It’s the nightmare scenario for any facility manager or business owner…
You have a leaking underground storage tank, a chemical spill, or other incident that has contaminated the soil and/or groundwater at your site… or even worse – it has impacted an off-site property, too.An investigation by an environmental consulting firm piles on the bad news – the price tag for investigation and remediation will be six figures.
Your first instinct is to start the work right away. You’re in a rush to get back to normal operations.
But hold on. Before you pay that hefty price tag, you need to get a second opinion.
It may cost a bit more to bring in a third party – another environmental consulting firm – to review the data or conduct their own investigation. But your cost savings could be significant in the end because the initial investigation and remediation recommendations could be way off-base.
We’ve been brought in as the third party on many projects over the years, and you’d be shocked at the amount of mistakes we identified that were made by the firms who did the initial investigations.
In short, there may be no real plan for collecting the proper data or how it should be used. As a result of those errors, the firms could not fully understand the problem. And they had no business recommending a plan of action. If you don’t know what you are dealing with or have a complete picture of what you need to address, how can you figure out a way to effectively remediate it, let alone estimate the cost?
They cost their clients tens of thousands… even hundreds of thousands of dollars… just for an initial site investigation that was insufficient. And when they send the remedial action plan in for approval, regulators fire back that they’re nowhere near fully characterizing the site and include a long list of deficiencies – which the firm disputes.
That means more money, wasted time, and hassle for the client as the firm and regulators argue back and forth. It could be six months to a year between communications with regulators. And the dispute stretches on for many years.
Yes, even major firms make those mistakes. How is it possible?
I’ve said it before, but often big name companies have projects going on all over the country, so to cut their own costs as much as possible, they send junior personnel out into the field to directly oversee projects with instructions in hand. They go with their firm’s standard operating procedure, even if it’s not appropriate for the site. These junior personnel may not be experienced enough to recognize what should be done and how; the senior personnel overseeing them may not have even set foot on the site.
That’s why you need a third party opinion from an environmental consulting firm that will do a more thorough job.
If your firm is leasing the property and uses or handles hazardous materials or petroleum products there, and the owner has retained a consulting firm and is paying them to conduct an environmental investigation, especially at a site that has been used for industrial purposes for many years, it is even more important to have a third party opinion from an experienced consulting firm who is working for you. The consulting firm working for the property owner may decide to save their client’s money by making the case that you, the tenant, are to blame for the problem!
I’ll admit, when Envision Environmental, Inc. comes in to give a second opinion, we face an uphill battle. Sometimes our clients haven’t even started on the expensive part of the projects and now they have to pay us to fix things first.
But our recommendations will put them right with regulators, usually cost less in the long run, and resolve the problems in a timely manner.
Our goal is to bring the issue into clarity and focus. We do this by fully characterizing the contamination and fully understanding the issues, then coming up with the plan to address the issue from the business side as well as from the environmental side.
The good news is we usually don’t have to start from scratch. We look at what is known about the site now and fill in the gaps in the data to be able to understand the conditions completely.
Our first step is to look at all the data collected by the previous consultant. Sometimes that’s key to coming up with the solution because they didn’t look at all the data they had as a whole, or they overlooked something.
We worked on one project where the client had bought another company and one of their sites was undergoing remediation. In New Jersey, soil samples need to be taken at different depth increments depending on certain scenarios.
But the national firm on the project ignored New Jersey’s technical rules and did it their own way. The result: a multi-page deficiency letter from regulators noting the data was not in compliance with the regulations.
In the meantime, the building on the site was razed and the property sold to an Italian food provisioning company – they supplied condiments to restaurants. A grandfather had bought it for his family. As a proud Italian family, they had installed an imported marble floor in the lobby of their new facility.
Then ENVISION got involved. Turns out the areas needing the most work were located under that marble floor. But based on our examination of the testing already done and the sampling we were able to avoid drilling through the marble floor: we closed out the site to the regulators’ satisfaction using all of the existing data.
But it was touch and go for a minute there. I’ll never forget one site meeting with a particularly rigorous regulator who was adamant that the samples had to be collected at a certain interval directly below the new marble floor. We showed her the complete data, showed that the contamination was limited and would not migrate, showed her the beautiful marble floor, and she relented. It didn’t hurt that the site owners were present and forewarned everyone that “nobody, and we mean nobody is drilling through our new floor.”
Sometimes just having a simple conversation makes the difference.
At one site we investigated, there were upgradient monitoring wells showing contamination. The previous consultant pointed the finger at the farmland next door as the source of the contamination. But that didn’t make sense to us because of the nature of the contamination and the historical usage of the property next door.
As we always do, we talked with the long-time facility workers at our client’s property. After reviewing site history, we were able to determine that the area where the upgradient monitoring wells were located had formerly been used as a drum storage area many, many years ago, which turned out to be the source of the contamination. Only the long-time facility workers had this knowledge. The previous consultant never interviewed these very knowledgeable workers at the site.
Again, just having a simple conversation makes the difference.
Often, we do have to collect new data because what’s available does not tell the whole story.
We took on one job where the first consultant had installed over a dozen monitoring wells to characterize the groundwater contamination at the property - a good first step to monitoring what’s happening at the whole site. But they made a critical mistake. They were taking groundwater samples from two or three of the wells in one quarter, then waiting six months to sample another set of wells, and then sampling a different set of wells a few months later. The problem is, it is difficult to figure out what is going on at the site if you are collecting groundwater data in a piecemeal fashion over varying, inconsistent timeframes. You really need to be consistent with your data collection approach.
There was another wrinkle. Seasonal variations at the site were affecting the groundwater quality and that had to be taken into account for the remedial action, which would be taking place over a long period of time. These seasonal variations were not accounted for by the previous consultant.
Depending upon the type of contamination that you are addressing, the concentrations of the contamination could vary significantly between seasons. At this site, in the wetter months, the groundwater rises and the contamination would be evident in the samples. But in the drier seasons, when the groundwater level is typically low… you may not see elevated concentrations. If you plan your whole remediation effort around the data collected from the drier months, you may fall short in addressing your overall problem.
It’s the “little” but super-important details that some environmental firms do often overlook that can mean rapidly increasing costs for clients and a lengthy remediation process that no one had planned for.
That’s why it’s so important to get a second opinion from a qualified consultant. You’ll save time, money, and hassle.
If you’re in the middle of a seemingly endless clean up at your site and your current firm hasn’t been able to make headway with regulators… or you just got a pricey remediation estimate that left you with “sticker shock”… we can help resolve your situation.
Give us a call now at (609) 208-1885 or send an email to markroman@envisionenvironmental.com
