KEMRON is completing a CERCLA Remedial Investigation (RI) on an approximately 250 acre proposed National Priority List site for a major Steel Manufacturer. The RI is being conducted in accordance with CERCLA under an Administrative Order on Consent. KEMRON is responsible for development and implementation of the Field Sampling Plan, Quality Assurance Project Plan, RI Work Plan, and the RI Report.The project includes evaluation of all media, including the biota and sediment in an adjacent river, air, soils and groundwater for impacts from the site in accordance with CERCLA and NCP requirements. KEMRON regularly interacts with USEPA, the lead agency, and the state regulatory agency, and has negotiated project specific requirements with the regulators. As part of the RI process, KEMRON is managing the development of a sitewide Human Health Risk Assessment and Baseline Ecological Risk Assessment. All environmental data collected have been subject to thorough data review and data validation to ensure the RI provides a complete, accurate and fully defensible assessment of site conditions.
KEMRON is contracted with a retail petroleum company to provide environmental consulting and remediation services at 13 current and former retail petroleum sites throughout West Virginia and Ohio. These projects were transferred to KEMRON from a previous contractor due to insufficient remedial progress. Since transitioning these sites, KEMRON has obtained No Further Action (NFA) status for six sites, is awaiting regulatory concurrence for one additional site and determined the client has no continuing liability for two other sites. KEMRON personnel have conducted site investigations, corrective measures, remedial pilot testing, operation and maintenance of remediation systems, light non-aqueous phase liquid (LNAPL) hydrocarbon recovery and groundwater monitoring services for the client at their facilities.
Remediation activities performed for the client include operation and maintenance of dual phase, high vacuum extraction (DPHVE) systems, well vacuum services at selected monitoring and recovery wells using a vacuum truck, pilot testing and design of air sparge (AS)/soil vapor extraction (SVE) systems and enhanced bioremediation. Reports generated as part of KEMRON’s activities include quarterly groundwater monitoring reports, Corrective Action Plans (CAPs), initial site characterization reports, LNAPL recovery reports and environmental site assessment reports.
Representative projects include:
KEMRON has provided a full range of professional consulting and remedial service contract to a retail petroleum for more than 10 years. Services include: UST removals, site investigations, corrective measures, design and installation of remediation systems, operation and maintenance of remediation systems and groundwater monitoring services. KEMRON provides services at sites throughout West Virginia, Ohio, Kentucky and Georgia and has achieved “No Further Action” status for 35 sites in the last four years. As part of these activities, KEMRON prepares and submits all reimbursement applications for Georgia UST work in accordance with Georgia EPD/USTMP guidelines. The reimbursement packages are submitted with each report submittal to ensure timely payment and we maintain close working relationships with Georgia EPD/USTMP reimbursement staff to insure that activities conducted at eligible facilities are reimbursable.
Remedial activities include the operation and maintenance of a groundwater pump and treatment/soil vapor extraction system, airsparge and soil vapor extraction systems, dual-phase high vacuum systems and bioremediation. These remediation systems include groundwater extraction pumped through an oil/water separators, air stripper then discharged to the storm or sanitary sewer. The soil vapor extraction system utilizes a vacuum blower to extract vapors from extraction wells and discharges effluent vapor into the atmosphere or through vapor-phase treatment.
Reports generated from these projects include quarterly groundwater sampling reports, corrective action measures reports, initial site characterization reports, environmental site assessment reports, discharge monitoring reports and UST closure reports.
KEMRON held a master service agreement with a Class I railroad for more than 10 years completing more than 200 projects. KEMRON completed a wide range of environmental services to include site investigations, engineering studies and remediation programs at railyards; removal of USTs from active and inactive railyards; emergency response to derailment/spill sites; preacqusition and divestiture audits; corrective actions; and large remediation in support of redevelopment. Representative experience includes:
Nationwide Tank Program. Under contract to the client, KEMRON removed over 300 USTs at various rail facilities throughout the eastern United States. Project activities included initial notification, site assessment, tank removal, free product recovery, soil remediation, soil and groundwater investigations and continuing investigative and remedial services necessary to achieve clean closure of each tank pit according to state guidelines.
Port Covington. KEMRON conducted a $7.5 million turnkey investigation and remediation of Port Covington site in Baltimore, MD, a 189-acre former railyard and port facility, for Brownfield redevelopment into a marina, hotel, office park and a newspaper’s printing plant/office complex. KEMRON conducted a preliminary assessment/site investigation to determine the extent and type of contamination. KEMRON developed remedial goals to address levels of arsenic, cadmium, lead, petroleum hydrocarbons and volatile organics found on site. KEMRON conducted a remedial investigation and feasibility study.Following selection of remedial options, KEMRON then implemented a large remediation program including: removal of surface refuse piles, emptying of septic tanks, removal of 200 drums of unknown contents, removal of contaminated soil from maintenance buildings and decommissioning/closure of 30 fuel storage tanks. KEMRON completed long term remedial actions using bioremediation of over 50,000 yards of contaminated soil and stabilization/fixation of 20,000 yards of lead contaminated soil.
Barr Yard. KEMRON conducted a comprehensive soil and groundwater investigation at the locomotive fueling facility located at a rail yard in Chicago, IL. Petroleum contamination was identified throughout the fueling area and was encroaching onto other areas of the rail yard. KEMRON developed a product recovery and soil remediation program integrated it into the engineering plans for upgrading the fueling area. The design/build solution developed and implemented consisted of the installation of a series of recovery trenches, installation of five lift stations, installation of 480 feet of horizontal wells and removal and disposal of contaminated soils.
Ellicottville, NY. KEMRON conducted a surgical removal of zinc ore from a train derailment incident. Box cars containing zinc ore derailed spilling the ore along several hundred feet of track bed in Ellicottville, NY. After the majority of the spilled material was removed, KEMRON performed a site investigation of the residual metals, contaminated track bed, and adjacent farmland. Cadmium, a secondary component of the ore, was of concern to the regulators. The KEMRON team conducted a risk evaluation of the cadmium contamination in three distinct environments – limited access railroad trackage, resort development property, and agricultural land. The remedial action plan included three remedial approaches; each tailored to the particular risk and concern of each environment contaminated.
Eckington Railyard. KEMRON conducted a comprehensive environmental and hydrogeologic evaluation of a former rail yard and three nearby parcels in Washington DC to determine if contamination existed from prior usage which would preclude redevelopment of these parcels for commercial use. A site history records search was performed and historical aerial photographs were reviewed. Remedial clean-up levels were negotiated with the District of Columbia Environmental Agency. KEMRON also surveyed onsite buildings for Asbestos.
KEMRON has been providing environmental services to Hartsfield Jackson Atlanta International Airport to include compliance audits, remediation, investigation, pilot studies, tank removals, excavation, air monitoring and groundwater monitoring. KEMRON is a primary subcontractor on an Environmental Contract for this airport and has completed a variety of projects covering Environmental Sampling, Regulatory Evaluation and Management, Field Surveys, Remediation, and Preparation of Environmental Reports
Examples of work completed under this contract include:
Remediation Field Testing. KEMRON conducted remediation field testing including: conducting soil vapor extraction (SVE) tests, conducting high-vacuum, multi-phase extraction tests and reporting of results. The field testing included collection of pre-test groundwater and free product levels from eight groundwater monitoring wells and one product extraction well. The specific data objectives included the soil-air permeability and potential effectiveness of high-vacuum, multi-phase extraction for product recovery.
The high-vacuum, multi-phase extraction test was conducted to assess the potential effectiveness of this technology for future free product removal. The test was conducted on the existing product recovery well, which has been observed as containing a product thickness of 10 feet. Data collected during the test included vacuum measurements for groundwater monitoring wells and groundwater/free product level data from all wells following the test. Air flow and total hydrocarbon measurements were recorded along with estimates of product and groundwater recovery.
Free Product Recovery and Pilot Testing. KEMRON performed free product recovery at Pit # 19 using the KEMVAC system. KEMVAC is a proprietary dual-phase vacuum extraction and thermal oxidation system developed by KEMRON. A JP4 fuel lead occurred in the hydrant fueling system producing free product on groundwater. The leak is located at gate A19, the busiest location at the airport. KEMRON performed a one-day, high vapor, multi-phase extraction pilot test. The objective of pilot test was to determine if this remedial technology is a cost-effective solution for cleanup of this high traffic volume site.
Environmental Compliance Audits. KEMRON provided consulting services to the airport’s Department of Aviation (DOA) to perform a multi-media environmental compliance audit of airport tenants. Three auditing teams, consisting of three individuals with varied compliance backgrounds, performed the environmental compliance audits over a three-month period in 2003. The multi-media environmental compliance audit encompassed the following areas of concern: Chemical Product Importation, Oil Pollution Control and Contingency Planning, Spill Response and Release Reporting, USTs, Wetlands, Hazardous Materials Management, PCBs, Solid and Hazardous Waste Management, and Water Quality. Each environmental compliance audit was completed by utilizing a three-step process. A pre-audit questionnaire was either picked up by the tenant or mailed to the tenant at least one month prior to scheduling the audit. A site visit and records review was scheduled with the environmental coordinator or manager of each tenant at least one week in advance. A site visit and records review was performed including an exit meeting with the tenant to discuss potential areas of concern identified during the audit.
A summary memorandum was generated to summarize audit findings for each tenant. The summary memorandum was forwarded to the DOA Environmental Projects Manager and the tenant representative. Tank Tightness Testing. KEMRON performed UST tightness testing for four underground storage tanks and associated piping; two (2) 600 gallon USTs located at building 6 fuel island and two 12,000 gallon USTs located at building 4 fuel island at HJAIA.
KEMRON conducted Phase I and Phase II Environmental Due Diligence Audits (EDDA) as part of this engagement for this airport client. The EDDA is required by the FAA for acquisition and disposal of real property at aviation facilities, to minimize the FAA’s environmental liabilities. KEMRON conducted the Phase I EDDA for over 400 acres of property.
The airport lies between residential and heavy industrial communities, and has been in operation for over 70 years. During the course of conducting the EDDA, KEMRON collected information from over 30 regulatory agencies and affected parties. All available historical documentation regarding site environmental issues was researched, reviewed, summarized, and catalogued. KEMRON then completed a comprehensive site reconnaissance, walking all areas encompassed by the EDDA and documenting existing site conditions and any potential environmental concerns. In addition, KEMRON was responsible for completion of all requirements pertaining to wetlands, threatened and endangered species, cultural and historic resources and biotic communities, per NEPA and DOT requirements.
Based upon this comprehensive document review and site reconnaissance, the EDDA revealed over 20 separate potential areas of environmental concern, including former USTs, hazardous waste units, solid waste disposal sites, contaminated soil management issues, and numerous potential releases of hazardous substances.
Subsequent to completion of the Phase I EDDA, KEMRON designed and implemented work plans for site investigation of environmental issues through a Phase II EDDA. KEMRON was responsible for development of the technical approach to assessment, preparing site specific health and safety plans, implementation of the plans, and report preparation. Work completed during the Phase II EDDA included installation of test pits, field screening and field testing of soil and waste materials, geoprobe investigations and extensive soil sampling and analysis for petroleum products, volatile and semivolatile contaminants. The Phase II EDDA field investigations evaluated all areas of concern identified during the Phase I.
Results of the Phase I and Phase II EDDA were compiled into a comprehensive five volume report of findings which included catalogued reference materials, original CADD mapping, analytical data, and interpretative summaries. All documents were also supplied to the client in electronic format for archival purposes.
KEMRON was contracted to perform environmental sampling of nine surface water outfalls and two instream monitoring locations to evaluate compliance with the Airport’s NPDES permit requirements. KEMRON also performed sewer sampling under the airport’s Comprehensive Sampling and Analysis Program (CSAP). KEMRON personnel responded within 12-24 hours of special requests and on regularly scheduled intervals to perform environmental sampling. The NPDES surface water sampling and analytical results were used to determine compliance with the NPDES permits.
For the airport’s CSAP sampling events, KEMRON personnel participated in identification of sewer manholes and catch basins using existing drawings of the airport sewer system. KEMRON personnel employed the drawings and field reconnaissance notes to determine appropriate sampling points, and conduct sampling within the sewer system.
Field activities are conducted both airside and landside. KEMRON personnel were available to work flexible schedules to accommodate needs for sampling events occurring during both day and night hours. Airside sampling was conducted in close coordination with airport personnel and in compliance with all FAA requirements to ensure that air traffic is not interrupted or impacted by the sampling activities, and that safety is ensured throughout each sampling event.
KEMRON was under contract to this petroleum refining and marketing company for site investigations and remediation of soil and groundwater contamination at a facility in Bayonne, New Jersey. KEMRON prepared and conducted a sampling plan to address both soil and ground water lead contamination at the site. The plan was prepared using the New Jersey Administration Code (N.J.A.C.) Part 7, Chapter 26E.
The purpose of the sampling event was to:
- establish a contaminant gradient for the soils
- collect ground water samples from the down-gradient monitor wells to determine if the ground water was contaminated
Low flow sampling methodology was used to both purge and sample the ground water from the three monitor wells. The low flow collection method attempts to simulate the aquifer conditions by pumping ground water from the monitor well at a flow rate comparable to the aquifers recharge rate. This was accomplished by setting the intake velocity of the sampling pump to a flow rate that limits drawdown inside the well casing. By simulating the recharge rate, the ground water was not dissolving any additional sediments or other aquifer material. Water parameters were collected at selected intervals and tabulated in the daily log notebook.
KEMRON evaluated innovative remediation approaches and because of the nature of the contamination (low levels of heavy metals, predominantly lead, in soil), was able to reduce the amount of soil to be remediated.
The first phase of activity involved the evaluation of remedial alternatives, the selection of the costeffective alternative, and the development of the Remedial Action Workplan. The second phase of activity involved developing the design of the cost-effective remedy, implementing the cost-effective remedy, and post-remedial monitoring. The third phase of activities involved preparing a Draft and Final Remedial Investigation Report, a Classification Exception Area proposal and a Remedial Action Report.
By evaluating innovative remediation approaches, KEMRON saved the client between 5 and 10% of initially estimated remediation costs.
A historical diesel fuel leak from a pipeline resulted in a free product plume over an area of five acres at this terminal site in Georgia. KEMRON installed groundwater monitoring wells at the site in order to define the extent of the free floating petroleum and initiated a quarterly sampling program to define the extent of the dissolved petroleum constituents. KEMRON performed routine maintenance of the existing product recovery systems and designed an expanded program involving the design and installation of product recovery trenches at the site. The trench recovery system eliminated season grass kills which occurred on an adjacent property during rising water table conditions. KEMRON designed a groundwater remediation system and performed operation and maintenance of the system. In addition, product-only pumps were installed in one day to address a sudden subsurface release.
KEMRON completed O&M activities at a Superfund site, located south of Marietta, Ohio. The transition from the previous contractor was managed efficiently with no downtime for operations. The site consisted of three inactive waste disposal areas (North Landfill, Site A and B) and a former phenol production unit area. The disposal units and the former phenol production area were located within the confines of two operating chemical plants. The primary contaminants of concern were dioxin, furans, benzene and chlorobenzene.
KEMRON employed two full-time and two part-time personnel, who were responsible for all daily O&M activities and acted as liaisons to the local operating plants. KEMRON maintained and operated a leachate collection system; performed routine gas vent maintenance and groundwater monitoring activities; provided site security; ensured compliance of neighboring facilities with site health & safety requirements when working on the property; interfaced with regulatory agency personnel; provide mowing/cleaning/and general maintenance of client property and equipment; provided response services for spills, releases and related issues; and supervise subcontractors in specialized maintenance activities.
Numerous special projects have been completed by KEMRON on the site in support of planned remedial activities. These projects have included: preparation of a comprehensive site Health & Safety Manual; filtration, solidification and consolidation of wastewater and sludges contained in the 150 drums stored on site; inventorying, packaging and disposing of IDW and site chemicals; collection of over 400 discrete soil samples from the former phenol production area for furan analysis. Investigation of adjoining property planned for acquisition by the client; upgrading of site facilities with installation of new office and decontamination trailers; comprehensive groundwater monitoring well inventory and upgrade plan for over 120 wells.
KEMRON also provided support on remediation of radioactive slags and metal owned by the client on an adjoining property. Work included preparation of a site sampling grid and collection of over 80 soil samples for analysis of radioactive constituents. KEMRON also provided assessment, containerization, testing and shipping of 90 – 4 cubic yard containers (360 yards) of radioactive material. Activities also included over packing drums and containers of radioactive waste where the containers had deteriorated.
KEMRON provided engineering and contractor services during the closure of the North Landfill and assumed the role of facility liaison for plant and agency personnel to the client’s project personnel and contractors. KEMRON commissioned the new leachate collection system and pump station installed during the closure. KEMRON authored the Operation & Maintenance Plan for the closed North Landfill.The O&M Plan described all activities and documentation required for the site. The plan conformed to site and EPA Region V requirements and was reviewed and approved by the regulatory agencies.
KEMRON installed an operated a groundwater remediation system at the site. Approximately 50 acres of the facility is impacted by a groundwater plume, with monochlorobenzene, benzene and phenol as the primary constituents of concern. Three separate source areas are controlled with extracted water treated at an operating chemical plant wastewater treatment facility. Monitored natural attenuation was used as the remedy for fringe areas of the plume extending south toward the lower terrace of the Ohio River.
KEMRON installed 25 new stainless steel recovery wells, 11 new piezometers and 4 new recovery wells. Also, two recovery wells and one large production well were abandoned. Eighteen of the new recovery wells were operated in conjunction with two existing wells to form a hydraulic barrier along the southern edge of a closed disposal unit. The hydraulic barrier wells were powered by pneumatic pumps, operated by a control system installed by KEMRON. Pneumatic pumping systems were utilized for groundwater recovery from 3 other wells located at waste disposal units on the northern portion of the property. Groundwater recovery in the highly productive river aquifer was accomplished by the installation of four new wells equipped with electric submersible pumps. These wells were operated in conjunction with one existing recovery well, with new piping, electric, and control systems installed by KEMRON.
KEMRON was contracted to perform a remedy screening treatability study on two contaminated materials sampled from a former manufactured gas plant (MGP) site located in Stockton, California. The treatability study was conducted was for an in-situ solidification contractor on behalf of an electric and natural gas distributor, to evaluate the feasibility of in situ solidification / stabilization for treatment of sludges sampled from the site.
Two candidate site materials were subjected to ISTD distillation treatment performed at two target temperatures and two retention times. During treatment, De-Ionized (DI) water was injected into the test material via a low volume peristaltic pump. The quantity of water injected was outlined by TerraTherm and included specified pore volumes, based on the treatment duration.
Throughout treatments, KEMRON performed constant temperature monitoring of the soil and injected water, and organic vapors in the off-gas via a flame ionization detector (FID). All vapors were passed through a distillation treatment and indicated that total volatile organic compound concentrations were reduced by more than 98%, and Diesel Range Organics (DROs) were reduced by more than 87%. Total semi-volatile organic compounds were reduced for many compounds but in general proved more difficult to treat than the volatile compounds.
The mobilization of DNAPL was evaluated by passing a specified pore volume of chilled water through the test soil while at ambient temperature. An additional specified pore volume of water was then passed through the test soil during heating. Throughout testing, KEMRON monitored the soil and water injection temperatures, the pressure within the test system, and visual clarity of the water exiting the system.
Geotechnical testing of certain treated site soil types was performed to ensure that thermal treatment did not adversely affect the physical properties of the site soils.