We have previously discussed spill response activities for Sites where an active release occurred and identified key factors in addressing spills. For historical release Sites that were not addressed or Sites which have undergone insufficient remediation of contaminated media (soil, surface water, groundwater), it is important to formulate a complete Site remedial strategy to establish what the end goal will be for site clean-up. Utilizing regulatory guidance, along with identified Site-specific characteristics, allows for flexibility in site clean-up approaches.
Consistent Strategy. It is very important to establish what the key drivers are for the Site-specific contaminants. Whether it is crude oil, condensate, refined product, produced water, or stored materials on Site — developing a sampling program to address the extent of affected media will allow for consistency in evaluating data and presenting information to the regulatory agency. It is equally important to develop consistent field screening methods and action levels to determine the extent of excavation or assessment. The goal is to determine what action levels will address Site concerns while balancing remediation costs to minimize the volume of contaminated media being taken off Site.
Site Conditions. Additional considerations in evaluating the remediation process are conditions at the Site, such as the areas accessible to complete controlled work. Can you pursue a permit and treat affected media on-Site to reduce disposal costs? Is it feasible to create Land-Use Restrictions and negotiate alternate clean-up levels with the regulatory agency? What are the closest waste disposal facilities and where are they located? The potential for on-Site remediation needs to be evaluated against loading, hauling, and disposal costs. At many Sites, it is easier to dig and haul out than it is to address affected media on-Site; however, there are cases where the long-term solution would be for on-Site treatment rather than a large trucking bill.
Communication. Lastly, communication is key. Know what your action levels and end goals are, communicate with regulatory officials, and know what scope your contractors are performing. There are a lot of aspects to manage during Site remediation and leaving affected media in place results in an unexpected future liability that you will have to address again.
When dealing with remediation projects, many factors must be considered to ensure a smooth operation. A project manager must understand site conditions to keep the project safe, efficient, and economical. Developing a consistent action-plan and field screening methods for the scope of the project is also key to meeting and maintaining cleanup objectives. And remember, frequent and thorough communication with regulatory officials, contractors, and other stakeholders is fundamental to a successful remediation project.
If you have any questions or comments, please contact Gary Tiedeman.