includes valuable guidance on defining the removal of LNAPL to the Maximum Extent Practicable (MEP). The LNAPL guidance in the TGM is based in large part on the Interstate Technology & Regulatory Council’s (ITRC) LNAPL Team publications and trainings (https://www.itrcweb.org/Team/Public?TeamID=18) ASTM’s LNAPL Transmissivity Guidance (E2856), and ASTM LCSM Guide (E2531).  BSTI’s Vice President and Principal Hydrogeologist Tripp Fischer, P.G. served as co-chair on this ITRC committee, is a trainer for the ASTM LNAPL Transmissivity Standard, and continues to provide training to regulatory bodies on the topic.
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BSTI gets physically challenged people up and moving on adaptive exercise equipment

BSTI’s major charity contribution this year was to the IM Able Foundation. The mission of the IM ABLE Foundation is to remove obstacles that prevent people affected by disabilities from being physically active. Recently IM Able organized a competitive duathlon race in Wyomissing PA as one of their annual fund raising events. A duathlon combines running and bicycling. The event also had a category for physically challenged athletes to compete on adaptive equipment, many of which was donated to them by the IM Able Foundation. Before the race started, Chris Kaag, founder of IM Able and an adaptive athlete himself, presented recumbent tricycles to two grant recipients. BSTI’s contribution went directly toward the purchase of this adaptive equipment. Here are some photos of the presentation and the adaptive athletes in action:

Chris Kaag, Founder of IM Able, presents adaptive equipment to grant recipients
The adaptive athletes started the race first
One of the grant recipients out on the course
Another grant recipient
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BSTI receives a Net Promoter Score of 97 from recent Customer Perception Survey

The Net Promoter Score, or NPS®, is based on the fundamental perspective that every company’s customers or employees can be divided into three categories: Promoters, Passives, and Detractors.

By asking one simple question – How likely are you to recommend BSTI to others as a good company to work with?–these groups are segmented to get a clear measure of a company’s performance through their customers’ eyes. Customers respond on a 0-to-10 point rating scale (10=extremely likely; 0=not at all likely) and are categorized as follows:

  • Promoters (score 9-10) are loyal enthusiasts.
  • Passives (Neutral) (score 7-8) are satisfied, but unenthusiastic.
  • Detractors (score 0-6) are unhappy customers.

The NPS can be as low as −100 (everybody is a Detractor) or as high as 100 (everybody is a Promoter). An NPS that is positive (e.g. higher than zero) is felt to be good, and a NPS of 50 is considered excellent.

“I am extremely proud to report that our NPS score is 97, breaking the previous high score of our marketing research consultant’s hundreds of customers which was previously 72.

As we celebrate our 20th year in business, you can be assured that we will not be resting on our laurels and we will use this valuable survey data to strategically plan for the future.”

Debbie Kollmeier, President

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A 7-step executive summary of EPA recommendations to reduce lead in drinking water in schools

The EPA is responsible for ensuring the safety of the nation’s drinking water in public water supplies. The EPA estimates that approximately 8,000 schools and child care facilities maintain their own water supply and are regulated under the Safe Drinking Water Act (SDWA).

There are approximately 98,000 public schools and 500,000 child-care facilities not regulated under the SDWA. These unregulated schools and child care facilities may or may not be conducting voluntary drinking water quality testing.

Exposure to lead is a significant health concern. The growing bodies of children and infants absorb more lead than the average adult. Drinking water is one possible, but not the only, source of lead exposure.

EPA’s 3Ts – Training, Testing, and Taking Action – provides tools for schools, child care facilities, states, and water systems to implement voluntary lead in drinking water testing programs.

Step 1 – Develop a communication plan

At the heart of an effective communication plan is preparation and coordination to deliver information swiftly, professionally, and consistently. Telling parents and staff about your 3Ts Program will demonstrate your commitment to protecting children and staff health. Communicating early and often about your testing plans, results, and next steps will build confidence in your ability to provide a safe environment.

Step 2 – Learn about lead in drinking water

Lead is a toxic metal that is harmful to human health. There is no safe blood lead level for children. In the human body, toxic lead can substitute for healthy calcium, which is a mineral that strengthens the bones. Lead is carried in the bloodstream and can harm the nervous system and brain. What is not excreted is absorbed into the bones, where it can collect for a lifetime.

Young children are especially susceptible to lead exposure, because of their frequent hand-to-mouth activity, and their metabolism—their bodies absorb metals at a higher rate than the average adult does. Children’s nervous systems are still undergoing development and thus are more vulnerable to the effects of toxic agents.

The only way to determine a child’s lead level is to have the child’s blood tested. Contact a health provider to learn more about blood lead testing.

Step 3 – Plan your 3Ts Program

Before sampling, facilities should establish a plan on how they will respond to their sample results to protect the school or child care facility population from lead in drinking water. You should consider potential partners, funding options, and how frequent testing will occur.

Step 4 – Develop a sampling plan

It is important that water samples be collected properly. Certified laboratories chosen to analyze samples may provide specialists to assist with sample collection. If the laboratory is not supplying someone to sample, be sure to identify an individual who is adequately trained to collect lead samples to help avoid sampling errors. It is useful to ask for references to confirm that individuals are qualified to test for lead in schools and child care facilities. Some state drinking water programs or public water systems may provide both services, although there is no federal requirement that they do so.

Step 5 – Conduct the sampling and interpret the results

The EPA recommends that schools and child care facilities conduct a 2-step sampling procedure to identify if there is lead in the outlet (e.g., faucet, fixture, or water fountain) or behind the wall (e.g., in the interior plumbing). These samples should be taken after an 8 to 18-hour stagnation period.

Take first draw samples from fixtures throughout the building that are used for human consumption. EPA strongly recommends that you collect these samples from all outlets used for drinking or cooking, prioritizing the high-risk outlets (i.e., fixtures that are known to or potentially contain lead and fixtures that are used most frequently). The plumbing profile will help pinpoint those high-risk fixtures and to prioritize sample collection.

Step 6 – Establish routine remediation practices

Engage the local health department, public water system, and other available resources to ensure the organization performing remediation is qualified and reputable. Ask vendors for information on the schedule, health precautions that must be taken during and following remediation, and request regular status updates on their progress prior to agreeing to work with any particular organization. The internal team should identify an individual that is responsible for working with the remediation contractors. This person should regularly communicate the schedule, activities, and hazards to the 3Ts Program team.

Step 7 – Perform good recordkeeping

Finally, it is important to keep an ongoing record of partners, team contacts, testing efforts, remediation efforts, public outreach, and communication activities. Keep copies of past communication materials and dates they were sent out. It is imperative to be able to prove steps were taken to inform the public on any lead issues. Strong recordkeeping can also prove to be helpful in illustrating what steps you have taken to notify the public of testing efforts and results.

Brownfield Science & Technology, Inc. (BSTI) provides qualified and experienced Environmental Inspectors, Professional Geologists, Geotechnical experts, Biologists, Environmental Scientists, Technicians and Engineers in support of environmental challenges to organizations in the Mid-Atlantic region.

BSTI’s website is www.bstiweb.com

Source: EPA’s 3Ts for Reducing Lead in Drinking Water Toolkit

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The Impact of Extreme Weather on Hazardous Material Releases

Extreme weather has an out-sized impact on petrochemical industries, in part because many are located along coastal and inland waterways. One aspect of this impact is an increased frequency of spills due to natural hazards in recent decades. 

In the analysis of federally reported releases presented, natural hazards are the underlying cause of between 1 and 7 percent of spills each year. Releases caused by natural hazards have increased sharply, in large part due to increased damage from hurricanes as well as floods and wind. Inter annual variability and trends over time for these spills generally match reported variation in extreme weather and associated climate indexes. For example, releases caused by floods in the last five years were approximately 50 percent greater than in the early 1990s and this increase is correlated with similar increases in extreme precipitation both nationally and for select US regions.

Although many releases caused by natural hazards are minor, some are large and expensive. Centralized records on the impacts of these events is imperfect, but federal records identify at least 180 evacuation events, 84 injuries and two deaths along with release of 11 million gallons of petroleum, 1.5 million gallons and 16 million pounds of chemicals and $32 million in damages. These values vastly underestimate actual impacts but serve to document that impacts have increased over time.

Predicted increases in the incidence of extreme weather in the future suggest that these types of releases will continue to multiply resulting in an increased potential for serious human and environmental impacts. Greater attention to management of natural hazard risk to industry, and in particularly to bulk storage facilities, is required to manage the frequency and severity of these events and this work can inform that effort. 

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Ten Insider Tips to Reduce Your Environmental Remediation System Operations and Maintenance Costs

So, you’ve just spent a lot of time and money designing and installing that in-situ environmental remediation system at your facility.  You were assured that the system will remove contaminants from the soil, soil gas and/or groundwater but it will take a few years or more to achieve regulatory endpoints.  At least the big headaches and costs have passed. Or have they?

It’s tempting to exhale a bit once your remediation system is up and running.  The construction crews have cleaned up, regulators have turned their attention elsewhere and your facility operations can get back to normal. Your operations and maintenance (O&M) budget has become a part of your annual planning.  But just because things have quieted down, it doesn’t mean you should stop paying attention to the costs.  Are you getting the most bang for your buck, especially over the long term?

The tips offered below are based on over 30 years of designing, building and operating environmental remediation systems. While no two situations are the same, there are certainly commonalities that contribute to the success and efficiency of an O&M program.  It is our hope that you will benefit from our experience and be able to deploy your O&M dollars as effectively as possible.

  • Understand your regulatory end-points before you commit to your remedy. You’ve spent a lot of time and money in the assessment stage trying to quantify the extent and magnitude of your subsurface contamination. You now want to know how much this will cost to clean up. Before you think remediation costs however, it would be advisable to engage an environmental consultant who can also assess the human and ecological risks associated with doing less or no remediation.  In many cases and in many jurisdictions, you may have options to scale back your remedial response based on the risk to humans and the environment.  Why design and operate a remediation system to attain generic cleanup standards when you don’t need to?

Even if you already have an active remediation system, its not too late to evaluate risk-based end-points. You may be closer to the end than you think.

  • Think O&M costs in the system design phase. Most remediation systems are designed for the full extent of contamination on day one. System designers don’t like to fall short on the equipment specifications, so many designs also include an additional performance buffer. That seems right for the first few months of your O&M program when the contaminant mass is at its most enriched and readily accessible state.  However, contaminant mass removal rates tend to drop off significantly over the early phases of the remediation program and then level off into a steady long-term phase. From fairly early on, the system is essentially over-designed.  Each month, more O&M dollars are spent for less mass removed.

During the design phase of your remediation project, ask for projections of anticipated O&M costs for both the “initial-mass” removal phase as well as an “average mass” removal phase.  Also ask for expenditures along the life-cycle of your projected project.  The long-term O&M costs are typically significant enough to factor into your initial design decisions.

Another way to save O&M dollars at the design stage is to make system-checks more efficient.  For example, an operator that has to visit and open each recovery vault or wellhead just to collect the days data will remain on the clock much longer than one who has all the valves and monitoring ports in a centralized location. Not only can significant cost savings be realized by reducing the operator’s time on-site, the operator will be in a much better position to collect performance data accurately and make the best optimization adjustments.

  • Do you need a hammer or a Q-tip, or both? As noted above, most remediation systems are designed with “day one” in mind.  The big “hammer” approach may have been necessary during the early stages, but to a lesser and lesser extent over time.  O&M dollars are increasingly spent on system upkeep and utility costs rather than toward moving the remediation project forward.  For various reasons, there seems to be a tendency to stick with an as-designed remedial approach long after its cost-effective life has past.

Be sure to have your consultant evaluate the cost-benefits of modifying the remedial approach in the later stages of the remedial program.  This “adaptive site management” approach can often identify a reduced-effort tactic (Q-Tip) that can make a real difference in your annual costs.

  • Are you paying for a system operator or a meter reader? All in-situ remediation systems require some degree of human operations and maintenance. The key is to hire O&M services that have the knowledge to maximize remedial progress.  An experienced system operator will measure and manage key performance metrics in each particular system to maximize the effectiveness of the remedial program during each and every site visit.

A great operator has the experience to anticipate system “upsets” which reduce unplanned downtime and costly repairs.  They also understand the difference between “preventative” maintenance and “reactive” maintenance.  We have seen that the right operator can single-handedly expedite the overall remedial timeframe and significantly reduce O&M expenditures.

If you are getting a lot of surprise invoices associated with unforeseen repairs or your system always seems to be “down” due to malfunctions, it may be that your system operator is really just a meter reader.

  • The long-term costs of the low-cost providers. Over a long haul, owners understandably seek to reduce their annual O&M costs through a competitive bid process. O&M responsibilities can change hands many times over the years; each time a successive operator picks up where the last one left off.  Tolerance for underperforming equipment and band-aide maintenance becomes the norm. While the unit rate of the latest operator is incrementally lower than their predecessor, the progress made on the overall remedial program continues to diminish.  Further, there is an inherent lack of motivation to be efficient and get the remediation project done. The low-cost provider simply doesn’t want the work to end.

We understand the rationale behind lowering costs. Such savings can be used elsewhere in your organization for greater benefit.  For that, we offer the next Tip.

  • Understand where your O&M dollars are going? It is important to recognize if your O&M costs are associated with equipment and consumables or if they are the result of personnel, or both. Are you spending a lot of money on electricity keeping your pumps and treatment devices running while little to no contaminant mass is in the process stream?  Are you spending a lot of personnel time collecting a mountain of data that never changes?  Are your processes constantly failing from organic or inorganic fouling that causes system downtime and increased maintenance events?  There are solutions to all of these common situations.

By first understanding the root cause of your O&M expenditures, you will be in a better position to potentially make a big difference in your annual budget.

  • Renewable verses consumable treatment devices – what’s the difference. Treatment devices can be classified in many ways. For this tip, we are going to talk about renewable verses consumable treatment devices.  A renewable technology is a device that does not diminish treatment capacity over time regardless of the amount of contaminant mass it has treated (catalytic/thermal oxidizers, skimmer pumps, soil vapor extraction systems, etc.).  A consumable technology is one that diminishes capacity as treatment occurs (granular activated carbon (GAC), sorbents, bag filters, etc.).

The application of renewable and consumable technologies is often dependent upon the amount of contaminant mass and the rate at which it is being treated.  Generally speaking, the more abundant and robust the contaminant mass, the more cost efficient it is to use renewable technologies.  Conversely, low mass situations can be better suited for consumable remedies. For example, a thermal or catalytic oxidizer is frequently a good choice for a soil vapor extraction system at the early stages of a remediation program.  Abundant mass is removed requiring off-gas treatment prior to being discharged to the atmosphere.  Using GAC at this early stage would be cost prohibitive as the abundant mass would quickly render the carbon “spent”; requiring frequent and costly change-outs. As the mass reduces over time, more O&M dollars are spent on the oxidizer (capital/lease costs, utility costs) than would be spent substituting for GAC.  This same concept of “dollars spent per mass removed” can apply to other technologies.

The key is to know when it is cost efficient to switch from a renewable to consumable process.  A good system operator can track mass removal rates verses treatment cost and recommend the proper time to switch treatment devices.  It is important to have your consultant pay attention to such details.

  • Consider telemetry and remote monitoring. Modern communication technology is cheap.  Sending a human to randomly check on a system is not.

Design or add telemetry systems into your remediation system that can be accessed via remote computer, can “call out” when performance metrics fall out of range and provide some data on system faults.  With even the simplest telemetry systems, the frequency of O&M visits can be dramatically reduced. Further, technicians can be more informed of system upsets and mobilize prepared to conduct the necessary maintenance.

Which brings us to “down-time”.  When a system is “found down” during a routine site visit, the technician is often unprepared or doesn’t have time left in the day to conduct the necessary repairs. Thus, another visit on a later date is scheduled.  Added cost and down time!  Also, without telemetry, we often don’t know if the system went down a day ago or a week ago.  Down time can easily add up to months or even years of prolonged operation and expenditures.

Note that we recommended simple telemetry systems.  Which leads us to the next tip.

  • Bells and whistles? Being able to open and close valves from a hundred miles away is a necessary function for some industries (pipelines, chemical plants, etc.). Being able to access real-time data to your office computer can also have benefits.  There are times when spending more to have such functionality is essential (e.g., critical safeguard, real-time discharge compliance, etc.).  We don’t consider such critical and essential design features to fall into the bells and whistles category.

Often, we’ve seen design features that only marginally add to the overall necessity of the system but add significant cost. Some can actually hamper the O&M process by becoming a maintenance item on their own.  Regardless if you are in the design stage or late in the overall remediation program, we recommend that you evaluate if the extra bells and whistles are truly necessary to attain your remediation goals.

  • Conduct an Annual Optimization Review. Very few in-situ systems operate exactly as designed.  Initial system designs are based on inherently limited data and an educated prediction of performance. The most accurate performance data becomes available only after the system has been activated.  Also, operational parameters and site conditions can change over time.  For example, groundwater elevations rise and fall, impermeable surfaces can be removed or upstream stormwater paths can be redirected.  These and many other factors can affect how the remediation system performs.

It is important to consider your remediation program as an iterative process, so routinely evaluate the status of your remediation program.  Instead of spending the same O&M dollars year after year to keep the same system “running”, recognize that circumstances have likely changed.

We recommend that you conduct annual “optimization reviews” with your system operator.  Many of the tips listed above can be evaluated during this review.  Not only will you discover considerable savings, you will also be confident that are getting the most bang for your buck.

Brownfield Science & Technology, Inc. (BSTI) is an earth sciences company specializing in environmental assessment, remediation and consulting services for public and private clients. We use science, human talent and state-of-the-art tools to guide our clients through environmental challenges. If you would benefit from deep expertise, responsiveness and been-there-done-that capability, then we may be the right firm for you.

For more information, contact:

John Kollmeier                                     Tony Finding

Senior Vice President                           V.P., Director of Remediation Technologies

jkollmeier@bstiweb.com                      tfinding@bstiweb.com

(610) 593-5500                                    (610) 593-5500

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12 Best Practices To Avoid Pipeline Construction Environmental Shut-Downs and Fines

Since 2005, innovative technologies such as hydraulic fracturing (i.e., fracking) and directional drilling (trenchless technologies) have made it possible to access valuable hydrocarbon resources from Pennsylvania’s Marcellus and Utica shale deposits. Domestic natural gas production has increased to the point that Pennsylvania produces 19% of the total output; which ranks #2 behind only Texas (24%).

The increase in natural gas production has triggered a demand for additional pipelines across Pennsylvania and the surrounding region to deliver product to market safely and efficiently. To construct a new pipeline, energy companies must navigate complex environmental regulations, permits, and technical obstacles. Any misstep along the way can result in costly operational shut-downs, public relations challenges, sizable fines and lengthy project delays.

Every pipeline installation location faces unique challenges. The purpose of this paper is to identify some of the more common causes of environmental, regulatory and permit violations that can result in work delays, fines and public relations challenges. The information below is presented in no particular order of importance. It is our hope that this paper can serve as a valuable guide to energy companies and pipeline operators as they plan and implement their pipeline construction projects.

Establish clear lines of communication

Insufficient responses, reporting delays, inattention to permit details and work crew variabilities have all been factors in pipeline construction shut-downs and fines. Communication challenges become more complex when the project involves multiple contracting parties.

Governing authorities will not accept a lack of communication at the project level as a valid reason for not complying with permit conditions. Repeated failure to promptly comply with permits can risk a forced work stoppage, imposed fines, and/or additional legal penalties.

A robust Communications Plan should be generated and implemented at all levels of the project. A clearly-outlined project personnel structure and chain of communication is vital to the Communications Plan. Timeframes and processes to report instances of non-compliance are also an important part of the plan. Managers and on-scene inspectors must be fluent in permit reporting requirements. They should also have the authority to obtain the information they need in a timely fashion. Enabling a process for field crews to identify and report potential issues to inspectors and managers can save valuable time and kick-start mitigation efforts. A self-regulating project can keep regulators from becoming overly involved with day-to-day oversight.

Proper soil segregation and restoration of open-cut wetlands

When open-cut trenching methods are used to cross wetland areas, soil segregation is important to maintain the integrity of the resource during restoration efforts. Specifically, wetlands underlain by an impermeable “fragipan” soil horizon are at risk of drainage if not properly restored.

Wetlands with endangered and/or threatened species, such as bog turtle habitat, will likely require additional measures to avoid long-term impacts and may not even be approved for open-cut crossing methods.

It is recommended that during initial trench excavation, a wetlands specialist or similarly-qualified expert is present to verify that soil horizons are carefully removed, segregated, and staged during construction. Following pipeline installation, complete and appropriate restoration of the wetland should be documented and approved by the expert.

Prepare for water infiltration within conventional bore excavations

Conventional bore crossings typically require the excavation of pits to attain a direct bore path beneath the feature to be crossed. Storm water runoff and/or groundwater infiltration into the pits may necessitate significant water management measures including temporary settling and containment structures. Often, additional space is needed to construct water management structures. Special attention to permit conditions is important to avoid management and discharge violations. Also, the time required to purchase/rent additional land for work space or to modify a permit can result in delays on the order of weeks.

It is recommended that a pre-construction evaluation of bore crossings take place to improve the understanding of the subsurface. This information can be used to design construction plans for crossings that add in contingencies for expanded dewatering and storm water handling requirements.

Maintain erosion control devices (ECDs) to prevent runoff into wetlands, streams and other waterways

Continual inspection and upkeep of ECDs is necessary to prevent runoff from the construction site into water bodies and other resources. Over time and multiple storm events, ECDs become less effective and need to be repaired or replaced to avoid unpermitted discharges to waterways and/or complaints from the public.

It is recommended that personnel be assigned to directly inspect ECDs on a regular basis as well as just prior to and after any storm events. Sufficient resources should be allocated to repair ECDs expeditiously.

Maintain construction operations during permitted work hours

Most municipalities and townships have ordinances specifying the permissible hours of operations for construction activities. Installation contractors are under pressure to make progress and may opt to work beyond the permitted timeframes. Especially in areas of increased public scrutiny, such actions may trigger noise and/or nuisance complaints from nearby residences. Habitual violations of such ordinances can risk temporary shutdown or revocation of local permits.

It is recommended that site supervisors be fully informed of and comply with all local rules and work timeframes. Daily work logs should always verify the actual hours of operation.

Systematize process for changes to construction methods/techniques

Often a construction method/technique change can make good tactical sense given in-field conditions or circumstances. However, such changes often require modifications to existing permits which will necessitate regulatory review and approval.

Failure to follow permitted construction methods or techniques can result in the suspension of all permitted activities, extended delays, and fines for failure to comply.

It is recommended that a thorough and detailed Communications Plan be adopted, and all personnel be trained on its content to prevent these issues from impacting the project.

Be careful in the selection of drilling fluid additives

Additives to drilling fluid can help overcome challenges during pipeline installation. Depending on the circumstance, it may be advantageous to adjust the pH, add bactericides, corrosion inhibitors, or other agents to the drilling fluids. The Pennsylvania Department of Environmental Protection maintains a specific list of approved drilling fluid additives.

In most cases, on-scene modification to a drilling fluid may make tactical sense but it does require approval. Further, use of an unapproved additive may be a permit violation and could result in fines.

It is recommended that all construction personnel be trained on the use of approved additives and that any reformulation of drilling fluids on the job site require supervisory level approval. Routine audits of drilling materials are also suggested.

Minimize inadvertent returns of drilling fluids into uncontrolled areas

Trenchless technologies, such as Horizontal Directional Drilling (HDD), utilize circulated drilling “mud” to advance a bore path through the subsurface often to cross underneath a major roadway or a sensitive environmental resource. Sometimes, the pressurized drilling mud will travel through natural subsurface pathways such as rock fractures and reach the ground surface. This is known as a “frack out” or inadvertent return (IR). IRs that enter waterways, wetlands, or ponds may be viewed as unpermitted discharges and subject to fines. In addition, IRs may cause property damage to nearby structures or roadways.

An IR can be quite visible to the surrounding community and often creates a public relations challenge. Exacerbating the problem, once an IR occurs, it will have a higher chance of reoccurring once drilling resumes due to the establishment of that preferential pathway.

It is recommended that a thorough geotechnical investigation be conducted in all areas that will likely involve HDD methods prior to actual drilling. Although nothing can detect all possible subsurface structure and fractures, the geotechnical investigation can predict areas where IRs would be more likely to occur. Reducing the length of an HDD bore to a minimum greatly reduces the risk of an unwanted IR. In high-risk areas or threatened or endangered species habitat, it may be advantageous to evaluate installation methods other than HDD.

Minimize the effects on potable water resources caused by trenchless technologies

As presented above, HDD drilling mud has the potential to migrate through the subsurface and can enter nearby domestic water supply wells. Although drilling mud is non-toxic, affects can range from increased drinking water turbidity to complete infiltration with drilling fluids.

Also, a horizontal bore may intercept a local aquifer which could cause drainage back through the borehole and lower the groundwater level. If groundwater levels drop below supply well pump depths, the local water supply may be lost. Affected users must be supplied immediately with alternative water sources and a long-term solution for their water needs will need to be addressed; possibly involving the installation of a new water well or connection to a publicly-owned water supply.

As noted above, it is recommended that a thorough geotechnical investigation be conducted during pre-construction in all areas of planned HDD activity. In addition, all potable water wells in the area should be identified and monitored before, during and after construction activities.

Promptly report unpermitted incidents/conditions

Accidental situations occur during pipeline construction that sometimes result in unpermitted conditions. Self-reporting a mistake or incident is inherently difficult, especially when on-scene workers are facing daily productivity pressures. Most permits have specified time frames to voluntarily report occurrences of non-compliance. However, failure to report such occurrences within the time frames can incur additional penalties to the project, including the stoppage of work.

It is recommended that thorough training of on-site personnel be conducted so that all personnel recognize when an unpermitted situation occurs, thereby minimizing the reliance on individual discretion. It is also recommended that a clear and timely process for reporting occurrences is adopted.

Maintain clean and orderly project access points

Pipeline installation requires that work be conducted in remote areas. Access to the construction sites is often over temporary gravel roads originating from a nearby public road. Construction permits require that project access entries along public roadways remain clear of mud and debris that can be tracked along with construction vehicles.

Such access points may be the only point of interaction with the local community. Failure to maintain good housekeeping and public sensitivity in these areas can result in public nuisance complaints. Continued problems of this kind could risk the revocation of local construction permits.

It is recommended that sufficient cleanup personnel are dedicated to maintaining public roadways.

Adopt a realistic and usable PPC Plan

In addition to IRs, unpermitted discharges to public waterways can occur due to fuel spills, hydraulic line failures, etc. In most cases, a Preparedness, Prevention and Contingency (PPC) Plan will be required for pipeline construction sites. The PPC Plan will include best practices to avoid such spills, methods to document the cleanup measures taken, and how to prevent further violations of permitted conditions.

Having mitigation supplies on hand at the time of a release is an important, and sometimes overlooked factor in response efforts. Lack of adequate procedures and/or cleanup equipment can allow spills to migrate to nearby waterways, resulting in permit violations, fines and work delays.

It is recommended that a PPC Plan be developed using practical and applicable techniques. Also, all countermeasure equipment should be readily available so that any job-site spills can be contained and cleaned up with minimal migration away from the loss area. The on-hand presence of cleanup and countermeasure supplies should be verified before construction activities begin.

he above summary represents our viewpoint and what we’ve witnessed to be the common environmental-related reasons causing construction delays, job-site shutdowns, public relations challenges and fines. This paper is not meant to be a comprehensive list of all possible issues that could be encountered during linear construction of pipelines.

Brownfield Science & Technology, Inc. (BSTI) provides qualified and experienced Environmental Inspectors, Professional Geologists, Geotechnical experts, Biologists, Environmental Scientists, Technicians and Engineers in support of the pipeline installation industry and operators.

BSTI’s website is www.bstiweb.com

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