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GEC Newsletter—Winter 2004

We, like many people and organizations, take time out during the holidays to reflect on the preceding year. For GEC 2004 was marked by many accomplishments for which we are very proud. Individuals within our organization grew professionally and personally, many becoming certified or licensed in their particular fields. As a company we completed numerous interesting, challenging and fulfilling projects, five of which are described below. In addition, we are proud of our continued support of local charities including the Pan Mass Challenge and the Dana Farber Institute. But most of all we are grateful for another year working with and for terrific clients, contractors and other business associates. Happy holidays and best wishes for 2005 and beyond.


In this Issue...

 

Wetland Delineation on MCP Disposal Site

Hazardous waste is not only found on developed properties. Often releases of oil or hazardous materials (OHM) occur in and around wetland resource areas, including bordering vegetated wetlands (BVW), floodplains, riverfront areas, and isolated land subject to flooding. The appropriate degree of response action is closely linked to the level of risk posed by the OHM on both human health and the environment. Knowing the precise location of wetland resources relative to OHM on a disposal site is paramount to designing the appropriate remedial action.

While conducting a Phase II Comprehensive Site Assessment, GEC evaluated the location of a previously established BVW line and the 100-year floodplain elevation. The entire area was impacted by a historic release of OHM. Upon a closure inspection of the size and location of the wetland, GEC determined that nearly one half of the area was in fact upland. In addition, the recorded floodplain elevation was nearly seven feet higher than the actual floodplain. A re-delineation of the resource area boundaries significantly reduced the cleanup activities because the ecological risk was significantly lower. Since the majority of the sensitive receptors reside within the wetland, the overall site risk was reduced with the reduction of the wetland area. Once the reclassification of the 100-year floodplain is completed, it will also result in reduced flooding insurance costs.

Sanitary System Upgrade

GEC’s engineers and wastewater specialists redesigned a less costly alternative to proposed wastewater treatment upgrade of the sanitary wastewater treatment system at a private school in Scituate. GEC performed sewage disposal system regulatory review, design, inspections, permitting, town and state licensing authority presentations when the original system was under review for possible expansion opportunities. GEC also developed a system Operations & Maintenance (O&M) plan and is currently operating the 30-year old 2,250-gallon per day (gpd) wastewater treatment system. The revised system contains a septic tank, an overflow tank, two 100gallon per minute (gpm) pumps with a 35-foot Total Dynamic Head (TDH), and valve chamber, two 4-inch diameter force mains, two splash/distribution boxes and six leaching pits. GEC’s inspection determined that the valves were corroded, the pumps were oversized and operating inefficiently, electrical feed and control and alarm panel was inadequate, and the original splash/distribution boxes were ineffective in reducing erosion at the bottom of the pits.

Because the system is located in a Zone II watershed regulators had required denitrification and potentially costly modifications. GEC evaluated proposed changes and recommended and obtained approval to utilize the existing design, requiring only normal less costly maintenance replacement. GEC replaced electrical and mechanical components, some of which include monitoring alarms telephonically connected to computer recording software that can e reviewed remotely. Also, GEC wrote and implemented an O&M Plan to conduct maintenance, inspections and tests at regular intervals. The O&M plan documents compliance with manufacturer’s recommendations of valves, pumps, piping and other electrical, mechanical and structural components. Furthermore, the O&M Manual provides for a checklist of maintenance items and Town requirements for yearly certification.

GEC working together with the client, lawyers, testing laboratories, town officials, and contractors brought to bear years of engineering, regulatory and environmental science experience to render realistic, practical and forward thinking solutions for the continued operations of a growing and essential community school.

Complex Risk Characterization

GEC recently completed a Method 3 Risk Characterization for a Massachusetts manufacturing facility. This risk characterization was particularly complex due to the number of exposure pathways for locations away from the facility.

At this facility, a release of tetrachloroethene (PCE) impacted the underlying bedrock aquifer. A plume of PCE and its degradation products migrated away from the facility, and extends into a Zone II for a municipal water supply, located more than 2,000 feet from the facility.

Besides impacting the Zone II, the plume of groundwater contamination was also intercepted by several private irrigation wells, including one used to fill a swimming pool and a private drinking water well. Contaminated groundwater also discharged to a wetland and stream, and seeped into the basement of a residence during times of high water table. Vapors emanating from the groundwater plume have intruded into the indoor air of the facility and a nearby residence.

For indoor air, drinking water, swimming pool water, irrigation water and surface water, GEC used directly measured contaminant levels to calculate exposure point concentrations. However, for levels of vapor in outdoor air, models were used to estimate exposure point concentrations at the wetland, above the swimming pool, during irrigation events, and above a hypothetical future excavation trench. Receptors included indoor and outdoor workers, construction workers, utility workers, visitors / trespassers and residents.

Significant risk of harm to human health was identified for several exposure scenarios, including future exposure to private and public drinking water, and current and future inhalation of indoor air at the facility and a nearby residence. Massachusetts Maximum Contaminant Levels, which are intended for protection of drinking water supplies, were exceeded at an irrigation well located within the Zone II, a private drinking water supply well, and several irrigation wells within 500 feet of the private drinking water supply well. The results of the Method 3 Risk Characterization were used to identify these areas as requiring further response actions.

Crackdown on Hazmat Shipments

One of GEC's clients recently experienced multiple in-flight emergency incidents while shipping hazardous materials by air. The Federal Aviation Administration (FAA), working under the U.S. Department of Transportation (DOT), and following recent aggressive enforcement measures to ensure safe hazardous materials shipments, immediately launched a comprehensive investigation.

GEC quickly reviewed the client’s DOT programs, including training and shipping practices for regulatory compliance. Several gaps were revealed, making the company vulnerable to potentially significant fines and penalties. GEC visited one of the main distribution centers prior to an impending audit and inspection by the regulatory authorities. This site represented several others like it, strategically located throughout the United States. GEC assisted its client by auditing their distribution center for DOT / FAA compliance, reporting results through attorney-client privilege, conducting required training for all of their nationwide distribution center managers, and resolving numerous specific shipping, hazard communication, and other environmental and safety questions.

Through the audit process, GEC identified and reported to their client several regulatory non-compliance issues, some requiring immediate corrective action. The client implemented many of the deficient program elements and audit recommendations at all of their distribution centers before they were inspected. The FAA inspections resulted in no fines or violations. GEC’s work improved site regulatory compliance and improved awareness of regulatory programs and company obligations. This example illustrates how GEC added value to their clients’ limited resources by working closely with Site personnel and taking a multimedia regulatory approach.

Facility Decommissioning

Property use can change and sometimes one needs to say “out with the old and in with the new.” But that is easier said than done at some facilities.
The Guber and Sherman facility, a metals recycling company, received and processed scrap metals for recycling. Processing of scrap metal occurred over many decades and involved sorting, cutting, bailing and preparing metal for resale to a recycler. In addition, because the Guber and Sherman building was constructed early in the 20th century, building materials included PCBs and asbestos. All of these elements, in addition to releases of oil and hazardous materials, lead to a complicated demolition project when owners slated the property for redevelopment.
GEC directed decommissioning activities and provided Licensed Site Professional (LSP) services to facilitate the redevelopment. GEC oversaw asbestos abatement, removal of PCB light ballasts, scraping and cleaning of a contaminated floor, removal of hazardous waste and removal of an abandoned underground storage tank. In addition, GEC conducted assessment and remedial activities to address releases of metals, polycyclic aromatic compounds and chlorinated solvents beneath the building. Because the building represented part of a larger development project, GEC worked with the developer to assure that all applicable regulatory elements would be in place and synchronized with the larger project.
GEC’s efforts on behalf of the property owner significantly reduced the costs associated with regulatory closure and resulted in a cost of closure that was roughly 50% below the estimate provided by the project developer.

[December 2004]