client experienced an accidental release of fire suppression foam containing C6
PFAS compounds in one of their facilities and was paying exorbitant fees to
emergency response clean-up crews. Aqueous film forming foam (AFFF) was
released into floor drains that normally led to the sanitary sewer. In this
emergency event, diversion valves were actuated to protect the sewer system and
divert the impacted water to an exterior emergency retention basin. Unfortunately,
the event happened on a windy day, and as a result the foam was subsequently spread
to surrounding areas, including other storm drains that ultimately emptied to a
nearby stream. Emergency response included manpower and multiple vacuum trucks
to remove the foam from the sewers and stream nearly a ½ mile away. Recovered water
was transferred back to the facility and staged in numerous temporary 20,000-gallon
storage tanks. After a few weeks, the response footprint was reduced to just
the localized sewer system. However, the
client was obligated to continue with recovery efforts on a 24 / 7 basis at
costs in excess of $18,000 per day until a permanent solution to the problem was
BSTI was enlisted into this project by one of our partner
companies to see if we could design and implement an automated solution to the
costly manual water collection program. Within
less than 24-hours of visiting the site, we responded with a solution for an
automated recovery system designed to remove the expensive vacuum trucks
offsite as soon as possible. Because of our remediation experience and can-do
attitude, we were able to procure, fabricate and deploy recovery pumps and
control systems within days. Measures
were also implemented to reduce/prevent storm water from being introduced into
the affected sewer network which lessened the volume of impacted water being
containerized. Within less than one week of system deployment, the client was able
to remove the manual crews and vacuum trucks from the site. The immediate
benefit to the customer is that they now have a reliable automated recovery
system in place for the same cost of just two days of vacuum trucks.
BSTI was subsequently asked to design and operate a
treatment system for the containerized PFAS-containing water. That, however, will be the subject of another
installment of Solving Complex Environmental Problems.
If you have questions about this subject and wish to contact
us, contact Tony Finding at firstname.lastname@example.org.
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.
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.
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 email@example.com. Visit www.bstiweb.com for more information on our capabilities.
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.
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.
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
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.
We have in our pockets a device that has instant access to nearly every piece of information known to mankind. So why is it so hard for me to cut through the clutter and get a somewhat applicable answer to a basic question? Geez, I just wanted advice on “growing tomatoes” (29,800,000 search engine results).
So recently I found myself proclaiming that the information age should be renamed the “too much information” age when my friend Mark chimed in. He reminded me that “the person who asks the best question always gets the best answer.” His simple statement hit me like a tidal wave. My problem was me! When I find myself struggling to find a good enough answer, I most certainly have not asked a good enough question. “What light conditions are optimal for growing indeterminate tomatoes indoors in the winter?” (230,000 results and the first five are really good ones!)
This simple concept has fundamentally changed the way I think. Consultants tend to boast that they have the right answers, but a truly valuable consultant should also have the right questions. This reminds me of something that I used to do for clients called “Defining the Bullseye,” but I’ll save that for another day.
Tony Finding, BSTI’s VP and Chief Operating Officer authored the article “The Twelve Best Practices to Avoid Pipeline Construction Shutdowns and Fines” which was featured in the NASTT publication Trenchless for Gas Infrastructure. In this article, Tony identifies some of the more common causes of environmental, regulatory and permit violations that can result in work… Read More
BSTI’s Chief Science Officer Tripp Fischer will be a panel member during the upcoming STEM Conference hosted by West Chester University on April 7-8, 2021. Mr. Fischer and Dr. Jennifer McCafferty (VP of External Manufacturing Operations at Merck) will be discussing: Mentoring an “Only” When You’re Not an Only during Breakout Session 2 on April… Read More