Category: Site Investigation and Remediation

More than fifty years after its final nuclear test, federal contractors are proceeding with a massive undertaking to clean up a site in New Mexico made famous by the “Manhattan Project.” The Los Alamos National Laboratory, which opened in 1943, was used to test and develop the atomic bombs that would later be dropped on Hiroshima and Nagasaki, Japan, during the final months of World War II. Projects to address this enormous environmental liability had been moving at a slow pace until last month.

In June, the New Mexico Environmental Department (NMED) and the U.S. Department of Energy (DOE) agreed on a Consent order to expedite all remaining work on legacy waste management from the laboratory. With this new Consent Order in place, federal contractors are now working on remediating the south facing slopes of the Los Alamos Canyons. Although this project involves a different type of contamination than the dry cleaning solvents we at EnviroForensics manage on a daily basis, there are similarities that we couldn’t help but notice.

Nuclear explosion tests at the site halted in 1965, and very little has been done up to this point to address the public health risks left behind by the years of nuclear testing. At the time of the nuclear testing, there wasn’t much known about the adverse effects of being exposed to high concentrations of radiation and nuclear fallout. As medical researchers eventually realized the dangers of these toxins, the concern for public health increased, as well as the necessity for a remedial solution. Similarly, PCE was once the leading solvent used in commercial dry cleaning. After 2007 when it was classified as a Group 2A carcinogen by the International Agency for Research on Cancer, it started losing momentum and began to be replaced by less toxic solvent alternatives.  Like the nuclear scenario described above, commensurate health studies on PCE didn’t come until long after its widespread use. Past handlers of these toxic substances in both cases had no way of knowing their practices could have such long-lasting potential health effects.

The DOE has chosen excavation to help complete this part of the legacy waste cleanup. As we’ve mentioned in previous blogs, excavation is one of the most straight-forward ways to rid a Site of many contaminants, including PCE.  Crews at the “Manhattan Project” site will dig in five separate zones in a 1 acre area along the south facing slopes, with the objective of removing 125 cubic yards of contaminated soil. Similar to the manner PCE contaminated soil is handled, the crews in New Mexico will prepare the soil and approve it for transport to a hazardous waste facility.

The south facing slopes of the Los Alamos Canyon is not considered a residential area, but the ultimate goal of this cleanup is to reduce the concentration of the contaminants (in this case Arsenic and Plutonium) to the EPA’s mandated “residential” levels. The hope is to redevelop the area around the Los Alamos National Laboratory site with commercial and residential real estate. Often times, the aim of a PCE site cleanup is also to remove the potential health risks for future tenants that have redevelopment on their minds.

NMED estimates the rest of the Los Alamos National Laboratory legacy cleanup will take another 19 years to finish and cost up to $3.8 billion. Chlorinated solvent cleanups often take years and cost hundreds of thousands or millions of dollars. In both cases, it seems an immediate or proactive approach is always the best way to go about addressing these problems.  Quicker action leads to more cost-effective solutions and a healthier environment for all.

The Indiana Department of Environmental Management is hoping some changes to the Voluntary Remediation Agreements participants in its Voluntary Remediation Program (VRP) execute in order to join the VRP will get projects that have stalled for years off the ground. A recent report from an Indianapolis news station indicated hundreds of sites participating in the VRP have gone unchecked for years, insinuating that the responsible parties (RPs) had been using the VRP as a loophole to delay cleanup while not having to face the legal ramifications of their inaction. In contrast to the State Cleanup program, the VRP offers its participants protection against future IDEM liability with a covenant not to sue at the completion of the cleanup. The new guidelines offer a more detailed set of benchmarks and deadlines in order to root out this problem.

Under the old guidelines, if an RP wanted to take part in the VRP, it had to have its chemical plume well-defined. The new requirements allow for a 2-year window for the plume to be fully characterized and investigated after signing the Voluntary Remediation Agreement (VRA). The IDEM’s new deadline for investigation and site characterization should force RPs to address their environmental issues or lose the protections against liability that the VRP provides in contrast to the State Cleanup program.

Also, a new, clear deadline has been set for the development and submission of a Remedial Work Plan (RWP). A responsible party and its environmental consultant have 180 days to conduct their initial and further site investigations and come up with a RWP to put into action. If they don’t comply with this deadline, the responsible party runs the risk of being taken out of the VRP, opening them up to possible lawsuits. However, the updated rules are not completely inflexible: once an RWP has been submitted, stakeholders and VRP project managers are given a little more leeway. Deadlines will be determined on a case-by-case basis.

For years, companies responsible for hazardous chemical contaminations have hid behind and took advantage of a program that’s number one priority is to protect human health and cleanup contamination while offering a layer of protection to its participants. The hope is with these new modifications to the VRAs, the prior inaction by VRP participants should be prevented from happening.

When it comes to cleaning up a contaminated site, there aren’t that many methods simpler than just removing the soil. Unfortunately, that soil has to go somewhere, and that’s where excavation can get pricy. Moving PCE contaminated soil to a specialized or “hazardous” landfill can cost hundreds of thousands of dollars. EnviroForensics’ teams are employing some new technology out in the field that is expected to take a few zeroes off the bottom line. With the implementation of a few relatively new chemicals, soil that was once considered hazardous can be brought to a regular non-hazardous landfill.

Here’s how it works. Field engineers add a mixture of water and a chemical called PersulfOx (developed by Regenesis), a white powdery substance that actually destroys volatile organic compounds (VOCs) like PCE and TCE, to the impacted soil. The PersulfOx reduces the concentration of the VOCs in the soil.  A few weeks later the EnviroForensics team returns to the site, tests the soil, then conducts another round of “Soil Mixing” as needed.  Once the soil testing reaches safe levels (of PCE and/or TCE), it can be transported to a non-hazardous regular landfill. Quicklime is then mixed in to dry out the soil for transportation and to increase and buffer the soil pH.

The cost difference between sending the contaminated soil to a hazardous landfill (also known as a Subtitle D landfill) and a “regular” non-hazardous landfill is staggering. What typically costs upwards of $500 per ton, now costs just $70 a ton, when you treat the soil, and transport it to a regular landfill. The savings on this part of the cleanup alone should be enough to keep this as a viable remediation method moving forward.

The U.S. Environmental Protection Agency (EPA) has established health advisories for two chemical contaminants called PFOA and PFOS based on the agency’s assessment of the latest peer-reviewed science. These advisories will provide the most up-to-date information on the health risks of these chemicals and aid drinking water system operators and state, tribal and local officials in making determinations as to the appropriate steps needed to address PFOA and PFOS in their communities. EPA’s assessment indicates that drinking water with individual or combined concentrations of PFOA and PFOS below 70 parts per trillion (0.07 micrograms per liter ug/L) is not expected to result in adverse health effects over a lifetime of exposure.

Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are manmade chemicals that are part of a larger family of chemicals called perfluoroalkyl substances (PFASs). PFOA and PFOS have been used in a number of consumer products, including; carpets, clothing, fabrics for furniture, leather, paper packaging for food, and as coating additives for waterproofing or stain and grease-resistant agents used in cookware and other materials. They are also used for firefighting at air-fields and in a number of industrial processes.

Exposure to high levels of PFOA and PFOS may result in developmental effects to fetuses during pregnancy or to breastfed infants, cancer, liver effects, immune effects, and thyroid effects.

For most people, their source of exposure to PFOA and PFOS has come through food and consumer products. But drinking water can be an additional source of exposure in the small percentage of communities where these chemicals have contaminated water supplies.  This is typically a localized issue associated with a specific facility, such as a manufacturing plant or airfield that made or used these chemicals.

Even though releases of these chemicals to surface water and groundwater is expected to decline given the limited ongoing uses of PFOA and PFOS-related chemicals, risk of exposure is still possible due to their legacy uses, existing and legacy uses on imported goods, and degradation of precursors. Additionally, PFOA and PFOS are very persistent in the environment and in the human body. They have been detected in water, wildlife, and humans worldwide. EnviroForensics employs technical experts in the field of environmental risk assessment and can aid in investigating, remediating, and conducting human health risk assessments to limit exposure to these chemical contaminants, as well as other environmental contaminants.

The Drinking Water Health Advisories for PFOA and PFOS, and supporting documents can be found at the following link:

https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos

The water crisis in Flint, Michigan has sparked concerns over the cleanliness drinking water in Indianapolis and in every city and town across America. It seems like everyday we are learning about new sites where environmental contamination has been found presenting health risks to residences in rural and urban neighborhoods.  Here at EnviroForensics we applaud the media for highlighting this problem and want to clear up one major misconception regarding how fast or slow environmental investigations and remediations take place.  While many, many sites take an unnecessarily long time to get through the investigation and remediation process, we pride ourselves in pushing projects to site closure.  In fact, we have closed more solvent contaminated sites than any company in the Midwest,  because we know that it is in our clients’ best interest as well as the communities’ best interest.

Recently, Channel 13 in Indianapolis, reported on a series of potentially dangerous contamination Sites across the state that have gone unchecked for years. These chemicals can get into the drinking water or seep into homes in the form of vapor, creating a risk to residents.

While it is the Indiana Department of Environmental Management’s responsibility to ensure that the public is being protected from the contamination at these sites, some businesses find loopholes in the system that allow the cleanup process to drag on and on for years.

In the report by Channel 13, they found hundreds of businesses that have been protected from lawsuits by being in IDEM’s Voluntary Remediation Program while performing little to no cleanup for years and in some instances decades.

Our goal at EnviroForensics is to make sure a chemical contamination never becomes a serious risk to public health. We pride ourselves in working with our clients to cleanup environmental contamination in a timely manner so that the environment is cleaner and their property values can be restored.  At EnviroForensics we live by our moniker that we Turn Environmental Liabilities Into Assets and this can only be achieved by remediating contaminated sites.

Citizens, business owners and community leaders of the Riverside neighborhood met with the US EPA, Citizens Energy Group and environmental professionals on May 24, 2016 at the Riverside Community Center to discuss the possibility of adding a group of city drinking water wells to the National Priority List (NPL) as a Superfund site.

While the Indiana Department of Environmental Management (IDEM) was noticeably absent from the meeting, citizens expressed their concern that designating this area a Superfund site would tarnish the neighborhoods reputation, hindering economic development and diminishing the hard work that their community has conducted in turning the area around.

Last April, the EPA announced a proposal to add the Riverside Groundwater Contamination site in Indianapolis to the NPL.  The NPL is EPA’s list of Superfund sites.  Superfund is a federal program that investigates and cleans up the most complex or uncontrolled or abandoned hazardous waste sites in the country.

The problem stems from groundwater samples collected from the city’s municipal drinking water wells that showed elevated levels of vinyl chloride and 1,2-dichloroethylene, chemicals found as a breakdown products of solvents commonly used by dry cleaners, small businesses, and manufacturers.  Representatives from Citizens Energy, manager of the city water supply, repeatedly stated that the drinking water was safe to drink and that water from the contaminated wells was mixed with other city water and treated before being supplied to their customers.

While many current and former businesses in the area have been identified as causing groundwater contamination, many more locations will likely come under scrutiny as being potentially responsible for the groundwater contamination of the city’s wells.  But, because the drinking water wells draw groundwater from two distinct water-bearing units nearly 100 feet below the land surface, it is very costly to collect soil and groundwater samples necessary to accurately identify the contaminant sources. In the past IDEM officials have expressed their lack of manpower and financial resources to take on this investigation and presumably asked EPA to assist them in those efforts.

The meeting was intended for EPA to educate the public on the process it uses to evaluate, score and rank sites when determining whether or not to actually list and designate a site as Superfund-eligible.   Frustration and surprise were commonly expressed by the general public and community leaders as they learned for the first time that EPA’s 60-day comment period started on April 6, leaving less than two weeks for them to provide their concerns in writing to the federal Agency.  Peggy Gamlin, who organized the meeting said, “For years this area has been redlined (a term used when banks, insurance companies and even supermarkets deny services directly or by raising prices) and now we are up against a Superfund designation that will only damage our efforts.” “At a minimum” she said, “could we at least extend the comment period?”

State Senator Greg Taylor was present and expressed frustration with the EPA for their lack of engaging the community in the process stating, “You’ve been studying this problem for years and no one has ever contacted my office to discuss this serious issue.  To my knowledge this is the first public meeting that has been held to discuss the merits of this Superfund designation and we are told comments are required in a little more than a week.”

Stephen Henshaw, president of EnviroForensics also spoke at the meeting. Henshaw agrees that listing this area as a Superfund site could give it a stigma that could adversely effect the growth plans for the area, but thinks EPA could assist the community by issuing information demands to the businesses that IDEM has identified as potentially causing or contributing to the groundwater contamination.  For several years, IDEM has been compiling a list of former dry cleaners and launderers and has found over 167 former and current dry cleaners within the wellhead protection area of Riverside and White River municipal wells.

Henshaw argues that while the groundwater levels observed in the Riverside municipal well field are below the allowed drinking water levels, such levels pose a risk and attention needs to be given to identify and mitigate sources of contamination that are found to be contaminating or threatening the city’s drinking water supply.  While acknowledging that cleaning up contamination from old manufacturing sites, dry cleaners, and other businesses is extremely costly, he stated, “While it’s true that groundwater contamination may have been caused by accidental spills and releases of dry cleaning solvents, as well as solvents used to clean machine parts in past decades, businesses — even those now defunct — can use their old insurance policies, policies written 40 and 50 years ago, to fund the costs of investigation and remediation.” Henshaw also contends that more focus needs to be given to those sites already in IDEM’s cleanup programs citing an unnecessarily long and drawn out process between consultants and IDEM in getting sites remediated.  He said that EnviroForensics routinely finds old insurance policies to assist past and current business owners address their environmental liabilities stating, “Insurance policies don’t expire and can still be used to protect the policyholder facing regulatory enforcement even if the company that caused the contamination is out of business.”

For more information on the Riverside Groundwater Contamination site, contact Nuria Muñiz, NPL Coordinator, 312-886-4439, muniz.nuria@epa.gov.  The EPA during the 60-day comment period currently expires on June 6.

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.