EnviroForensics Achieves No Further Action Designation for Scrap Metal Processing Site

EnviroForensics continues to clean up and close contaminated sites! Most recently, our client Secondary Metal Processing (Secondary Metals) in Wabash, Indiana, a scrap metal processing facility, was issued a No Further Action designation at the end of 2015.

It all began when the Indiana Department of Environmental Management (IDEM) performed a routine inspection at the Site in April 2010, and an area of accidental contamination was found. Secondary Metals entered into an Agreed Order with the IDEM to facilitate a timely regulatory closure, and sought out EnviroForensics to investigate and address the contamination. Our team of environmental experts conducted a subsurface investigation, which revealed that a release of chlorinated solvents had occurred at the site, in addition to more typical automotive oils and lubricants.

Following a complete investigation and assessment in cooperation with the IDEM, cleanup activities began in November 2013.  Fortunately, a straight-forward soil excavation enabled the contamination to be removed entirely in no more than two phases.  EnviroForensics submitted a Remediation Completion Report to the IDEM, which recommended that the job was complete. IDEM conducted a Follow-Up Inspection in September 2015, and on November 17, 2015 issued a letter stating Secondary Metals had achieved compliance with the terms of the Agreed Order, which resulted in no further action and case closure for the site.

Secondary Metals is one of 12 sites impacted with chlorinated solvents and/or other contaminants we have achieved regulatory closure for in the past five years. Currently, EnviroForensics is performing active remediation activities on behalf of numerous clients, and is performing post-remediation monitoring on many more throughout the Mid-West. Chlorinated solvent contamination can be complicated and challenging to address, but EnviroForensics’ team possesses the unique and specialized expertise, experience to achieve regulatory closure for these types of sites. We have the track record to prove it.

Soil Gas Point Installation Using Hydro Excavation

Often times, environmental consultants encounter manmade structures during environmental investigations which can serve as preferential pathways for the migration of vapor phase contaminants.  Sewer lines are common preferential pathways and are usually investigated during vapor intrusion assessments to determine whether offsite properties are at risk of exposure.  Sewers are present at various depths and constructed of different materials, including clay tile, reinforced concrete, and PVC, depending on the timeframe during which they were installed.  Great care must be taken when accessing the sewer lines to make sure that they, along with any other utilities in the area, are not damaged.  Hand augers are typically used to access utilities because the use of heavy drilling equipment results in a higher potential for damage.

Recently, EnviroForensics completed a preferential pathway investigation near an active dry cleaning facility to determine the extent to which the sewer line serving the property may be acting as a preferential pathway.  This Site presented a unique challenge since the sewers are buried 15 feet below ground under a hard clay material, making them difficult to access with a hand auger.  In order to overcome the challenge, EnviroForensics elected to make use of hydro excavating equipment during the installation of soil gas sampling implants.  Hydro excavation makes use of high-pressure water to break away soil and a vacuum is then used to remove the soil and water from the cavity.  Since the water pressure is not great enough to damage the sewer materials themselves, it is possible to safely expose the utilities for inspection and investigation.

Steel soil gas sampling implants were installed within the fill material surrounding the sewer, allowing EnviroForensics staff to collect samples of the subsurface vapor that may be migrating to offsite properties.  The use of hydro excavating equipment proved to be both efficient and effective, allowing for the installation of three soil gas points in a timely fashion while causing minimal disturbance to the surrounding properties, and ongoing business operations at the dry cleaners.

EnviroForensics is committed to utilizing the most effective techniques and technology to ensure each investigation is conducted as thoroughly as possible. Our team of experts are experienced in locating the source of contamination and creating remediation plans that accurately address and clean up any contamination on our clients’ properties. Additionally, we are equipped with a team of Vapor Intrusion (VI) experts who are known within the VI assessment community and are being sought out specifically to evaluate the VI exposure pathway.

At EnviroForensics, we know that dealing with contamination at your site of business can be overwhelming, burdensome and expensive. We work to eliminate these concerns by accurately addressing contamination while searching for alternative means of funding—such as historical insurance policies—that will significantly reduce your out-of-pockets costs. Our clients are our priority, and we are committed to turning your environmental liabilities into assets.

About the Authors

Matthew Bono

Project Manager

Mr. Bono has over 3 years of professional experience in environmental consulting. He has been involved in subsurface investigations and remediation activities at facilities and properties impacted with chlorinated solvents, petroleum products, and other hydrocarbons throughout the state of Indiana. Matt has assisted with data evaluation and reporting on all phases of projects from investigations through closure and has provided project management services including work scope development, budget management, and personnel management. He has provided oversight during remedial plan implementation, incorporating multiple technological approaches including pump and treat systems, soil vapor extraction (SVE), enhanced anaerobic bioremediation, thermal desorption, and soil excavation. Matt also has experience in contaminant transport and groundwater flow modeling. He has worked closely with clients and subcontractors, as well as state and federal regulators.

Garnes Wiliam 3 15 Enviro PS

William Garnes
Field Geologist

Closure Timeframes: Remediation Strategies Determine Long-term Stewardship Requirements

EnviroForensics recently attended a technical presentation regarding chlorinated solvent groundwater remediation techniques at a former manufacturing facility using reductive dechlorination. A case study was presented wherein a groundwater remedy was implemented for a comingled TCE and 1,1,1-TCA plume. The groundwater remedy included application of emulsified vegetable oil and microbes to the subsurface, circulation of groundwater, and monitoring over a 2 year period. The treatment successfully reduced groundwater contamination, but did not address the source of contamination within the soils.

The source of soil contamination was left in-place and “capped” by the former building slab, which was reportedly cracked and in poor condition. Migration of contaminants can occur when rainwater percolates through the soil downward to the underlying groundwater. If a prescribed cap fails to prevent soil contaminant migration to the groundwater, a potential exists to re-contaminate the entire groundwater treatment area. In presented case study, the “cap” was cracked and in poor condition; and therefore, unsuitable to prevent rainwater percolation through the contaminated soils. If selected as a viable option, a cap must be appropriately designed and engineered to prevent migration of soil contamination to the groundwater.

Leaving a source of soil contamination in-place should be a major concern for business and property owners. A responsible party should consider the potential liabilities and obligations of a remedy that leaves any contamination in-place. Contamination left behind can result in long-term monitoring requirements for an indefinite period of time, in some cases 30 years or more; in addition to severely limiting the future reuse of the property. During the remedial planning phases of a project, it is important to choose a proven remedial strategy that will remove contamination across all media phases, thereby reducing future liability and long-term stewardship requirements (LTS).

LTS requirements typically include monitoring and assessing exposure to contaminants remaining in-place which could pose a risk. LTS plans are developed with specific strategies to monitor and assess contaminant exposure over an indefinite period of time. Monitoring can be required until contaminants reach a level that do not pose a risk. When dealing with recalcitrant contaminants like trichloroethene (TCE) and tetrachloroethene (PCE) that don’t readily breakdown in soils, this can be a very long time. The burden of LTS requirements can ultimately be placed on the responsible party owner indefinitely.

EnviroForensics’ expert team understands the potentially-high cost and lengthy responsibilities associated with long-term environmental problems–we know it’s essential to address contamination at its source. We assist property owners every day to develop appropriate plans for cleanup of soil and groundwater so that business and property owners understand the remediation plan and are not burdened with long-term environmental issues. Our team of environmental professionals possess the skills and experience to accurately assess environmental contamination and create cleanup strategies that minimize future liabilities. We know that remedial strategies including LTS do not fit into your overall business goals, which is why we make it our business to ensure remediation plans clean up your property and limit future liabilities and long-term requirements.

About the Author

Jennifer Hallgarth, L.P.G.

Senior Project Manager

Ms. Hallgarth is a licensed professional geologist with over 10 years of experience in environmental consulting with focus in insurance claim expertise.  She has been responsible for management of numerous chlorinated solvent and petroleum projects throughout various stages of investigation, remediation and closure; ranging from $1,000 to over $1,000,000.  Ms. Hallgarth has experience in due diligence, compliance, remediation, reporting and regulatory negotiation. She has directed numerous subsurface investigations of varying size and employed a variety of remedial technologies including: soil excavation, air sparge, soil vapor extraction, multi-phase extraction, and chemical oxidant injection.

Ms. Hallgarth has conducted various vapor intrusion assessments including property access coordination and risk-communication with residents, business owners and stakeholders.  She has employed vapor mitigation using sub-slab and sub-membrane depressurization systems, and other techniques to control indoor air exposure.

Ms. Hallgarth has experience in file reviews, forensic investigation design, reserve estimating, claim coverage evaluation, cost allocating, settlement, litigation support and third-party oversight.  She has interfaced and negotiated with property owners, insurance carrier groups, attorneys and other stakeholders.

EnviroForensics Successful in Obtaining Site Closure for Sites Impacted with Chlorinated Solvents

Cleaning up soil and groundwater contaminated by chlorinated solvents, such tetrachloroethylene (PCE) and trichloroethylene (TCE), can be a lengthy and complicated process. When compared to environmental releases from run-of-the-mill retail petroleum sites, achieving regulatory closure for chlorinated solvent sites is not all that common. There are several factors that contribute to this reality; some of which are explained in more detail in The Unbalanced Cost of PCE Spills. It takes a great deal of specialized expertise, experience and technical strategy to close a chlorinated solvent site, and EnviroForensics is an industry leader in this category.

In the past five years we have:

  • Achieved regulatory closure for 12 chlorinated solvent sites;
  • Remediated 6 additional chlorinated solvent sites currently in the post-remediation closure monitoring phase; and are
  • Actively implementing remedial measures in accordance with approved work plans at 15 more than chlorinated solvent sites.

What sets us above our competitors? Our staff of skilled and experienced hydrogeologists, geologists, engineers and scientists who are specialized in developing innovative, risk-based approaches to remediating soil and groundwater contamination to achieve site closure. Our engineers use the most current and effective technologies, including in situ biological and chemical remediation, in addition to traditional mechanical and physical contaminant removal methods. We handle everything from site investigation to risk assessment and site remediation, all while working to ensure our clients’ out-of-pocket expenses are kept to a minimum by locating and utilizing their old insurance policies to help fund cleanup costs.

Our goal is always to obtain site closure for our clients’ properties, and we have been successful in doing so.  We work to restore the value of our clients’ properties and businesses in a way that won’t place financial strain on them. Our clients are always our priorities, and you can trust EnviroForensics to turn your environmental liabilities into assets.

Update: Indiana House Bill Limiting State Regulation Receives Significant Edits

In February, we posted on our blog about a bill approved by the Indiana House that would prevent state regulatory agencies from passing environmental laws tougher than those enforced by the federal government. The controversial bill was sent to the Senate for consideration by a 64-33 House vote. In light of justified objections, the bill has now undergone significant edits.

Despite obvious support from industry groups, the bill was seriously opposed by environmental and public health groups—for good reason. Although the bill would have potentially saved businesses money by limiting possible expenses for environmental compliance and cleanup, it would have effectively stripped Indiana’s regulatory agencies of the power to accurately address our state’s unique environmental concerns. Considering Indiana has been ranked one of the most polluted states in the country, a bill limiting our state’s environmental regulation could have devastating effects.

The language that would have restricted state environmental regulators from imposing laws harsher than the federal standard has been removed from the bill. Instead, the bill now simply requires the Indiana Department of Environmental Management (IDEM) to inform the legislature each year on new rules it’s developing and enacting.

Environmental advocates who expressed concern over the initial wording of the bill seem pleased with the new revisions. Although the bill will still allow for additional scrutiny of regulatory bodies by the legislature, it is no longer limiting their ability to protect Indiana from environmental harm. In the initially-approved version of the bill, Indiana would have been restricted to the oftentimes vague federal guidelines for states, which have not always gone far enough in protecting Indiana from serious environmental issues—such as livestock farm manure pits.

While this restrictive wording has currently been removed from the bill, that doesn’t mean it won’t be brought up again in the future. It’s important that environmental advocates remain aware of legislation being pushed by the House to limit environmental regulation, and it’s even more important to speak up when such bills are proposed. The rewriting of this latest bill proves how much of an impact our voices can have.

EnviroForensics’ Second Lunch & Learn in the 2016 Series Discusses Insurance Archeology

EnviroForensics’ monthly Lunch & Learn program is designed to bring employees together to learn more about a specified company- or industry-related topic. Our 2016 series, What We Do & How We Do It, will take employees step by step through our unique and challenging way of supporting our clients. The first installment last, How Past Dry Cleaning Practices Resulted in Environmental Releases,took place in January and delved into the history of chlorinated solvents and the dry cleaning industry—taking attendees back to the roots of the environmental consulting industry.

Last week, EnviroForensics’ employees were invited to attend a presentation to learn more about funding sources for the environmental work that we do. We have had many successes in helping our clients find hidden financial assets to help them address demands for environmental investigations and cleanups. Attendees enjoyed an employer-sponsored lunch while learning more about this aspect of our business.

Although the majority of our employees may not be involved in this part of our company on daily basis, we feel it is important for employees to possess an understanding of every component of what we do. Not only does this ensure that we remain a cohesive team, but also helps everyone to better recognize their own role in the overall business model and see how everything fits together. It is for this reason that we have established the What We Do & How We Do It series, which will continue through 2016.