Site Closure Strategies

Reducing the liabilities and costs of remediation by focusing on end results, continually reassessing project goals and controlling O&M expenses

• By David H. Simpson, Rusty B. Norris, PE, PLS, RSM
• Sep 01, 2004

U.S. industry faces the daunting task of managing investigations and clean-ups at thousands of contaminated properties. In staying abreast of new technology and ever-evolving regulatory programs, companies must address many challenges involving regulations, technologies, and costs. For each project, it is important to:

• Focus on the ultimate goal of regulatory closure, using an integrated site closure (ISC) approach;
• Periodically revisit and re-assess the design basis for the remediation strategy along with the approach, with a remediation system evaluation (RSE); and
• Carefully manage and control operations and maintenance (O&M) costs and performance.

Integrated Site Closures
Integrated site closure (ISC) refers to the seamless integration and delivery (either by self-performing or by subcontracting) of the chain of remediation activities including agency negotiation, site investigation, risk assessment, feasibility evaluation, design engineering, remediation, and O&M monitoring needed to achieve "regulatory closure" at contaminated properties. In essence, ISC starts with the end in mind.

Recognizing the interrelationships of the steps of the remediation process, an ISC approach combines assessment and remediation in a comprehensive site closure strategy to develop a more responsive, accurate, and cost-effective solution than can be achieved by a traditional remediation approach. ISC projects often involve a multi-disciplinary team of scientists, engineers, and regulatory experts working on agency negotiations, site investigation, risk assessment, feasibility evaluation, design engineering, remediation, and the O&M of hazardous waste sites, all in order to move the project steadily toward the goal of efficient site closure.

Saving Money While Turning a Brownfield Green
The ISC approach saved The Fort James Company time and money during the closure of a former paper-manufacturing site that had operated as a mill for over 100 years in a historic area of wetlands and floodplain in New Jersey. Over many years of operation, the buildings, nearby soils, and riverbanks were contaminated with polychlorinated biphenyls (PCBs) and, to a lesser degree, heavy metals. ENSR worked closely with the client, regulatory agencies, and the N.J. Historical Society from the initial assessments through the final construction, successful closure, and disposition of the property to the N.J. Green Acres Program.

According to a Fort James project manager, "There were many key steps in this project that resulted in cost avoidances/reductions...and the turn-key approach ENSR provided to us for the project...kept the cost down and the production up on the site." In a key cost-saving step, the consulting team conducted baseline ecological and human health risk assessments for alternative cleanup criteria documentation, and used these findings to successfully negotiate site-specific alternate clean-up standards with the New Jersey Department of Environmental Protection. The consulting team also worked closely with the N.J. Historical Society to preserve the building footprint and foundations; this kept the project schedule on track and resulted in additional savings.

The bottom line is that the ISC approach saved The Fort James Company $165,000 in remediation costs, and kept the project schedule on track.

Remediation Systems Evaluations
A key component of ISC is a remediation systems evaluation (RSE). An RSE is a proven strategy to help businesses save significant costs and time at remediation sites. In addition, RSEs help companies improve the effectiveness of their cleanup plan, reduce their liabilities, and achieve site closures. These reviews are crucial, because even a five-year-old remediation program may no longer be the most cost-effective strategy, due to changes in operating and monitoring requirements, site conditions, regulatory controls, or technological advances that affect even well-designed systems.

There are several common problems that RSEs reveal, such as unclear remediation objectives. For example, it is important to establish whether the goal is hydraulic containment, receptor protection, or remediation. Conflicting criteria for cost decision-making is another common stumbling block; frequently, the need to achieve containment (to minimize costs) conflicts with the need for remediation (that minimizes time). Performance criteria -- such as concentration, flow rate, mass removal, and exposure -- can also clash. In some cases, performance and cost decision-making do not align, such as when costly upgrades are made to poorly performing systems. And often, it is revealed that expensive monitoring data is collected, but never used.

The Remediation System Evaluation Approach
ENSR has developed an eight-step RSE process that helps reveal these types of problems and create a comprehensive approach for the future management of a site. Note that RSEs are not intended as detailed engineering specification projects nor are they formal demonstrations of technical feasibility.

• Step 1: Identify Systems Objectives. An important first step for any RSE is to establish the objectives of the remediation program, such as containment, cleanup, or receptor protection. In each case, the ultimate goal of the RSE is to assist the owner in meeting the objectives of the remediation program while seeking to lower costs, shorten project timelines, improve effectiveness, reduce liabilities, and achieve site closure.

• Step 2: Evaluate Current Operating Criteria. Engineers review ongoing compliance strategies and long-term closure strategies. Financial information is also scrutinized to determine the percentage of annual costs allocated for O&M engineering, electricity, sampling reporting, project management, etc.

• Step 3: Compile Data. Among the copious documentation to amass are internal annual project review reports; the last three years' worth of regulatory correspondence; controlling remediation documents; copies of permits Resource Conservation Recovery Act (RCRA), National Pollutant Discharge Elimination System (NPDES), and air; and system O&M manuals. During the review, we also gather monthly discharge reports; record drawings and P&ID for remediation systems; financial summaries; boring logs and well construction details; flow rate records; chronology of down times, significant upgrades, and repairs; summaries of general obligations for sites; and regulatory contacts.

• Steps 4-8: Evaluation. The last four steps assess alternative criteria, present performance and costs, cost reduction, and options for the current system, such as low-cost enhancements and high-cost enhancements.

A Manufacturing Facility Reaps Big Savings
ENSR performed an RSE in 1998 for a former manufacturing facility in North Carolina with chlorinated volatile organic compounds (VOCs) in the soil and groundwater. The company had implemented a groundwater pump-and-treat system, using soil vapor extraction technology.

We found that the company could obtain cost savings in several areas. O&M labor costs were reduced by utilizing one senior-level plant operator and pushing down more responsibility to the operator, while moving reporting and database roles to off-site administrative staff. We also recommended RCRA permit modifications. The existing RCRA permit required extensive groundwater sampling. Changing the program allowed a shift from semiannual to annual sampling and reporting, and the removal of wells and specific compounds from the reporting program. We reduced NPDES sampling costs by modifying analytical requirements and removing specific compounds. And we reduced operating costs by saving electricity, modifying the groundwater treatment system (GWTS), and negotiating a change in waste disposal classification.

The environmental consultant improved the operation of the groundwater extraction-hydraulic containment system, resulting in savings of almost $300,000 in the first year. In subsequent years (1999 through 2002), the company has saved an average of $100,000 or more.

Outsourcing Site Operations and Maintenance
RSEs can lead to a recommendation to outsource the O&M of a site. Outsourcing the O&M of a remediation program to a qualified environmental services firm (the O&M provider) enables a company to closely manage cost and performance, while focusing their energy on its core business.

A long-term fixed-price and fixed-performance contract requires the O&M provider to have a monetary stake in effective maintenance and system performance. Extended contract terms (e.g., five to 10 years long) and/or a portfolio of multiple sites affords the O&M provider the opportunity to leverage better pricing from vendors and to provide the owner with superior rates and margins based on reduction in indirect labor, lower work procurement costs, and lower contract administration costs. This is leverage neither party can wield during the proposal phase of a traditional O&M contract.

The O&M provider thus becomes a partner. Given an incentive to maintain and operate equipment in the most cost effective manner possible, the O&M provider must carefully manage costs -- not just pass them through to the owner. For example, the scope of work and base equipment repair and replacement costs are established and agreed upon during contract negotiations. The O&M provider must balance risk and reward when establishing pricing, and the extended contract terms allow the provider a mechanism to reduce risks, which correspondingly reduces cost over the long term for the owner. In addition, an O&M contract achieves project efficiencies by centralizing communications and standardizing project management measures and practices-- all of which translate into lower owner costs.

A Fixed-Price O&M Contract with a Multi-Site Client
In January 2000, ENSR implemented a five-year O&M contract with a major industrial manufacturing company to manage all aspects of the ongoing remediation at four legacy sites in the Carolinas. For a fixed monthly fee, the consultant provides regular O&M labor, sampling, and reporting by state licensed treatment plant operators. The consultant also provides utilities, supplies and subcontracted maintenance and repair, along with regular replacement of equipment as needed to maintain effective operation of the treatment systems. Additionally, the consultant provides required performance monitoring and reporting. Benefits to the client include stable predictable cash flow, reduced administrative and contract management time, a centralized project manager, and contacts for all aspects of the O&M program, with lower overall project costs.

Bottom Line Results
Outsourcing O&M, RSEs, and an overall ISC approach are remediation strategies proven to eliminate much of the uncertainty and risks associated with contaminated properties, as well as facilitate regulatory closure. By employing these strategies, managers are able to free up cash flow and maintain regulatory compliance, while reducing both financial liabilities and remediation reserves.

Integrated Site Closures
This approach typically includes the following activities:

• Peer reviews
• Site investigations
• Risk assessments
• Removal actions
• Treatability and pilot studies
• Feasibility studies
• Development of agency negotiations/regulatory strategies
• Remediation designs
• Remediation system implementation/construction management
• Remediation system operation and maintenance (O&M)
• Remediation system evaluations (RSEs)
• Long-term monitoring
• Fenceline ambient monitoring
• Community relations/public presentations
• Litigation support/expert testimony

This article originally appeared in the 09/01/2004 issue of Environmental Protection.