AeroJet Sacramento Facility

one of the major west coast sites that it seems everyone in the environmental remediation business gets to work on at one point is the AeroJet Sacramento Facility. Even though I am based in Southern California, I did a soil gas investigation out there in the summer of 2002 or 2003. It seems that the site continues to require attention and has received additional federal funding. The EPA issued the following press release last week:

SAN FRANCISCO — The U.S. Environmental Protection is ordering a $60 million clean-up of rocket fuel-polluted groundwater at the Aerojet Superfund Site in Sacramento County, Calif., the latest phase of a long-term decontamination project at the site. The extent of toxic pollution at the site makes it one of the largest and most comprehensive Superfund groundwater cleanups in California.
A 27-square mile swath of groundwater underneath and around the former aerospace facility is polluted with several compounds, including very high levels of perchlorate — a main component of rocket fuel — and a known developmental toxin. Aerojet, under the direction of the EPA, will contain the underground plume to prevent it from spreading into nearby rivers and streams. Future plans will also treat groundwater within the site’s boundaries.

This site is one of many former aerospace facilities that requires site investigation, cleanup, and various other compliance-related focus.

Form more information, see the EPA website: www.epa.gov/region09/Aerojet

EPA Fine

Last month, TMW Corporation, a plating company located in Van Nuys, California was fined $100,000 by the United States Environmental Protection Agency (EPA). These fines are not arbitrarily handed out over night, they are generally the product of numerous unanswered notices of violation, inspection requests, and other correspondence with the EPA. Avoiding these types of fines and violations is not a difficult process and is something that I have done and will happily do again for numerous clients.

Here is a link to the press release from the EPA website.

The full text of the press release:

U.S. EPA fines Van Nuys metal plater $100,000 for hazardous waste violations
For Immediate Release: June 29, 2011, Contact: Francisco Arcaute, (213) 244-1815, Cell (213) 798-1404, arcaute.francisco@epa.gov

SAN FRANCISCO – The U.S. Environmental Protection Agency fined TMW Corporation, 14660 Arminta Street, Van Nuys, $100,000, for violations of the Resource Conservation and Recovery Act.
The violations were discovered at the company’s facility, Crown Chrome Plating, a Division of TMW Corporation, during an inspection conducted by EPA in April 2009. The facility, which does metal plating primarily for the aerospace industry, is located in a light industrial zone of Van Nuys, a San Fernando Valley community of approximately 136,000 residents.
“The toxic wastes and sludges at the Crown Chrome facility have the potential to pose a danger to employees, the surrounding community and the environment,” said Jared Blumenfeld, the EPA’s Regional Administrator for the Pacific Southwest. “EPA is committed to enforcing the federal laws that require all companies to properly store and handle their hazardous wastes.”
TMW Corporation generated multiple hazardous wastes including, paint wastes, alkaline and acidic corrosive liquids, and sludges containing heavy metals such as chromium and lead. These hazardous wastes, and the waste handling violations associated with them, are typical of those produced by metal plating shops, which are often the target of EPA enforcement actions.
The federal hazardous waste regulations require companies to properly manage hazardous waste to prevent harm to human health and the environment. EPA discovered the following violations at TMW Corporation’s facility:
• Storage of hazardous waste for over 90 days without a permit
• Failure to conduct required inspections
• Failure to train personnel or maintain training records
• Failure to maintain required emergency communications equipment
• Failure to make a hazardous waste determination
As a result of this enforcement action, TMW Corporation has returned to compliance with federal law and will pay a fine of $100,000.
EPA’s hazardous waste rules require facilities to properly store, label and close hazardous waste containers. Facilities must also have properly trained staff, as improperly stored hazardous waste can spill and pose a risk to workers and the environment.

Federal, state and local regulatory agencies have formed a Los Angeles Enforcement Collaborative to focus resources over a multi-year effort to ensure that businesses and industries in this area are complying with environmental laws. U.S. EPA is joining forces with several state and local agencies under this collaborative including Cal/EPA, the California Department of Toxic Substances Control, the Los Angeles Regional Water Quality Control Board, and the California Air Resources Board as well as local non-profit organizations to improve environmental and public health conditions in Los Angeles communities.

Types of Sites – Dry Cleaners

This post will continue a post series that I started toward the beginning of this blog and including:

Regulatory FAQ
Regulatory FAQ II
Definition of Terms
and
Industrial Facility

Those posts described the basic steps associated with the work I do at various types of sites. This post will describe my involvement in the standard dry cleaner site located in a standard shopping center.  Let’s say that there is a shopping center that has multiple units and one of them is a dry cleaner.  This tenant has been in operation as a dry cleaner since the center was built some 20-30 years ago.  The dry cleaning process, as I have discussed in my previous post about green dry cleaning, uses tetrachloroethelene (PCE).  From an environmental standpoint, this chemical can be a hassle to purchase, manage, dispose of, and generally use.  Due to the difficulties associated with disposal of PCE, many operators of dry cleaning facilities historically disposed of the chemical in the sewer by either dumping it in a floor drain, sink, or the toilet.  This practice was generally conducted up until the mid-1970s when environmental regulations became more mainstream.  Releases can also occur beneath the dry cleaning machine itself and in the area where the chemical is stored.

Investigating the potential for releases at these types of sites is generally performed in a few phases starting with a soil vapor survey in the area along the sewer line followed by soil samples in impacted areas identified during the soil vapor survey.  The final phase of investigation generally consists of groundwater samples in impacted areas identified during the soil sampling.

Remediation of a dry cleaner site generally involves soil vapor extraction (SVE) in the area of impacts.  The SVE methods can range from carbon adsorption to chemical oxidation (Generally, carbon is sufficient).  Since the impacted areas are commonly inside the building, excavation using small drill rigs and Bobcat-type excavators is necessary.  There are a number of challenges associated with the process, but it is rather common and these types of sites can be usually be remediated within a few years.

Types of Sites – Industrial Facility

For this post, I thought I would continue on a subject that I began a couple of years ago on this blog:

Regulatory FAQ
?????????Regulatory FAQ II
and
Definition of Terms

Those posts described the basic steps associated with investigation of your standard corner retail gas station. For this post, let’s assume that you own an industrial facility of some sort. Either you owned the property and leased it to a widget manufacturer or you are the widget manufacturer and you own the property were you do your work. For whatever reason, the decision has been made to close the widget factory and sell the property. To do so, you will have to decommission all the various parts of the facility. A vital step in this process is what is called the, “Hazardous Materials Inventory”. This process will identify everything from mercury switches in thermostats and PCBs in light ballasts to large storage tanks and make recommendations for the appropriate method(s) for their decommissioning.

Let’s just say that a portion of this facility was used as a steam cleaning area with floor drains that conveyed the wash-down water into the sanitary sewer. Before the wash-down water went into the sanitary sewer, it flowed through a three-stage clarifier to allow the solids to settle out. All of this is a very common feature in industrial facilities. The Hazardous Materials Inventory identified the use of chlorinated solvents, specifically TCE, during the 1970s in various parts of the property including the steam cleaning area. Based on these findings, the recommendations are to advance soil borings in the area of the steam cleaning area, the floor drains, and the three-stage clarifier. The data collected from this investigation will allow us to evaluate how much soil (if any) around of the steam cleaning area is impacted with TCE and / or anything that was being washed off the widgets that were being steam cleaned.

Can’t wait to hear the next part? What do we do? How much do we have to dig out? How much will it cost? How long will it take to do all the work? Well, it takes a couple weeks to get data back from the lab and write the report. Check back next month!

Pause Post – Definition of Terms

To continue on the subject of the last post, let’s assume that you disposed of the tank and the pea gravel or sand that surrounded the tank without incident. You even excavated as much of the stained soil from the base of the excavation as possible while you had the excavation contractor onsite. Let’s also assume that you were able to back-fill the excavation with 1 sac slurry without incident. The soil samples you collected from the base of the excavation came back with gasoline and BTEX, so you will have to perform an additional investigation under the direction of the County Fire Department. You’ve hired your drilling contractor to come out and collect some soil samples as well as install some vapor extraction wells.

You may be thinking to yourself, “I am starting to not understand these terms”. That’s completely fine. Let me take a minute to define a few of these terms before we move on:

BTEX – A combination of volatile organic compounds commonly found in gasoline, Benzene, Tolulene, Ethylbenzene, and Xylenes. Xylenes inlcude m,p-xylenes, o-xylenes, and total xylenes. These compounds all have their own regulatory limits, there is no regulatory limit for BTEX as a group.

Clean Certificate – A Marine Chemist will certify the tank for “Hot Work”. If “Hot Work” will be done on the tank at the destination it will be transported to, the certification that the tank is clean and vapor free should be performed by a certified Marine Chemist.

CUPA – Certified Unified Program Agency, a California state agency. The CUPA was created by SB 1082 in 1994 to consolidate a number of hazardous material programs into one single agency. In many areas the local CUPA is the local fire department, but based on where your property is located your CUPA may be a city agency, the department of health services, or the local arm of the Environmental Protection Agency. In the previous post, the CUPA agency is the Los Angeles countyHot Work – Welding or cutting of metal with a torch.

Marine Chemist – A person qualified to certify a tank as “clean” meaning that all visible deposits, sludge, and all other foreign materials have been removed from the inside of the tank and that there is no flammable hazard or vapors exist. The Marine Chemist fills out the “Clean Certificate”.

One Sack Slurry – A type of cement mix that is delivered in a cement truck. It is mixed at the cement plant and consists of one sack of portland cement to one sack of aggregate, in this case we usually use medium sand. The benefits of a one sack slurry is that is has a pretty good compressive strength meaning that you can drive a truck over it and once it is dry and it can still be worked with an excavator or a backhoe.

Pea Gravel – Gravel, usually crushed granite, that falls within a certain size range that roughly equals the size of a pea. This type of gravel, sand, or one-inch crushed rock is used when a UST is installed because it doesn’t settle or allow the tank to shift around inside the tank pit.

UST – Underground Storage Tank, usually used to hold petroleum hydrocarbons such as gasoline or diesel. Can also be used to hold industrial chemicals and waste oil.

That is a good ammout of information for this post, so I’ll end it there. Next time we’ll discuss what is involved with investigating the extent of the imacts from this leaking tank.

Regulatory FAQ – II

Back to our regularly scheduled program of regulatory how-to.  One of the problems that I mentioned in my last post that you may encounter is the potential that the Underground Storage Tank (UST) that you were planning to remove leaked during it’s former use.  Let’s assume again that the tank held automotive gasoline.  Let’s also assume that the tank is located in Los Angeles County and therefore all work will be overseen by the Site Mitigation Unit of the Health and Hazardous Materials Division of the Los Angeles County Fire Department.

You went ahead and filed the permits to remove your tank, paid the fees and got approval.  You also scheduled with your contractor to excavate the tank and remove the tank in the presence of the inspector.  The inspector also required you to have a marine chemist on site during the tank pull, so she shows up and runs her tests, fills out her forms and now you are good to go.  Until the tank is pulled and exposes a small rust hole  and a relatively large  patch of stained soil beneath the tank.

Now you have a site investigation on your hands.  You will still collect samples from the sidewalls and the base of the excavation, but the samples you collect from the base of the excavation will be impacted with gasoline.

The County Fire Department will require an investigation  whether you backfill or not, so let’s just say that in this case you need to backfill because you have other redevelopment contractors that need to be able to drive over the area.  Go ahead and order your 1 sack slurry from your local cement supplier and fill that excavation up.  You will also have to dispose of the pea gravel or sand that was around the tank so call your favorite trucking company and find a place that will accept the material.

Call a drilling company and plan on collecting soil samples and installing a soil vapor extraction system.  We’re into remediation now, hold tight for the next installment in the process.

Regulatory FAQ

One question I commonly get is, “What is the regulatory agency for my property?”.  This relatively simple question has an amazingly complex answer.  The answer is so complex that I will spend the next few blog posts answering it.

Let’s first discuss a relatively common and relatively simple situation, a site with an Underground Storage Tank or UST.  In this scenario lets say you will need to remove the tank as part of your property redevelopment activities.  Maybe the property was an old gas station, maybe it was an old warehouse that had a diesel UST for delivery trucks, or perhaps the UST was used to store waste oil from some sort of operation that was formerly conducted at the property.  In any case, the tank must be removed and you need a permit to do that, but who will be issuing the permit?

Again, this relatively simple question has a quite difficult answer when we go to hunt down the regulatory agency for the property.   In the State of California, issues of this nature are overseen by the local Certified Unified Program Agency or “CUPA ” .   The CUPA was created by SB 1082 in 1994 to consolidate a number of hazardous material programs into one single agency.  In many areas the local CUPA is the local fire department, but based on where your property is located your CUPA may be a city agency, the department of health services, or the local arm of the Environmental Protection Agency.  Other programs overseen by your local CUPA include:

  • Hazardous Materials Business & Emergency Response Plans;
  • Underground Storage Tank Regulations;
  • Hazardous Materials Business Plans;
  • Hazardous Waste Regulations;
  • Hazardous Waste Treatment Regulations; and
  • Risk Management Plans.

For converstaion’s sake, let’s narrow it down a little and say that the property is located in Los Angeles County, specifically the City of Santa Monica and let’s just say the property is a former gas station and the tank formerly held automotive  gasoline.  These assumptions will narrow the CUPA agency down to the City of Santa Monica Environmental Programs Division.   A quick review of the City of Santa Monica website (link) tells us what form has to be filled out and what fees are required to file the application.  There is an extensive packet of CUPA information that (hopefully) was partially filled out when the tank was installed, but you may have to catch up on the filing if it wasn’t done or if it was done incorrectly.  This could also mean paying back-fees.  You will have to file the forms, schedule a contractor to pull the tank, schedule an inspection at the time of the tank pull, collect soil samples, arrange for a laboratory to analyze the soil sample, write a report, submit the report to the CUPA agency (City of Santa Monica in this instance), and backfill the excavation.

Hopefully the tank didn’t leak.  If it did, there is usually an investigation and removal action required that involves more agency interaction and will most likely be more than just the CUPA, but that also depends on the property location and every City/County is different.

There is also always the chance that your property is part of  a larger investigation area or Federal Superfund investigation.  The complexity increases quite a bit at that point, more info in my next post…