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 delays. Please click the link below to read the entire article.
was asked by the operator of a wastewater treatment plant to explore options that
would mitigate the diminishing capacity of an existing spray irrigation field. Over
time, the diminishing capacity of the spray irrigation field was creating
operational issues and exposing the operator to potential violations of their Water
Quality Management Permit.
spray field is an upland deciduous forest with an area covering approximately
12 acres. Infiltration testing carried out by BSTI along with the observance of
excess surface runoff indicated that hydraulic loading to the spray field had
exceeded its infiltration capacity. Further, a significant population of mature
trees within the spray fields died as a result of intolerance of spray field
conditions; thereby exacerbating the problem. Because the logistics to simply
transfer the excess wastewater to another location was problematic and cost
prohibitive, BSTI focused on helping the existing spray field become more
determined that establishing additional vegetation would increase the
evapotranspiration rate of the area and improve spray field hydrology. Several species of shrub willow were
identified and selected for further study due to their rapid growth, disease
resistance, high yield of leaves and adaptability to a wide range of soil and
in-field pilot study indicated that the tested shrub willow species were indeed
well suited for the water and soil chemistry conditions that exist in the spray
field, and when established have potential average transpiration rates of approximately
one inch per week, similar in magnitude to the permitted hydraulic loading rate
for the spray field (1 to 3.4 inches per week). BSTI also determined that the
survival of any future willow plantings would require the temporary installation
of a deer fence enclosure. The enclosure will ensure that the willows planted
in the spray field had time to grow to a size resistant to browsing, expected
in three to five years, at which time the fence can be removed if desired.
Based on testing conducted by BSTI, gypsum demand across used portions of the spray field varied from 9 to 140 pounds per 1,000 square feet. Given these variable conditions, BSTI conducted a single application of gypsum at 40 pounds per 1,000 square feet prior to planting. This moderate dosing, in line with typical agricultural practices, will improve calcium to sodium ratios, reduce the potential for negative impacts on vegetation from sodium while minimizing the potential for excessive leaching of metals from soil, and potentially improve soil infiltration rates by improving soil structure.
full-scale planting of 28,000 willow “stakes” was comprised of the four shrub
willow species that exhibited the greatest tolerance to spray field conditions
during the pilot study. The four shrub willow
species were intermixed throughout the planting zones to avoid monocultures
that are more susceptible to disease and pest predation. The target willow
planting density was achieved using 9 high density rows of varying lengths
(6,000 stems/acre), one willow stake per 7 square feet, with open corridors
around spray heads to provide clearance for spray operation and maintenance
access. When fully mature these willow species will reach heights ranging
between 18 to 25 feet with 2 to 3-inch calipers.
following the shrub willow planting, BSTI began monitoring willow growth and
the integrity of the deer fencing on a bimonthly basis. BSTI is also monitoring
spray field hydrology through three soil moisture monitoring stations to
establish a baseline of current conditions for comparison to conditions once
willows are fully established.
The high-density willow planting was completed in the spring of 2020 and has returned early positive results. BSTI’s solution to this complex environmental problem has allowed our client to continue to provide wastewater services without fear of permit violation or the high cost of engineered alternatives. Moreover, the once-decaying vegetation in the area will be augmented with a vibrant green landscape.
If you are in the construction or redevelopment business, you already know how frustrating and costly construction delays can be when unplanned environmental issues arise. The discovery of soils and/or materials impacted with regulated substances can pose a safety concern for workers, shut down tight schedules and throw budgets into chaos. We frequently get calls from construction managers to solve problems that could have been easily managed before all the construction equipment arrived. The purpose of this paper is to help our friends in the construction and redevelopment business anticipate and manage environmental issues as an understood part of the process instead of as a surprise.
Simple up-front planning and development of a cost effective soils management plan can alleviate this common pain point for project stakeholders. The project development team should consider performing valuable and often simple investigations regarding the type and extent of potential soil impacts that may be present. These investigations can provide information that can be favorable to the overall project. Instead of reacting mid-construction (during excavation and off-site disposal of soil), stakeholders may be able to take advantage of regulatory programs such as the PADEP’s Land Recycling Program (Act 2) or other Voluntary Cleanup Programs (VCPs) to potentially leave impacted soils on-site; especially where construction plans enable capping of impacted soils under paved areas. Cut and fill plans can in some cases incorporate impacted soils into the overall balance; allowing for reuse and/or preapproved load and go disposal of impacted soil.
Furthermore, advance knowledge of soils and material conditions can augment an existing soils management plan, reduce risk and enable a site contractor to plan the required Health & Safety (H&S) measures to protect workers and the public. Site contractors may also be required to obtain various OSHA training certificates for personnel including
equipment operators to work at these kinds of facilities.
Another item to consider is fill material. Most states including Pennsylvania have management policy programs to evaluate fill quality. A person or entity placing solid waste onto the ground is generally required to obtain a disposal permit from the PADEP. A person or entity is not required to obtain a permit under the Solid Waste Management Act (SWMA) if they can demonstrate that the material qualifies as clean fill in accordance with the municipal and residual waste regulations. In January 2020, a new Management of Fill Policy was released that provides the PADEP’s procedures for determining whether fill is “clean fill” or “regulated fill”.
Luckily, you don’t need to be an expert in environmental issues to avoid common soil management pitfalls. The experts at BSTI can help you with this planning process.
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.
uses a science-based approach to close a site with LNAPL, save our client money
and re-start a stalled real estate transaction.
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.
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.
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.
(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.
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:
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:
9-10) are loyal enthusiasts.
Passives (Neutral) (score
7-8) are satisfied, but unenthusiastic.
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.”
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