Remediation “Innovation” Over The Last 50 Years – Who's driving?

Don't worry, I have nothing to sell you. These are my thoughts after retiring. TLDR? Scroll to the end. (Photo: no kids on board and no injuries; credit https://www.wisn.com/article/racine-school-bus-overturns-in-pond-after-crash/63020820)

Environmental regulations related to soil and groundwater in the US really didn’t begin to get traction until the late 1980s to early 1990s.? For sure, the 1960s began an era of greater environmental awareness, and the 1970s were a period when environmental regulations began to take shape.? The USEPA was formed, and industries became regulated to lessen air and water pollution.? The Superfund Program passed by Congress in 1980 started to hold polluters responsible for cleaning up PAST contamination from hazardous waste sites, and Resource Conservation and Recovery Act related soil and groundwater contamination investigations started to be performed in the late 1980s.? Many monitor wells were drilled and installed, and soil and groundwater samples take and analyzed.

I started college during this time in the mid-1980s and discovered a love of earth sciences, particularly enjoying the environmental side of it.? As geologists were working at McDonalds and Thom McAn because of the petroleum bust, I went straight to graduate school.? I studied engineering geology under Dr. Chris Mathewson and Professor Norm Tilford, and took a few classes in contaminant hydrogeology from Dr. Patrick Domenico - known to most hydrogeologists for applying analytical math to groundwater and contaminant behavior that ultimately led to computer models; I remember a large circuit board on plywood that was displayed in his office that represented an early 2-dimensional computer model.

I then started and spent my career in the petroleum and chemical industries, working directly for the regulated historical so called “polluter”.? When I started, groundwater pump and treat was the be-all, end-all solution to our groundwater contamination issues.? Soon we found out about asymptotic behavior of contaminant concentrations and back diffusion of contaminants from matrices.?

We needed a secondary method that would “polish” the remaining contaminants so we could meet our goals –drinking water standards and governmental approval and closure.? So the 1990s into the 2000s became an era of in-situ treatments to treat the remaining nagging compounds that could not be remediated by pump & treat in many lifetimes – physics and chemistry of our earth would not allow it. ?We had redox compound injections, biological treatments, nutrient injections (molasses, vegetable oil), air sparging, soil venting, thermal desorption, so on and so forth.? It really was a booming time with exponential research and innovation for a couple of decades.

Then bring in concepts of ecological and human-health risk assessments based on the toxicology of contaminant molecules (“the dose makes the poison”), and source-pathway-receptor models to limit or stop exposures thus doing no harm.? Government agencies thus began issuing “No Further Action” letters with some amount of acceptable contaminant concentration levels to be left in place, sometimes with institutional and engineering controls, with deed and use restrictions put in place (such as no residential use, no drinking water extraction, etc.).? As long as concentrations were demonstrably statistically stable or decreasing, clean-up was deemed complete “enough”.

Difficult to treat compounds and rebound were challenging issues at my sites.? At times I had to make sure that my project sites were not simply grounds for academic research or consultant revenue – I needed my messes managed and/or cleaned up! – sometimes fast, sometimes cheap.?

It got to the point where in the last couple of decades, I would actually pay more for the certainty and speed of contaminated soil excavation.? Even with road trucking or rail risks, and the tail-liability of future landfill issues if not incinerated, we’d rather do this than pay less with uncertainty of finality and additional risk of time.? My management expected no surprises, especially when quarterly and annual financial forecasts needed to be flawlessly accurate. ?It was then that I joked that I got 2 college degrees to dig dirty soil and haul it away – “play” with excavators and dump trucks. No fancy schmancy remediation techniques.

The business side likes the surety of remedy of past sins, even if it costs more, and just relocates the liability to somewhere safer.? That liability is removed from the balance sheet at that point.? Environmental reserves are no longer necessary.? The site is remediated, the agency issues closure, and the waste is “gone” (incinerated or relocated to a licensed management facility, hopefully to never awaken).? However, this is only one scenario.?

What if the company is NOT flush with cash, or is not in condition to clean up its balance sheet?? Then you need to preserve cash, damn the balance sheet.? Your remediation strategy needs to accommodate.? And that can switch on a dime, as we barreled towards during the Great Recession when my employer entered Chapter 11 bankruptcy protection.? And again flush with cash when we successfully emerged, stronger (few companies ever do emerge).

Land could be put back to some productive use, especially as US manufacturing started to shut-down and head overseas over the last 30 years.? I managed and oversaw almost 2 dozen plant shutdowns and demolitions, unfortunately (my first one in 1999 was surreal).? Having a reasonably clean environmental bill of health was necessary for these disused assets to be sold for future use.? Various managements battled with whether to keep a site forever to control liability, or to sell with adequate insurance and contractual protections and make some money.? My different management teams had different appetites for legal risk over the years and the pendulum swung in different directions at least 4 times over the last 35 years.

Takeaway thought:? As a customer, an owner, a regulated entity - if you are not driving, you’re just a passenger…surely your management expects more from you as the representative of the polluting past.? Be technically saavy, be strategic, ask the hard questions – don’t be wishy-washy between tough management bosses, smart consultants with innovation to sell (and sometimes a conflict of interest), and regulators with a job to do.? Listen to your Board of Directors and help your Executives succeed based on the big 3 – balance sheets, P&L, and statements of cash flows.? These are 7-8 figure dollars at stake and a lot is riding on YOU as the remediation manager to protect the house…sometimes even from itself!