Assessment, Remediation, and Monitoring (ARM) services incorporate a broad range of activities focused on addressing the release of hazardous substances or threats of release at your project site from discovery through regulatory closure.
Hazardous substances can originate from a variety of sources and are commonly found at manufacturing facilities, oil and gas sites, waste facilities, agricultural sites, and more. Chemical byproducts and petroleum that originate from the operation of these sites may be released into your project sites and property, contaminating the soil, groundwater, and air in the surrounding environment. The presence of these substances can pose a threat to the health and the ecology of the region. What is the best process for dealing with unwanted contaminants? ARM is conducted in instances that require environmental due diligence, such as real estate development and redevelopment, site closures, and more.
Assessment, Remediation, and Monitoring (ARM) provides a process to address hazardous substances, combining the skills of specialized experts trained in remediation strategies with the latest technology to create a cost-effective process. We’ve broken down the steps with some real-world examples.
Step 1: Assessment
Phase I Environmental Site Assessment (ESA)
Identification of a hazardous substance release or threat of release is the primary objective of Phase I ESAs. Phase I ESAs are most often performed during real estate transactions as part of the due diligence process.
The Phase I ESA includes an inspection of the entire property, regulatory research on the site and surrounding areas to identify violations or other issues of non-compliance that could lead to a release of hazardous substances, a review of the historical chain of title, and aerial photographs, and interviews with site personnel to develop a thorough understanding of the issues potentially affecting your property. Phase I ESAs are performed under the ASTM 1527-21 standard, providing a consistent basis for your analysis and providing your client with landowner liability protection under CERCLA. If the findings of the Phase I ESA indicate the presence of recognized environmental conditions, the ARM process continues.
To demonstrate the Phase I ESA process, consider this 8-acre parcel of land contracted to be redeveloped into a high-rise building and parking lot. A Phase I ESA was executed by the Cameron-Cole team and from a surface-level perspective, conditions seemed acceptable. A more detailed audit of historical records revealed that a coal gasification plant had operated on a 2.5-acre portion of the property, so our team further assessed the potential for hazardous substance release associated with this activity.
While a Phase I ESA identifies the potential for hazardous substances to have impacted your property, further investigatory steps are required to define the nature and extent of those impacts.
Step 2: Site Characterization and Investigation
Phase II ESA
The information generated during the Phase I ESA is used to inform your site characterization process, which involves the sampling of environmental media to further assess issues identified during the Phase I ESA. Data collected during the Phase II ESA allows trained professionals to begin understanding the nature and extent of the issue. Phase II ESAs typically include the collection of geologic and hydrologic data to understand where the hazardous substances released at a property may have migrated to.
In one case, Cameron-Cole conducted a Phase II ESA at a brownfield slated for redevelopment. Surface soil was sampled and analyzed for potential contaminants. After contamination proved to be minimal and did not pose a threat to human health, the redevelopment process began, saving the client considerable time and costs.
Site characterization provides you with the answers to your contamination questions. In the best-case scenarios, your site characterization proves that no remediation is necessary. In instances where contamination is determined to be present, the Phase II ESA findings lay the groundwork for the detailed analysis of determining the need for remediation and selecting a remedial solution for the site.
Step 3: Remediation
The site characterization and investigation process identifies the presence of hazardous substances at unacceptable levels, which then initiates the remedy selection process. Feasibility studies are focused assessments conducted to identify the best remedy for an impacted site. The process can involve extensive site characterization activities to fill data gaps, bench and pilot scale testing of potential remedial alternatives, detailed cost evaluations to identify the most cost-effective remedies, and an assessment of regulatory and community acceptance of the proposed remedy.
The remedy selection process considers multiple approaches to remediating a given site.
Remedies for a given site take into consideration the current and future land use of the property, and the desired timeline to achieve regulatory closure. In some instances, remedies are selected because they can remove contamination relatively quickly, facilitating the timely redevelopment of a site or addressing an imminent hazard to human health and the environment. For example, impacted soil can be excavated for off-site disposal at an appropriate facility, or other mitigation measures can be implemented to quickly address potential exposures to hazardous substances.
A former industrial facility investigated by Cameron-Cole revealed a Volatile Organic Compound (VOC) plume within groundwater on the property. To address this contamination, we took an active remediation approach, installing a groundwater pump and treat recovery system that extracted the groundwater and discharged it directly to a local municipal sanitary sewer system. This approach was determined to be the most cost-effective method to halt groundwater plume migration and limit exposure to contaminated groundwater.
In instances where achieving site cleanup is less critical on time, the application of a more passive remedy may be preferable. Passive remedies generally reduce contamination levels slowly over longer time frames, often resulting in significant savings for clients. Passive remediation approaches include monitored natural attenuation, whereby the inherent capacity of the environment is utilized to reduce contamination levels through biological and geochemical means. Another commonly used passive remedy technique that Cameron-Cole frequently utilizes is Targeted Microbial Applications (TMA), which employs an In Situ Bioreactor (ISBR) system to augment the contaminated subsurface with bacteria capable of rendering contaminants harmless over a period of time.
At one waste management facility Cameron-Cole partnered with since 2009, extensive soil and groundwater contamination was detected where downgradient contamination was occurring. To remediate the VOCs, we utilized one of our most effective passive remediation strategies, an ISBR with TMA to effectively degrade the VOCs over time. The ISBR systems are still in place and are being actively monitored by our specialists.
In many situations, a combination of both active and passive remediation solutions must be implemented to fully address the contamination on site.
Step 4: Monitoring
Now that your remediation system has been implemented, the site must be consistently monitored to test the effectiveness of the solution that is in place. Monitoring serves as the key tool for evaluation. Long-term trends in the chemistry of the soil, groundwater, and air quality are evaluated. Your site will also be evaluated for additional threats that have presented themselves. If a new threat is detected, it is first examined, and an appropriate remediation system is then designed and applied.
In the TMA project mentioned above, continuous monitoring of our ISBR systems is critical to tracking the progress and efficiency of the remediation strategy. Ongoing monitoring practices include evaluation of daily remediation system operational data, collection of quarterly and semiannual groundwater samples, and preparation and submission of technical reports documenting these monitoring activities. These same monitoring techniques must be employed across all remediation systems to ensure the efficacy of the systems in place.
As you can see, hazardous substance release is a complex issue that can present major liabilities to your project site. There is no ‘one size fits all’ approach to solving these challenges. Professional experience and a deeper understanding of the challenges are critical to ensuring the protection of the environment and the occupants of the area. If contamination is suspected at your premises, get trained professionals on site as soon as possible. The longer an area is contaminated, the greater the potential is for the contamination to spread, resulting in a costlier and more time-intensive remediation process.
Cameron-Cole, an ADEC Innovation, specializes in assisting our clients with complex environmental liabilities through environmental remediation. Do you suspect contamination at your project site? We have performed thousands of due diligence Phase I and Phase II ESAs for a multitude of clients across multiple industries. Contact us for a free consultation to discuss your current and potential remediation obligations.