Category: Site Investigation and Remediation

Helping you with property redevelopment after remediation

Posted on by EnviroForensics Staff

Often times our clients are concerned about our work impeding their business, or worse yet, standing in the way of reaching the goal of property redevelopment.  To the contrary – our work from the big picture, helps them gain back their property as an asset.  A case in point is when clients of ours in southern Indiana were going out of business due to less demand for services, they were trying to sell their property.  After having several interested buyers walk away because of rumors that the EPA forced them to close due to the environmental problems, we offered additional service.  Our marketing team created a flyer which contained vital information regarding notifying prospective buyers of the ongoing and “all expenses paid” environmental clean-up at the property and enrollment of the site in the Voluntary Remediation Program (VRP). This information will educate prospective buyers, and should put them at ease with regard to the environmental status of the property. The clients were very happy and thankful we are looking out to help them with property redevelopment.

Helping Clients with Property Redevelopment - Commercial Real Estate Poster

 

Poster text: “The property has been enrolled in the Voluntary Remediation Program (VRP) with the Indiana Department of Environmental Management (IDEM). We have cleaned clothes for decades and prior to selling, have engaged with the IDEM voluntarily to clean up the environment beneath and around our facility. The process is common among dry cleaners and other industrial facilities. In this case, it is being fully funded to comply with the IDEM and perform the reasonable and necessary work to obtain the clean bill of health for the property. This is good news for any prospective purchaser! There is currently a Remediation Work Plan (RWP) submitted to the IDEM that is moving the Site property toward regulatory closure. The facility is in the heart of the commercial district in a great location. Please feel free to address an inquiries too: John & Jane Doe at 555-555-5555.”

What it takes to keep our remediation systems running

Posted on by Alex Miller

Remediation is a calculated, and deliberate process. One that takes months and sometimes years, depending on how large the volume of contaminant is. Luckily, we have high-tech solutions that help us with the day-to-day monitoring of the cleanup process. We regularly install remediation systems that work autonomously and without the need for constant supervision, which saves our clients time and money. But, in order to reap those benefits, we must make sure we’re properly maintaining the mechanical components of remediation systems.

Whether it’s a Soil Vapor Extraction (SVE), Dual Phase Extraction (DPE), Air Sparge, or Ozone Sparge System, we enact a regularly scheduled preventative maintenance program. The idea is to keep the system running efficiently, and catch any potential problem before it turns into a real problem. The focus, during our maintenance visits, is on keeping the system clean, lubricating bearings and other moving parts, correcting deficiencies (i.e. worn or broken belts, rusted hardware, dirty filters), and operating safety devices. We also pay close attention to hazard controls like machine guards, exhaust ventilation, silencers, control technology, and other devices important to the operation of the machine.

There are two obvious advantages to Preventative Maintenance. First and foremost, it preserves and enhances the reliability of our equipment and ensures optimal efficiency. A broken component that goes unrepaired could lead to bigger issues down the road, costing the client both time and money. And when we offer our services, we make promises to our client, and we don’t like to break them. Maintaining a working remediation system that will operate either at or underneath the quoted costs goes a long way in helping us keep those promises.

Another distinct advantage to Preventative Maintenance is that it helps us reach our health and safety goals. Proactive repairs protect us from possible injuries caused by malfunctioning equipment. Thorough record-keeping allows for more seamless automation and upkeep, and gives us more transparency with our regulatory partners. As we mentioned earlier, it also improves the efficiency of the system in removing contaminants, and the ultimate goal is to root out the human health risks anyway.

We appreciate the technology that we have at our disposal. Active remediation systems allow us to conduct the meticulous process of remediation without continuous human supervision and oversight. The caveat is maintaining these systems, making sure they’re running at optimal efficiency, and uncovering any problems before they cost the client time or money. A properly executed preventative maintenance plan allows us to stay one step ahead.

 

What we look for during a preventative maintenance check of our remediation systems

 

Above are three good examples of things we look out for during maintenance of our remediation systems. Dirty filters, signs of wear, and rust are things that could impact the efficiency of our systems.

Having All of Your Bases Covered During a Phase I Assessment

Posted on by EnviroForensics Staff

When conducting a Phase I Environmental Site Assessment for a property transaction, it’s important to understand what your client wants to do with the property. A solid grasp on their project and objectives can go a long way in identifying all environmental due diligence topics that may apply. Many people don’t realize there are Out-of-Scope topics not covered by the Phase I Assessment reporting standard, and if overlooked, they could present environmental liability issues to a prospective purchaser.  These include:

 

•      Wetlands – For properties undergoing development, assessment is ESSENTIAL.  Regulated federally by the Army Corp of Engineers and by IDEM in Indiana.

•      Mold – Can pose health concerns.  No state or federal regulations on mold assessment in Indiana but guidelines are in place by several trade associations.

•      Asbestos – Can pose health concerns and can be costly to abate.  Regulated by EPA federally and IDEM in Indiana.

•      Lead Paint – Can pose health concerns and might apply to any project involving painted surfaces: multi-family residential, child care, bridge repairs, and commercial structures.  Regulations vary by project.

•      Environmental Compliance – Is the business following all federal, state, and local environmental laws and regulations?  Could be relating to permitting, reporting, waste disposal, etc.

•      Air Quality – Can pose health concerns.  In addition to vapor intrusion (covered by the Phase I standard) indoor air quality from an indoor source may be a concern.  Regulations may include OSHA, but vary by source.

 

If you are hiring an environmental consultant to conduct due diligence investigations at a commercial or industrial property, be sure to discuss your specific needs and not assume that all topics will be covered in a Phase I Assessment report.  Communication is the key to success!

 

New Hazardous Waste Management Rules Are Coming Soon – Are You Ready?

Posted on by EnviroForensics Staff

Some of our drycleaning clients are in the process of, or already have transitioned away from perc solvent, but there are still plenty of functioning perc drycleaning machines currently in operation across the country.  Parts degreasers utilizing chlorinated solvents are also commonplace.  All spent chlorinated solvents have to be properly managed and disposed of in order to avoid unintentional releases to the environment.

Spent solvents are considered hazardous waste under the Resource Conservation and Recovery Act (“RCRA”). Depending on the amount of solvents used and disposed of, the user is either classified as a Very Small Quantity Generator (“VSQG,” formerly CESQG), a Small Quantity Generator (“SQG,”) or a Large Quantity Generator (“LQG”). Most, but not all of our clients are either VSQGs or SQGs, the difference being that SQGs are required by law to report their activities and acquire a RCRA waste disposal number from their state regulatory agency.

Since its passage into law in 1980, RCRA has seen some changes; the U.S. Environmental Protection Agency (“EPA”) and industry are constantly looking to fine-tune the process of safe disposal of hazardous waste while not overly burdening the industries that generate it as a by-product of their operations. EPA’s last rulemaking affecting the hazardous waste generator regulatory program was in 2004 and addressed many of the remaining rough edges.The most recent rulemaking, which goes into effect this fall (2016), further improves the process by building in flexibility for generators who properly dispose of their waste.

How do these new rules regarding Perc this affect our clients?

  1. The new rules allow a generator, who normally falls under VSQG/CESQG or SQG status, avoid categorization as a higher status generator during a month in which they generated episodic waste, so long as they properly dispose of said waste.
  2.  They allow VSQGs to send hazardous waste to an LQG that is under the control of the same person, allowing for satellite locations of larger facilities to consolidate and dispose of waste in a more efficient manner; and
  3.  They make it easier for generators located in urban environments who find it difficult to meet the requirement that containers holding ignitable or reactive waste be placed 15 meters (50 feet) from the site’s property line by allowing generators to apply for a waiver from this requirement from their local fire department or emergency response organization.

While RCRA is not the model of legislative clarity, these most recent proposed rules from EPA look to further simplify the requirements on industries that produce hazardous waste while maintaining protection of human health and the environment. If you have questions about compliance with these new rules, EnviroForensics has professionals trained in managing hazardous materials who are on hand to assist you.

EPA Adds West Vermont Street Site to Superfund List

Posted on by Alex Miller

Following nearly a year of speculation, an 18-acre groundwater contaminant plume on Indianapolis’ West Side, has landed the area on the U.S. Environmental Protection Agency’s new Superfund list.  Superfund is a federal program that aims to address some of the most contaminated land and waterways in the country.

In September 2015, the EPA made the proposal to put the West Vermont Street groundwater site on the National Priority List. In 2009, Marion County Health Officials had discovered high concentrations of vinyl chloride (a breakdown product of drycleaning solvents) in the drinking water of three homes near the Allison Transmissions plant, just south of the Indianapolis Motor Speedway.

Proposal Map for West Vermont Street Superfund Site. Courtesy: United States Environmental Protection Agency
Proposal Map for West Vermont Street Superfund Site. Courtesy: United States Environmental Protection Agency

 

According to EPA officials, there were at least 20 other potentially affected homes in the area, and immediate action was taken to ensure the health and safety of these homeowners. Utility workers diverted the water service from the underground water wells in the area to municipal water.

Even with this measure in place, EPA officials determined the potential danger of the groundwater plume was too much to ignore. Investigations confirmed the migration of the plume could put as many as 18 thousand people at risk of becoming exposed to the contaminant.

EPA officials are now conducting further investigations to delineate the horizontal and vertical nature of the plume, filling in data gaps, and identifying all potential exposure pathways including vapor intrusions. A few potential responsible parties have been identified as a result of their historic operation and known individual contaminant releases on their properties.

EnviroForensics has been involved in SuperFund sites like this one around the Indianapolis area, including the Keystone Corridor Project, and we know how important this work is. We look forward to providing additional information as new developments arise regarding this project.

A Vapor Intrusion Success Story

Posted on by EnviroForensics Staff

Sometimes detecting and addressing a vapor intrusion pathway is like a giant game of whack-a-mole. As soon you knock one down, another one pops up, and so on and so forth. One of our teams recently encountered this issue, having discovered that their initial mitigation efforts had not decreased the concentration of tetrachlorethene (PCE) inside an apartment located above a dry cleaner.  Despite this setback, our team dusted themselves off, and went back to work, going by the old addage; if at first you don’t succeed, you try again.

To give you an idea of what we were working with, our site building is a 2-story structure with a dry cleaner on the first floor, and an apartment on the second. The dry cleaner is now a drop-off only location, but had conducted on-site cleaning in the past. We discovered PCE in the sub-slab vapor underneath the structure, which helped us determine there were vapor intrusion risks to both the dry cleaner building and, perhaps more importantly, the apartment above it. We installed a sub-slab depressurization system (SSDS) to address this issue.

Unfortunately, that did not solve the problem. Indoor air PCE concentrations in both the first floor dry cleaner and second floor apartment remained above the residential vapor action level despite the operation of the SSDS. The concentrations were similar on both floors, which suggested direct physical pathways for indoor air movement. The HVAC systems that services these spaces were the most likely culprit.

Armed with this new knowledge, we focused our efforts on the first floor room that houses both of the HVAC systems. We first sealed up the mechanical room, using an air-tight door gasket and sweep. Duct work and piping penetrations in and out of the mechanical room were also sealed and a furnace filter cover was added to prevent the apartment furnace system from potentially capturing vapors from the first floor. We then installed door gaskets between the first floor store and the second floor apartment stairway. The final touch was an energy recovery ventilator (ERV) installed on the apartment’s furnace to increase fresh air exchange.

Early returns suggest this latest attempt to address the problem was successful. The first post-mitigation indoor air sample collected from the apartment did not contain PCE above laboratory detection limits. Our team will conduct a confirmation air sampling event during the upcoming winter months, when conditions will be ideal for a “worst case” air assessment.

In the Environmental Cleanup business, there really isn’t any room for failure. The preceding is a good example of the trial and error we go through when looking for all potential vapor intrusion pathways. Using the experience and ingenuity we have managing contaminations like this, we were able to come up with another solution. And, at least in the short run, it appears the residents of that 2nd floor apartment can breathe easy without having to worry about the potential health risks of exposure to PCE.

image was a courtesy of Washington State, Department of Ecology
image was a courtesy of Washington State, Department of Ecology

Putting the Forensics in EnviroForensics

Posted on by EnviroForensics Staff

When you hear the word “Forensics”, often times it conjures up images of television detectives. You imagine a hard-boiled cop working on his second cup of coffee, lifting up the caution tape on the police perimeter, so he can walk onto the crime scene and begin to reconstruct what happened. He collects clues like patches of fabric, hair and blood samples. Talks with witnesses and potential suspects; interrogating the shifty ex-con whose fingerprints are all over the crime and whose past won’t afford him the benefit of the doubt. It all invariably leads to the climactic finish with the unlikely perpetrator being caught in the final ten minutes of a neatly wrapped 60-minute serial. Environmental Forensics is kind of like Hollywood forensics – we reconstruct the past to answer questions like “who done it?”, and its application can assist in a multitude of ways when dealing with an environmental liability.

Environmental forensic investigations differ from traditional environmental investigations in that the objective is not to identify human health exposure pathways or answer remedial feasibility and design questions, but rather to answer specific questions about historical contaminant release scenarios.  The leading question is typically, “who is responsible?”  To answer this question, it is often instructive to determine where and/or when the release occurred.  Other potentially useful information may include contaminant type and indicator parameters detected with the contamination.  The need for a forensic investigation often comes about through environmental litigation proceedings, but forensic evidence can also be used to support insurance claims, out-of-court settlement proceedings, or other questions that may be aided by understanding the contaminant release and migration history at a site.  We have many tools to use for this purpose, including Fate and Transport Modeling (most common), Compound Specific Isotope Analysis, Principal Components Analysis, and Chemical Ratio Analysis, to name a few.

Just like our Hollywood example, forensic evidence in an environmental case also plays a huge role in the legal side of things.  We deal with the question of “who-done-it” a lot.  After all, figuring out who’s responsible/liable is what sets this whole thing into motion in the first place.  Often times, there are multiple, overlapping plumes with more than one potentially responsible party.  Forensic evidence can help us determine who is at fault, if there are any other responsible parties, and if a suit or claim is defensible.

It may not be as dramatic or as glamorous as the criminal forensics you see on TV, but environmental forensics is still a very important and useful practice.  The tools involved allow us to determine the nature of a release of a chemical contaminant, the timing of release, and perhaps most importantly, the source of release.  These facts not only help us better understand the site and recommended courses of action, but also aid in cost allocation, identify responsible parties, and support litigation proceedings.

 

 

Where There is Exposure, There is a Problem: Identifying Exposure Pathways

Posted on by Alex Miller

It may seem like the objective of every project is to completely wipe out contamination, but it’s a little more nuanced than that. Sure, we want to make certain that a client’s property is as clean as it can be for future use, but it’s also important to consider where actual risks to human health occur in situations where a thorough site cleanup isn’t possible. That’s why, when we develop a Conceptual Site Model (CSM) a key component is the identification of potential exposure pathways and receptors. Once we can prove there’s no possible way a human can come in contact with the contaminant, we’re one step closer to obtaining the coveted “No Further Action” letter from the regulatory body with which we’re working.

It all starts with the investigation. In short, we use the data collected from soil and groundwater tests to delineate and characterize the horizontal and vertical nature of the contamination plume. The size, shape, and location gives us a general idea of which structures and buildings may be impacted, and, using this information, we can draw up our CSM.

In the Conceptual Site Model (seen in the simplified figure below) you can see we’ve labeled the actual dry cleaner machine (the established source of contamination) the buildings resting above the contaminated soil and groundwater, the different types of impacted soils,  groundwater and all identified migration pathways.  The contaminant migration pathways are indicated by the arrows in our figure.

Conceptual Site Model Example

The next step is to test those pathways to determine if there’s a potential for exposure, because where there’s exposure, there’s a problem.  We start at the established source, and work our way down and up from there, checking surrounding structures for possible vapor intrusions, and testing soil and groundwater impacts and the possible receptors they could come in contact with (sewer laterals, sewer mains, groundwater wells, and the like.)

Once we’ve determined the existing pathways, it’s time to figure out what (if anything) needs to be done. We conduct an exposure assessment based on the type of receptors being impacted. Those receptors can be humans, utility corridors, drinking water wells, and the like. As an environmental consultant, we want to wipe out any contamination, but we are also beholden to both the institutional constraints and the client’s legal obligations. Identifying the potential exposure pathways at a Site can help us pin-point our focus as we draw up our site closure strategy.

 

 

Thermal Remediation: How to put VOCs on the Hot Seat

Posted on by Alex Miller

We know that chlorinated solvents tend to volatize on their own, so what happens if we use the chemical’s physical properties to cause them to volatilize even more? That’s the concept behind Thermal Conductive Heating (TCH) or Electric Resistance Heating (ERH). The idea is to heat the subsurface to such a temperature that any present contaminant becomes volatized and can be removed from the soil and groundwater. Using super-heated metal rods (TCH) or an electric current (ERH) along with some familiar applications from remedial techniques we’ve touched on in the past, a “thermal” approach can make for an effective remediation strategy for sites where other techniques are less feasible.

Excavation might not be an option if above ground structures are in the way or if contamination is too deep. Soil Vapor Extraction Systems (SVE) can prove to be an effective solution, but can prove to be equally ineffective if the contaminant plume is too deep or the concentration of the contaminant is too great. In other cases, the contamination could be resting in a patch of more dense clay soil, making it more difficult to extract contaminants. Contamination in saturated clay soil can be slowly released into groundwater over time in a process known as “back diffusion,” which makes it more difficult to achieve cleanup goals. In all these scenarios, TCH or ERH can be a viable option.

Thermal Conductive Heating
Figure Courtesy of: Terratherm

 

 

 

 

 

 

 

 

 

 

 

 

A thermal remediation system has a set of components that, working together, can effectively remove contamination from a cleanup site. The first component is the heat itself. In a TCH application, several heating rods are placed into the impacted areas to effectively raise the temperature of the ground. Additionally, a vacuum component will be installed into these wells to extract the vapor generated by the heat. If necessary, groundwater extraction wells will be installed near the heating wells to collect impacted groundwater. Treatment systems are used to remove contaminants from the water and vapor that has been extracted.

Once the thermal remediation process is started, the components operate like workers on an assembly line. Heat is applied to the subsurface, chemicals become volatized, and contamination is collected in the vapor phase by the vacuums in the heating wells. The vapors are put through a treatment component, then released into the atmosphere.  Groundwater is extracted from the subsurface as well and goes through a treatment process of its own.

“Thermal” applications are considered “in-situ”, or in-place, and are perfect for sites in which demolition or excavation are not possible, or the contamination cannot be addressed by any other means.

Eliminating Background Sources of Vapor Contamination at Active Dry Cleaners

Posted on by Jeff Carnahan

Vapor intrusion continues to be one of the most common exposure pathways that we investigate in our work at EnviroForensics.  We’ve mentioned in past blogs that many household and commercial products can serve as background sources of contamination in indoor air, making it difficult to determine how much contamination is truly due to vapor intrusion from the subsurface.  The presence of background sources is likely to increase concentrations of contaminants in indoor air samples if they are not eliminated prior to sampling and this bias may misrepresent indoor air as it relates to vapor intrusion.  Therefore, elimination of background sources is necessary to obtain a true measurement of indoor air quality related to vapor intrusion.

But what about cleaning products and emissions at an active dry cleaning businesses?  Dry cleaning emissions are also considered a background source that can contribute to indoor air conditions, but removing them is not as easy as simply moving a bottle of cleaning supplies out of the building before samples are collected.  IDEM recently required indoor air sampling in each tenant space at a strip mall where one of our clients owns a coin operated laundromat and actively performs dry cleaning with PCE and TCE. The EnviroForensics team had to go the extra mile to make sure background sources were eliminated as best as possible before collecting the air samples.

After assessing the strip mall’s basic construction and configuration to gather information pertaining to air circulation, we determined that the best approach was to physically remove as many cleaning materials containing PCE or TCE as possible and then complete a fresh air exchange in each tenant space at least 48 hours before sampling.  We worked with our client to determine a period of time when his business could continue to operate but cease dry cleaning for approximately three (3) days.  Cleaning products that could easily be removed were taken out of the building, but materials were not drained from the dry cleaning machine and dry cleaned clothes were wrapped in plastic and left in place.

After coordinating with the other businesses in the strip mall, a fresh air exchange was conducted in each tenant space using a ventilation fan to draw air from inside the building to the outside, allowing fresh air to flow in.  When the air exchange was complete, the EnviroForensics team waited 48 hours before collecting indoor air samples inside each tenant space.  In doing so, the project team able to satisfy the IDEM requirement for vapor intrusion assessments, making sure that the samples collected were truly representative of vapor intrusion from subsurface conditions.

EnviroForensics continues to think outside the box to identify viable solutions that will minimize the burden on our client’s ability to run their business while addressing their environmental liabilities.