Experience Summary

Assisted clients with risk management activities, including evaluation of area hydrology and hydraulics, property assessment results, modeling studies, etc., to determine feasibility of proposed real property transactions. Completed Environmental Site Assessment (ESA) reports documenting these studies.

Prepared work plans to investigate, permit, design, report to regulatory agencies, and close hazardous materials release sites under regulatory regimes resulting from the Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, or “Superfund”) and state-administered equivalents; e.g., HSRA, etc.

Directed and/or performed field work necessary to assess and characterize hazardous materials release sites; including evaluation of area hydrology and site hydraulics, personnel interviews, public record searches, aerial photography missions, monitoring well installations, surface and subsurface sampling, etc. Direction included preparation of formal Sampling and Analysis Plans (SAP), RCRA Facility Inspections (RFI), assessment of RCRA Solid Waste Management Units (SWMU), HSRA Compliance Status Reports (CSR), CERCLA Preliminary Assessment - Site Inspection (PA-SI) equivalents, Leaking Underground Storage Tank (LUST) site assessments, etc.

Performed risk-of-exposure assessments at hazardous materials release sites using contaminant fate and transport analyses, including hydrologic, hydraulic, chemical and biological models running on various computer platforms

Evaluated storm water hydraulics and hydrology at industrial and commercial facilities and hazardous materials release sites. Prepared plans for storm water pollution prevention (SWP3) in discharges directly to waters of the United States and/or municipal-separate storm sewer systems (MS4). Developed plans and specifications for engineering controls, including detention basins, sewer systems, piping, pumps, etc.

Negotiated and coordinated with clients, regulatory agencies, and public utilities to develop cost-effective hazardous materials release corrective actions, including innovative remedial technologies. Prepared Corrective Action Plans (CAPs) for public comment under RCRA, HSRA, etc.

Prepared water and waste waster discharge, solid waste disposal and air pollution control permits; corrective action plans; engineering design reports, plans, and specifications for industrial facilities and hazardous materials release site remediation. These included permits for pre-treatment and discharge to Publicly-Owned Treatment Works (POTW or municipal sewage collection and treatment systems) or directly to the waters of the United States under the National Pollutant Discharge and Elimination System (NPDES) program of the Clean Water Act.

Assessed, inventoried and calculated hazardous materials quantities at industrial facilities for compliance with the Emergency Planning and Community Right-to-Know Act (EPCRA); otherwise known as Superfund Amendments and Reauthorization Act (SARA) Title III. Completed required reports.

Performed field tests for pilot studies of proposed remedial designs at hazardous materials release sites and performance evaluation of in-place systems; including aquifer pump/slug tests, computer modeling, bioventing treatability, etc. Prepared construction plans and specifications and/or recommended design modifications, as necessary.

Planned and performed engineering inspections for corrosion, cracks, and existing repairs in process vessels, transport tanks and other aboveground storage tanks (ASTs) containing hydrocarbon fuels, liquid hazardous wastes, etc.. Evaluated area hydrology and facility hydraulics for potential threats of releases to waters of the United States and/or MS4. Prepared Spill Prevention Control and Countermeasures (SPCC) Plans and recommendations for further action.

Prepared engineering design plans and specifications for pollution control construction at industrial and commercial facilities. Secured regulatory approval and permits.

Directed construction, operation, and maintenance of corrective actions at industrial facilities and hazardous materials release sites.
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Representative Projects

Advanced Design & Packaging, Inc., Manufacturing Plant, Atlanta, Georgia (06/99 to present): Developed comprehensive environmental compliance plans for custom-product packaging design and manufacturing facility located adjacent to Chattahoochee River in Atlanta. These included assessment of manufacturing processes and discharge of waste water, air emissions and solid wastes disposal.

Prepared water balance calculations to estimate industrial discharge flow to sanitary sewer and prepared detailed as-built process drawings and piping diagrams. Prepared application for industrial pre-treatment permit with Fulton County POTW.

Modified processes to recycle and re-use cooling water in glue production, reducing potable water use and industrial discharge flow. Modified process to also achieve compliance with POTW discharge limits, including replacing certain printing press cleaning solutions, etc. Designed and directed installation of waste water monitoring station and prepared bi-monthly reports to POTW.

Assessed, inventoried and calculated hazardous materials quantities for compliance with EPCRA. Completed required reports. Assessed solid waste disposal activities and profiled waste stream for non-hazardous certification, including sampling and laboratory testing. Prepared Environmental Program Manuals for managing compliance with AD&P customer requirements for hazardous materials content in finished products.

Directed preparation of facility-wide air emissions inventory and minor-source air permit application. Based upon computer modeling results, directed modification of certain process exhaust stacks.

Evaluated site hydraulics and hydrology, plant operations and management, and developed SWP3, including assessment of five outfalls discharging into a perennial stream and the Fulton County MS4. Plan included development of appropriate checklists and procedures for outfall monitoring and sampling, and facility equipment inspections.
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William L Bonnell Company, Manufacturing Plant, Newnan, Georgia, HSI #10090 (08/96 to present): Directed closure of ASTs at major aluminum recycling and manufacturing operation, according to RCRA and other hazardous wastes regulations. Permitted adjacent soils as RCRA landfill closure.

Performed additional RFI, including collection and analyses of soil and ground water samples, and installed vapor monitoring wells. RFI included treatability study for potential bioremediation corrective action. Performed engineering calculations for concrete cover and certified documents for RCRA closure of the SWMU associated with the earlier AST closure.

Performed on-site pilot tests, using vapor wells, and designed a system for remediation of the soils affected by the solvent spill. The design specified in-situ bioremediation using forced-air bioventing technology. Prepared required underground injection control (UIC) permit. Directed construction of system.

Performed aquifer tests by rapidly purging monitoring wells and timing recovery. Performed 72-hour in-situ respiration tests of subsurface microbial metabolic rates feeding on solvents affecting landfill soils, approximately every six months, to evaluate system performance over time. Mobilized to site on periodic basis to inspect and adjust system operations and test subsurface extent of aeration. Used weekly fax updates of system gage and meteorological readings collected by Bonnell technicians to remotely monitor proper system operations.

Used aquifer hydraulics, microbial respiration and system operations data to develop one-dimensional model of contaminant transport, leaching and remediation effectiveness and predict time remaining to closure. Completed risk assessment with termination of system operations pending regulatory approval.

Developed RCRA Contingency Plan for compliance with Part B, Treatment, Storage and Disposal Permit. This required top-to-bottom assessment of all plant manufacturing operations, hazardous materials use and storage, and safety procedures.
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Name-brand Consumer Products Manufacturer, Production Plant, Northwest Georgia (1995 to present): Developed SPCC plan for management of two 30,000-gallon fuel oil underground storage tanks (USTs) feeding on-site generators and boilers. Developed plans and specifications for engineering controls of fuel delivery operations. Documented completion of upgrade construction in SPCC plan update.

Directed later closure of USTs (Georgia ID #4-080194). Achieved “No Further Action Required” (NFAR) status using RBCA standards, assessment of area environmental receptors and graphical modeling of area hydrology and site hydraulics. Designed and permitted replacement of USTs with single 10,000-gallon AST located in high-risk industrial manufacturing operations area in close coordination with state and local fire safety officials. Prepared amended Corrective Action Plan (CAP) using RBCA analyses for several smaller USTs removed by plant in 1989-90 and achieved NFAR status.

Evaluated site hydraulics and hydrology, plant operations and management, and developed SWP3, including assessment of nine outfalls discharging into a perennial stream. Plan included development of appropriate checklists and procedures for outfall monitoring and sampling, and facility equipment inspections. Also, developed Slug Discharge Control Plan for compliance with Industrial Pre-treatment Permit issued by local Publicly-Owned Treatment Works (POTW).
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Major Manufacturer of Fiber-reinforced Plastic Bath Fixtures, South Georgia (01/2003 to present): Evaluated site hydraulics and hydrology, physical condition of facility, manufacturing operations and management, product freight transport operations and existing environmental management systems. Then developed SPCC, including visual integrity assessment of 7,000-gallon ASTs containing polyester resin, 10,000 gallon diesel fleet fueling AST, drummed protective coatings, etc. Calculated secondary containment capacities around ASTs and load-unload racks. Plan included development of appropriate checklists and procedures for facility equipment inspections, product delivery operations, emergency spill response, etc. Plan also included program of required upgrades to facility pavements, curbing, AST secondary containment, etc., and replacement of polyester-resin tanks with new, more modern systems.
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Citizen’s Bank & Trust of West Georgia, Carrollton, Georgia (02/98 to 2001): Assisted bank with risk management activities, including evaluation of property assessment results, hydraulic modeling studies, etc., to determine feasibility of proposed real property transactions. Assistance included performing a Phase I ESA, according to the standards of the American Society for Testing and Materials (ASTM), at a local convenience store and gasoline service station (Georgia ID # 9-022065) proposed for sale.

Visually assessed local area hydraulics and hydrology together with a review of existing literature studies and a limited search for potential environmental receptors. Used the on-site drinking water well to assess site hydraulics by performing a limited, aquifer draw-down test followed by laboratory analyses for chemistry of a water sample.

Input the aquifer test results into a one-dimensional contaminant transport computer model (TRANS1D and in-house spreadsheet models) to assess the potential risk associated with a worst-case release scenario. These results indicated acceptable risks without the need for additional expensive site investigation and laboratory sample collection.
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Used Truck Parts Salvage Yard and Repair Shop, Middle Georgia (12/00 to 2001): Assisted facility with risk management activities, including evaluation of area hydrology and site hydraulics, property assessment results, etc., to determine feasibility of proposed real property divestment. Assistance included evaluating previous graphical modeling studies of on-site chemical contamination developed from installation and sampling of monitoring wells. The on-site “recognized environmental conditions” resulted from former un-registered USTs, solid waste incineration, equipment cleaning operations, etc. Results of the site assessment have been used to develop recommendations for additional site investigation, etc., related to HSRA compliance. Implementation is pending further action.
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Former Texaco Service Station, Brunswick, Georgia (02/99 to 2002): Assisted developer with risk management activities, including evaluation of area hydrology and site hydraulics, property assessment results, hydraulic modeling studies, receptor surveys, etc., to determine feasibility of proposed “brownfields” redevelopment. Assistance included performing an initial, one-dimensional computer modeling study (TRANS1D) to determine feasibility of using monitored natural attenuation (MNA) for remediation of contaminated soils and ground water at this coastal zone site. Based upon this assessment, developer proceeded to close the purchase and begin construction of new commercial development (Eckerd Pharmacy).

Results of the initial study indicated partial soil remediation and contaminant source removal would be required to prevent contaminated ground water from reaching the nearby subsurface utility trenches at an unacceptable concentration. Directed removal of UST system (Georgia ID #06-30185), including tanks, piping and dispensers, over-excavation of contaminated soils, and collection of geotechnical soils data. New store construction began immediately following the partial remediation.

Using results of UST closure assessment, developed SAP for additional site investigation, including installation of off-site monitoring wells and sampling of nearby surface and ground water receptors. Prepared off-site access permit application with Georgia Dept of Transportation (GDOT) and secured construction approval.

Mobilized to site and directed construction of proposed wells, additional soil and ground water sample collection for laboratory analyses, re-surveyed site features with tie-in to nearby USGS boundary monument, and met with local government engineers to obtain maps of underground utility trenches. Performed aquifer tests by rapidly pumping ca. 50 gallons from three different monitoring wells and timed recovery.

Using results of additional site investigation, developed two-dimensional model (BIOSCREEN) of site hydraulics and contaminant transport with decaying source term to simulate partial soil remediation and source removal. Model predicted ground water plume would never reach nearby receptors at unacceptable concentrations.

Incorporated results into combined CAP Parts A & B for submittal to the Georgia Environmental Protection Division (GEPD). Quarterly monitoring confirmed model predictions were safely conservative and GEPD issued a No Further Action Required (NFAR) letter. New pharmacy store has opened to help re-vitalize formerly depressed area.
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Hana Convenience Store Property, Riverdale, Georgia, HSI #10563 (12/99 to 10/00): Assisted client with risk management activities, including evaluation of area hydrology and site hydraulics, property assessment results, etc., to determine corrective actions likely to be required by GEPD. Assistance included evaluating previous graphical modeling studies of on-site contaminant fate and transport developed from installation and sampling of monitoring wells.

The on-site “recognized environmental conditions” resulted from improper disposal of dry cleaning solvents (trichloroethylene, or TCE, and tetrachloroethylene, or PCE) and petroleum releases from regulated USTs (Georgia ID #03-10007). Calculations indicated ground water concentrations of chlorinated aliphatic hydrocarbons (CAH) would exceed applicable HSRA Risk-Reduction Standards (RRS). The presence of a nearby drinking water well supplying a mobile home park was a particularly important factor in the hydraulic analyses of contaminant transport.

Developed SAP including installation of an additional water-table well, adjacent to the existing on-site “vertical-extent” well, and collection of additional geochemical, geotechnical soils and aquifer hydraulic data. Results indicated no subsurface vertical flow components and the USEPA, two-dimensional model, BIOCHLOR, could be used to determine the feasibility of an MNA corrective action.

Application of the BIOCHLOR model indicated MNA was feasible and these results were incorporated into the compliance status report (CSR) submitted to GEPD according to HSRA regulations.
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Ford Motor Company, Atlanta Assembly Plant, Hapeville, Fulton County, Georgia (04/99 to 05/99): Four USTs (Georgia ID #70-00039) containing virgin and waste solvents were operated on site for a period of almost ten years. The tanks were closed by removal in 1993. During the time the USTs were in operation, solvent releases resulted in dissolved concentrations of methyl isobutyl ketone (MIBK) in the underlying aquifer exceeding acceptable standards.

Assessment of area hydrology and facility hydraulics indicated groundwater flow under the site is controlled by a surface stream to the east. A receptor survey indicated underground sources of drinking water are not present within 1.0 miles of the site for public sources, or 0.25 mile for private sources.

Evaluated MIBK transport in ground water from the on-site solvents release using a simple one-dimensional spreadsheet model (TRANS1D). Estimated parameters using site investigation results for aquifer hydraulic and geochemical parameters, along with literature values for soil geotechnical values.

The model predicted an assumed worst-case water quality standard will not be exceeded at a perennial stream, Mud Creek, located 800 feet downgradient of the release source. As a result, a corrective action of MNA was feasible with very little risk to public health and the environment. Subsequent monitoring results confirmed the model validity and resulted in GEPD issuing a NFAR letter.
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Atlanta Structural Concrete Company, Former Manufacturing Plant, Powder Springs, Georgia (06/94 to 01/01): Assisted developer with risk management activities, including evaluation of area hydrology and site hydraulics, property assessment results, hydraulic modeling studies, etc., to determine feasibility of “brownfields” redevelopment. Assistance included performing a Phase I ESA, according to the ASTM standards, evaluating potential effects of plant operations (including former un-registered USTs and ASTs) on unused land behind the plant (proposed for divestiture) and later on the plant property itself.

The latter assessment included review of previous environmental studies and development of a SAP, including installation of temporary monitoring wells (TMWs) and collection of soil, ground water and surface water samples for laboratory analyses of chlorinated hydrocarbons, petroleum hydrocarbons, RCRA-regulated metals, polychlorinated biphenyls (PCBs) and other hazardous materials. Used TMWs to map aquifer hydraulic properties.

Used these results in a graphical modeling study to assess potential risks to downgradient environmental receptors. Study results indicated acceptable risks when combined with those of completed corrective actions mandated by the GEPD. Facility has now been re-developed into commercial and residential properties improving economic conditions, creating new jobs and increasing property values in area.
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Wip-X Systems, Inc., Commercial Laundering Facility, Mansfield, Georgia (02/99 to 11/00): Developed comprehensive environmental compliance plans for commercial laundering facility located in rural Newton County near the city of Mansfield. These included assessment of manufacturing processes and discharge of waste water and solid wastes disposal.

Prepared water balance calculations to estimate industrial discharge flow to sanitary sewer and prepared detailed as-built process drawings and piping diagrams. Prepared application for industrial pre-treatment permit with the State of Georgia, the permitting authority for the City of Mansfield. Prepared plans and specifications for connection with a pump station constructed on site by the POTW. Evaluated sludge management practices and chemical profile data, then developed appropriate de-watering and disposal methods.
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Former Manufactured Gas Plant, Rome, Georgia, HSI #10109 (08/93 to 10/96):Developed expert testimony in multi-million-dollar litigation between the facility owner, Rome I, Ltd., and the corporate successor to the gas works company, Atlanta Gas Light (AGL). The purpose of the testimony was to answer the questions of what, if any, corrective action would be required by GEPD and the potential cost of satisfying the requirement, if imposed.

Reviewed existing site history and investigation data, including area hydrology and site hydraulics. Researched history of manufactured gas plant (MGP) residuals management practices. Calculated site hydraulics and hydrology under the influence of varying stages in adjacent major river. Estimated likely contaminant source areas and concentrations and calculated applicable HSRA-RRSs.

Delineated contaminated site areas and calculated media volumes requiring corrective action to meet likely GEPD cleanup standards. Evaluated potential corrective actions and developed preliminary designs to remedy both soil and ground water contamination along with estimated costs of construction, operation and maintenance to site closure.

Proposed remedy included excavation and disposal of contaminated soils by on-site incineration; with ground water remediation by pumping to surface and treatment by coagulation-flocculation. Presented resulting testimony in deposition with litigant attorneys. Case eventually settled out of court.
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