Taking Sites from the Initial Emergency Response Phase Through Regulatory Closure

When members of the EWI emergency response team receive notice of a potential hazard – a fuel spill on gas station property, for example – they have to act quickly. At the same time, our team members must keep environmental compliance top of mind at all times. The process of taking sites from the initial emergency response phase through regulatory closure is an extensive one, but it shows just how committed we are to preserving our environment.

Taking Sites from the Initial Emergency Response Phase Through Regulatory Closure

Step One: Initial Emergency Response and Assessment

When we get a call from a business or property owner, our emergency response team immediately schedules an on-site assessment. There, we’ll assess the severity of the situation. If the spill is small, we might be able to clean it up that day. However, if the spill has moved into a creek, onto an adjacent property, or into groundwater, excavation or vacuum extraction may be in order. Finally, if impacted soil can’t be completely cleaned up or if questions remain as to the extent of impact, our experts will characterize the site for further assessment. Our emergency response team works through these steps rapidly to move toward regulatory closure as quickly as possible. At this point, our experts can also walk the property owner through the Missouri Petroleum Storage Tank Insurance Fund process, which can help financially support remediation in some cases.

Step Two: Additional Site Characterization

The cleanup of spills is generally overseen by a regulatory body like the Missouri Department of Natural Resources (MoDNR). If MoDNR requires additional information on the site, our team will conduct a more thorough site characterization. This starts by putting together a conceptual model of the site to better understand the current and surrounding land use, area geology, and evaluate all potential exposure pathways. This conceptual site model can be used to prepare a work plan to determine where more soil borings or groundwater data are necessary to move forward. The conceptual site model is also updated as more data is gathered, providing a “big picture” view of what potential risks are present at the site. This can be an iterative process, conducted in coordination with the overseeing regulator, continuing until both the horizontal and vertical extent of soil and groundwater impact is delineated.

Step Three: Risk Assessment

Once the complete extent of soil and groundwater impact is known, our experts will prepare a risk assessment report. The risk assessment evaluates each potential exposure pathway, both current and future, as well as plume stability, which is a way of predicting whether or not the hazard will spread. Exposure pathways include things like vapors entering a building, or impact reaching a drinking water well. Data from the site is compared to available target levels to determine if any risks are present.

Step Four: Remediation

If current or future risks are identified in the risk assessment, our team will prepare a Corrective Action Plan, recommending an approach to eliminate that risk. This could involve things like excavation of additional soil, installing a treatment system to prevent vapors from entering a building, or placing an environmental covenant on the property to prevent future water wells or future buildings over certain areas of the site. EWI works with the client and regulators to come up with a plan that works for each involved party.

Step Five: Regulatory Closure

Regulatory closure is the final step in this process – the step at which we can consider a case to be fully resolved. Before a site can achieve regulatory closure, there are several standards it must meet:

• The site must have proof that all environmental risks have been addressed and that no unacceptable risks are presented by the conditions at the site.
• The data used to evaluate these risks must be fully representative of the site – which means if data was averaged together to evaluate a pathway, high concentrations weren’t ”diluted” by including a bunch of low or “clean” samples in the average.
• A plan must be in place to ensure responsible future land use. For example, if soil or groundwater impact is left in place at a site and the concentrations exceed the target levels for residential property use, there should be a mechanism in place to prevent future residential use of that property.
• The site must have demonstrable plume stability to ensure that impact from the site is not migrating toward another property.

Our emergency response team is committed to fast, thorough environmental remediation. We have the expertise and the equipment to walk property owners through every step of emergency response, including coordinating with resources like the Missouri Petroleum Storage Tank Insurance Fund.

If you have questions about the importance of taking sites from the initial emergency response phase through regulatory closure – or any of the events that occur therein – Environmental Works is here to help. To learn more, please click here to contact us online.