Groundwater Modeling and Site Monitoring
Michigan Utility Company
A confidential utility company retained Superior to complete and submit to the Michigan Department of Environmental Quality (MDEQ) a Final Assessment Report (FAR).
Superior performed a hydrogeological investigation to collect the data to complete the FAR. The hydrogeological investigation provided site-specific data that was used to predict the fate and transport of an existing petroleum groundwater plume. During the course of the investigation, two additional petroleum hydrocarbon plumes were identified, creating a potential problem for some types of traditional remediation approaches due to commingling of the plumes.
Superior used computer modeling to demonstrate that the client’s petroleum groundwater plume was migrating at a low velocity and degrading at a significant rate. The computer modeling also calculated a time horizon for natural biodegradation to completely remediate the plume. The FAR, which outlined natural biodegradation as the preferred remedial alternative, was submitted to the MDEQ. The modeling provided the rationale for the MDEQ to approve the FAR and for the site to enter monitoring as corrective action.
Asbestos Sampling, Air Monitoring, and Quality Control of Abatement Activities
Confidential Communications Company
A confidential communications company contracted Superior to sample suspected asbestos containing building materials (ACBMs) in seven facilities located in the upper and lower peninsulas of Michigan. At locations identified as having asbestos, Superior provided air monitoring and abatement oversight to ensure quality control of the abatement contractor. Superior provided the client’s on-site staff with information concerning the abatement process and potential hazards. Superior’s close working relationship with the client and their on-site staff enabled us to meet the client’s criteria and schedule and to alleviate staff concerns.
Environmental Assessments and Response Actions
Midwest Manufacturing Facility
Superior was contracted to perform Phase I and Phase II Environmental Site Assessments (ESAs) at a manufacturing facility that has been doing business in the Midwest for more than 100 years. The business provided precision grinding and sharpening services primarily to the timber and paper manufacturing industries. As part of the ESAs, Superior conducted an asbestos inspection and regulatory compliance audits. Superior also supervised the closure of a regulated underground storage tank (UST) system in accordance with Michigan’s Leaking Underground Storage Tank (LUST) Act. Clean closure of the UST system was achieved. In addition, Superior conducted a hydrogeologic investigation at the site.
This hydrogeologic investigation involved a wide variety of investigative activities, including: interior and exterior soil borings; installation of monitoring wells using a truck-mounted drilling rig equipped with continuous flight hollow-stem augers; on-site analysis of soil and groundwater samples using portable gas chromatography equipment (Field GC); vertical aquifer profiling to a depth of 100 feet; and surveying and sampling of monitoring wells.
The horizontal and vertical distribution of volatile organic compounds (VOCs) in soils and groundwater outside the plant was delineated by the drilling and sampling program. Impacted soils were remediated by excavation and disposed in a licensed Class II landfill. Asbestos containing building materials (ACBMs) were removed and properly disposed of by a licensed abatement contractor. Polychlorinated biphenyls (PCBs) identified in transformer oils were properly handled by a licensed contractor.
Superior worked with state regulators and the client to assess the full extent of VOCs, polynuclear aromatic hydrocarbons (PAHs), and PCBs identified in soil samples adjacent to selected migration pathways inside the plant in order to prepare a formal closure request. As a result of Superior’s detailed hydrogeologic investigation, VOCs identified in the groundwater were traced to an up gradient, off-site source – a LUST system at an abandoned gasoline station located across the street from the client’s facility. This source identification resulted in a considerable savings to the client.
Site Assessments for Potential Pesticide and Herbicide Contamination
Major Pesticide, Seed, and Pharmaceutical Manufacturer
Superior was contracted by a major pesticide, seed, and pharmaceutical manufacturer to perform a number of facility assessments in Washington, Minnesota, Wisconsin, Iowa, and in Ontario, Canada specifically looking at the distribution of chlorinated pesticides and herbicides in soils, groundwater, surface water, and sediments.
The scope of work generally included activities designed to evaluate the presence of volatile organic compounds (VOCs), herbicides, and pesticides in soils, groundwater, sediments, and surface water. As part of the initial site characterization study, one surface water sample was typically collected from each stream, retention basin, or discharge area. An activated-messenger sampler was used for surface water sampling. The samples were arbitrarily collected downstream from locations that appeared to potential sources of contamination and near the inflow and the outflow of the potential source areas. Composite water samples from the top, middle, and bottom zones of the water column were typically collected. The samples were analyzed for pesticides and herbicides. Samples collected from the settling pond were also analyzed for VOCs.
One sediment grab sample was collected from each discharge point and each settling pond using an Ekman Dredge Sampler. When performing an initial site characterization study, one sediment grab sample was commonly collected near the center of each retention basin (settling pond) at the site. The grab sample was collected from a biased sampling location downstream from the potential source of contamination at a depth of 0.0 to 0.5 feet below the sediment surface sampling interval. Soil and groundwater samples were collected with a hand-bucket auger, and a temporary monitoring well was installed.
Environmental Assessment Activities
Local Municipality and Developer
Superior was contracted by a local municipality to performed real estate environmental due diligence services and conduct brownfield redevelopment activities associated with the redevelopment of an industrial property in West Michigan. The objective of the project was to expeditiously perform all required due diligence activities to facilitate the purchase of the industrial property by a confidential development company and to provide brownfield environmental consulting services as part of the redevelopment of the property into condominiums and a restaurant.
Superior performed a Phase I Environmental Site Assessment (ESA) on an approximately 1.26 acre industrial property. The Phase I ESA indicated several current and historical environmental conditions on the property. Superior conducted a Phase II ESA on the property to evaluate recognized environmental conditions (RECs) that were identified during the Phase I ESA. The Phase II ESA included the collection and analysis of soil and groundwater sampleson the property, which identified the presence of contaminants at the property. After determining that the property was defined as a ”Facility”, Superior prepared a Baseline Environmental Assessment (BEA) and Section 7a Compliance Analysis (CA) in compliance with the Michigan Department of Environmental Quality’s (MDEQ’s) Instructions for Preparing and Disclosing BEAs and Section 7a CAs, and disclosed the BEA to the MDEQ on behalf of the developer.
Superior also conducted an asbestos inspection to identify, locate, sample, and quantify friable and non-friable building materials suspected of containing asbestos. The asbestos inspection was conducted by one of Superior’s state-accredited asbestos building inspectors in accordance with Occupational Safety and Health Administration (OSHA) regulations, Environmental Protection Agency (EPA) 40 CFR Part 61; Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP) Revision: Final Rule, dated November 20, 1990, and Retailer’s Specifications.
In addition, Superior assisted the local municipality with the preparation and submittal of a work plan in accordance with the Brownfield Redevelopment Financing Act, 1996 PA 381, as amended (Act 381) Work Plan to Conduct Eligible DEQ Response Activities to the MDEQ. Included in the response activities the MDEQ approved was excavation oversight of contaminated soil and treatment of the extracted groundwater during excavation and dewatering activities. As part of the groundwater treatment operations, Superior assisted with obtaining a National Pollutant Discharge Elimination System (NPDES) permit and operating a groundwater treatment system that included the use of two 10,000-pound granular activated carbon (GAC) and four 1,500-pound GAC vessels plumbed in series during the dewatering activities. After dewatering, Superior supervised the excavation activities.
Remedial Investigation and Remedial Action Plan
Industrial Service Supplier
Superior was retained by an industrial service supplier to conduct investigation and remediation activities to address contamination from historic releases on their site. The activities were a condition of a Consent Judgment entered into between the client and the State of Michigan.
Superior conducted research to evaluate the current and past uses of the site. Prior to the client’s purchase and occupancy, the site was historically used to store herbicides and pesticides. A fire resulted in a release of chemicals to the subject property. Extensive remediation was conducted to address this release, including soil excavation and removal of impacted surface water. Research indicated that the excavation area was backfilled using foundry sands. Additionally, a fire sprinkler system malfunctioned that resulted in the discharge of chromium impacted water to several areas of the site.
Superior conducted a detailed analysis of the client’s chemical usage and conducted additional research to evaluate contaminants associated with the foundry fill. It was the client’s position that a number of the analytical parameters initially required by the Michigan Department of Environmental Quality (MDEQ) were directly related to historic use of the site and not the client’s activities. The MDEQ originally required samples to be analyzed for volatile organic compounds (VOCs), organochlorine pesticides, semi-volatile organic compounds (SVOCs), organophosphates, chlorinated herbicides, and “Michigan 10” metals. Superior presented its research findings to the MDEQ. The MDEQ agreed that the client’s remedial actions were limited to only those contaminants associated with their operations: VOCs, chromium, and lead.
Superior conducted investigation activities to delineate the extent of soil and groundwater contamination at the site. The investigation included the installation of monitoring wells and Geoprobe® soil borings. The investigation determined that contamination was limited to property owned by our client.
Superior prepared a Remedial Action Plan (RAP)/Closure Report on behalf of the client. The RAP was prepared as a Limited Industrial RAP. The RAP included a Restrictive Covenant that limited land and resource use restrictions to prevent unacceptable exposure to remaining contamination. Superior, with attorney representation, also prepared a Legally Enforceable Agreement and Affidavit to Support Un-remediation Releases as part of the RAP.
Superior prepared a Due Care Plan on behalf of the client. The purpose of the Due Care Plan was to undertake measures necessary to prevent exacerbation of existing contamination, mitigate unacceptable exposure to hazardous substances, and take reasonable precautions against reasonably foreseeable acts by third parties. The Due Care Plan was also a requirement of the RAP. The Due Care Plan included a checklist to evaluate compliance with provisions of the RAP and Restrictive Covenant. This checklist was to be submitted to the MDEQ annually to provide documentation of compliance with Due Care and the RAP. The Due Care Plan also contained a notice that will be provided to third party contractors that may perform work on the property.
The project was completed on time and within budget. Superior’s activities resulted in an MDEQ approved Limited RAP without conducting remediation activities.
North American Pipeline Company
A major North American pipeline company (The Company) contacted Superior within 4 hours of the discovery of a crude oil release. The release originated from a break in a 33-inch diameter buried pipeline that transports crude oil from the Chicago area northeast through Michigan and into Sarnia, Ontario. Superior was one of the first calls placed by The Company for assistance with environmental monitoring and operations support. The release originated in a wetland area and flowed overland until it reached a creek where it then flowed to the confluence of the creek and a major southwest Michigan river to an inland lake and continued flowing west toward Lake Michigan, extending approximately 38 miles from the release point. Superior mobilized staff, vehicles, equipment, and a mobile laboratory to provide environmental monitoring of the surface water, sediments, potable wells, and wildlife between the release area south of Marshall, Michigan and westward to Lake Michigan.
Superior set up permanent sample collection locations where surface water and sediment samples were collected daily. Initially, Superior teams collected surface water and sediment samples between the release point and the inland lake. Additional Superior teams collected samples from the inland lake to Lake Michigan at 5-mile intervals. Superior also provided teams to collect samples from potable wells when the residential well owner in proximity to the creek or river contacted The Company’s Response Call Center. Additionally, a continuous strike force was staffed by Superior for rapid-response inspection and sample collection services for residential or commercial properties that were affected or were suspected of being affected by the spill.
As the spilled crude oil and water were removed from the river, Superior provided staff on a 24-hour basis to oversee the entrance and exit of a temporary tank farm, which consisted of over 90 fractionation tanks. At the tank farm, recovered oil and water were stored until the fluid could be classified, recycled, treated, discharged, or transported from the area. Superior staff logged each of the shipments and collected samples of oil or water in the treatment area on an as-needed basis.
Superior staff assisted in designing and building the Wildlife Welfare and Rehabilitation Center. Superior staff also was tasked with deploying deterrent mechanisms to attempt to inhibit wildlife from coming in contact with the crude oil. Air cannons, fences, and noise makers were used as deterrents. As local residents reported the locations of affected wildlife to The Company Response Call Center, Superior staff responded in an effort to locate the animals or birds, capture them, and transport them to the Wildlife Welfare and Rehabilitation Center for cleaning, observation, rehabilitation, and eventual release away from oil impacts.
Superior also provided senior staff to aid in writing Health and Safety Plans, Sampling and Analysis Plans, Oil Capture and Containment Plans, Waste Disposal Plans, Backfill Plans, and a variety of standard operating procedures that guided the response activities and were incorporated into larger plans that were submitted to the United States Environmental Protection Agency (USEPA), Region V on-scene coordinator and other regulatory and non-regulatory agencies.
Work on the effects of the release is still ongoing and Superior continues to provide support services to The Company.
Phase I and Phase II Environmental Site Assessments, Baseline Environmental Audit, and Asbestos Survey
Real Estate Developer
Superior was retained by a real estate developer to complete Phase I and Phase II Environmental Site Assessments (ESAs), a Baseline Environmental Assessment (BEA), and an Asbestos Survey on a parcel of property in central Michigan. The Phase I ESA was completed in accordance with American Society for Testing Materials (ASTM) standards and the Michigan State Housing Development Authority (MSHDA) requirements. Recognized Environmental Concerns (RECs) were identified on the property warranting further investigation. As part of the Phase II ESA, Superior personnel completed soil borings, both in and around existing site structures, to assess and characterize potential site contaminants. Soil was continuously logged in each borehole by an experienced field geologist. All samples were field-screened using a photoionization detector (PID). Select soil and groundwater samples were collected in accordance with method requirements or State of Michigan sampling criteria. Appropriate chain-of-custody documentation was maintained to ensure sample integrity.
Soil samples were subsequently transported and analyzed by an independent laboratory for volatile organic compounds (VOCs) and lead. Superior personnel evaluated the laboratory analytical results, compiled the existing data into tables for ease of reference, and provided the information in the form of a Category “N” BEA report for submission to the Michigan Department of Environmental Quality (MDEQ).
A comprehensive asbestos building inspection was completed on the site. The inspection included the entire interior spaces of the site buildings. Random bulk samples, representative of the suspect asbestos containing building material (ACBM) of each homogeneous area, were collected according to a modification of the guidelines published as Environmental Protection Agency Final Rule: Title II of the Toxic Substances Control Act (TSCA), 15 USC, Sections 2641 through 2654 and in compliance with 40 CFR, Part 763.
Superior contracted with an accredited laboratory for asbestos bulk analysis using polarized light microscopy (PLM) with dispersion staining. Following receipt ofthe sample results, Superior prepared a summary report that described the visual observations recorded during the site inspections and contained appendices with photographs of each homogeneous area, sketches of each building with labeled homogeneous areas and sampling locations, and the analytical results from each sample.
Superior completed the asbestos and lead based paint abatement and confirmation sampling activities on behalf of the client. The objective was to remove all ACBMs and lead based paint identified in the building and to provide confirmation air and wipe sampling to document the abatement results. Superior was on-site for the duration of abatement activities to insure the bid specifications were adhered to and to provide lead clearance sampling and analysis when the project was completed.
Analytical results of the post abatement lead samples indicated that the building was below the acceptable criteria. Analysis of the asbestos air clearance testing indicated that the total fiber concentrations inside the work areas were below the Environmental Protection Agency (EPA) recommended clearance concentration of 0.010 f/cc. Based on the information collected and the final site walk, the building was appropriately abated and made suitable for renovation activities to begin.
The developer completed the renovations and the building is currently a senior housing facility.
LUST Site Closure
Michigan Automobile Dealership
Superior Environmental Corp (Superior), on behalf of a confidential Bay County, Michigan automobile dealership, was hired to investigate and close a used oil underground storage tank (UST) release at the car dealership, originally reported in 1997.
The following remedial actions were performed:
- On September 29, 1997, two 1,000 gallon steel UST systems were removed from the ground.
- On December 2 and 3, 1998, approximately 394 cubic yards of impacted soil was excavated from the UST basins.
However, after the excavation, the site still contained soil and groundwater contamination, and used oil (LNAPL) was present in the soil and at several groundwater monitoring well locations. At the time (1998), the site could not be closed under existing Michigan Department of Environmental Quality (MDEQ) guidelines as the LNAPL impacts extended under the site building and there appeared to be few economical options for cleaning up and closing the site. To complicate things further, a wetland exists downgradient of the release, and multiple easements are present throughout the property. The project seemed to be at a standstill.
However, in 2014, the site was re-evaluated in light of the 2012 Amendments to Part 213 of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (NREPA) and the relatively new (2013 and 2014) guidance documents from the MDEQ. The new guidance documents now allow sites with existing contamination and LNAPL that were not suitable for closure previously to pursue closure through a risk based corrective action (RBCA) process.
In 2014, after completing the delineation of soil, groundwater, and soil gas impacts, estimating the extent of mobile and residual LNAPL, and completing an exposure pathway evaluation using the RBCA process, a Final Assessment Report (FAR) was submitted to the DEQ to document the investigation and remediation phase. Based on the strategy presented in the FAR, on April 17, 2015, a Closure Report was submitted to the DEQ that would protect current and potential future site receptors, while allowing contamination, including the used oil (mobile LNAPL), to remain in the ground. The closure strategy was economically acceptable to the client and it would allow the car dealership to continue operating without interruption. The closure report utilized a Declaration of Restrictive Covenants filed with the county registry of deeds as a method of ensuring that site users would not come into contact with the contamination. The Restricted Covenant had the following restrictions to selected contaminated sections of the property:
- The site is restricted to non-residential use.
- The existing asphalt/concrete ground cover had to remain in place (or be replaced with something of equal protective value) to limit direct contact to the soil and LNAPL, as well as to prevent rainwater from infiltrating through the contaminated soil.
- New buildings are restricted unless they have additional vapor intrusion investigations or presumptive mitigation.
- Groundwater use is restricted (the area is on municipal water supply).
- The reuse of contaminated soil is restricted.
On May 29, 2015, Superior received a letter from the DEQ of their intent to audit the Closure Report. On June 5, 2015, Superior received a letter from the DEQ notifying that the Closure Report had been approved. The client was elated to have the environmental liability for the release removed and to have the release removed from the MDEQ LUST list, which was holding up a property transaction.
In summary, this project is a good example of newer closure options available under Parts 201 and 213 in Michigan. Sites that have existing contamination, including LNAPL, that were not suitable for closure previously may be suitable now. The additional closure processes are in place, all the necessary guidance documents have been issued, and the MDEQ is eager to work with owners and consultants to close sites.