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Guideline for the Management of Sites Contaminated with Light Non-Aqueous Phase Liquids

Light Non-Aqueous Phase Liquid (LNAPL) Management is the process of LNAPL site assessment, monitoring, LNAPL Conceptual Site Model development, identification and validation of relevant LNAPL concerns, and the possible application of remediation technologies. The presence of LNAPL can create challenges at any site.  Examples of LNAPLs include gasoline, diesel fuel, and petroleum oil.

In 2009, the United States Interstate Technology and Regulatory Council (ITRC) published LNAPL-1: Evaluating Natural Source Zone Depletion at Sites with LNAPL (ITRC 2009b) and LNAPL-2: Evaluating LNAPL Remedial Technologies for Achieving Project Goals (ITRC 2009a) to aid in the understanding, cleanup, and management of LNAPL at thousands of sites with varied uses and complexities. These documents have been effective in assisting implementing agencies, responsible parties, and other practitioners to identify concerns, discriminate between LNAPL composition and saturation-based goals, to screen remedial technologies efficiently, to better define metrics and endpoints for removal of LNAPL to the “maximum extent practicable,” and to move sites toward an acceptable resolution and eventual case closure.

This guidance, LNAPL-3: LNAPL Site Management: LCSM Evolution, Decision Process, and Remedial Technologies, builds upon and supersedes both previous ITRC LNAPL guidance documents in an updated, web-based format. LNAPL-1 and LNAPL-2 are still available for review; however, LNAPL-3 is inclusive of those materials with new topics presented and previous topics elaborated upon and further clarified.

This guidance can be used for any LNAPL site regardless of size and site use and provides a systematic framework to:

  • develop a comprehensive LNAPL Conceptual Site Model (LCSM) for the purpose of identifying specific LNAPL concerns;
  • establish appropriate LNAPL remedial goals and specific, measurable, attainable, relevant, and timely (SMART) objectives for identified LNAPL concerns that may warrant remedial consideration;
  • inform stakeholders of the applicability and capability of various LNAPL remedial technologies
  • select remedial technologies that will best achieve the LNAPL remedial goals for a site, in the context of the identified LNAPL concerns and conditions;
  • describe the process for transitioning between LNAPL strategies or technologies as the site moves through investigation, cleanup, and beyond; and
  • evaluate the implemented remedial technologies to measure progress toward an identified technology specific endpoint.

Initial development and continued refinement of the LCSM is important to the identification and ultimate abatement of site-specific LNAPL concerns. Figure 1-1 identifies the stepwise evolution of the LCSM, the specific purpose of each LCSM phase, and the tools presented within this guidance to aid in the development of the LCSM. As depicted, the LCSM is the driving force for identifying actions to bring an LNAPL site to regulatory closure.

LNAPL remediation process and evolution of the LNAPL conceptual site model (LCSM).

This guidance document is organized into sections that lead you through the LNAPL site management process:

  • Section 2 – LNAPL Regulatory Context, Challenges, and Outreach
    Section 2 identifies some of the challenges implementing agencies face when investigating, evaluating, or remediating LNAPL sites. These challenges include regulatory or guidance constraints, a lack of familiarity or understanding of LNAPL issues, and poorly or undefined objectives and strategies. This section also stresses the importance of identifying and communicating with stakeholders early in the process in order to address issues or concerns that can lead to delays or changes in strategy. Understanding and recognizing these challenges and concerns during development of a comprehensive LCSM can help reduce costs and lead to a more effective and efficient resolution at an LNAPL site.
  • Section 3 – Key LNAPL Concepts
    Section 3 provides an overview of key LNAPL terminology and concepts including LNAPL behavior following a release to the subsurface (i.e., how LNAPL spreads away from the primary release point, its behavior above and below the water table, and how its migration eventually stops and naturally depletes). An understanding of these basic terms and concepts is crucial for developing a comprehensive LCSM and an effective LNAPL management plan.
  • Section 4 – LNAPL Conceptual Site Model (LCSM)
    The LCSM is a component of the overall conceptual site model (CSM), and emphasizes the concern source (i.e., the LNAPL) of the CSM. The presence of LNAPL necessitates an additional level of site understanding. The unique elements of the LCSM are presented as a series of questions for the user to answer to help build their site-specific LCSM. Ultimately, a thoroughly-developed, initial LCSM provides the basis for identifying the LNAPL concerns associated with an LNAPL release.
  • Section 5 – LNAPL Concerns, Remedial Goals, Remediation Objectives, and Remedial Technology Groups
    Section 5 describes the decision process for identifying LNAPL concerns, verifying concerns through the application of threshold metrics, establishing LNAPL remedial goals, and determining LNAPL remediation objectives. This section also introduces remedial technology groups, the concept of a treatment train approach, and how to transition between technologies to address the identified LNAPL concern(s) systematically and effectively. It is important to understand the content of this section prior to selecting and implementing an LNAPL remedial strategy.
  • Section 6 – LNAPL Remedial Technology Selection
    Section 6 describes the remedial technology screening, selection, and performance monitoring process. This section begins by identifying technologies recognized as effective for mitigating specific LNAPL concerns and achieving site-specific LNAPL remediation objectives based on the collective experience of the LNAPL Update Team. The LNAPL Technologies Appendix summarizes each of the technologies in detail and presents a systematic framework to aid the user in screening out technologies that are unlikely to be effective, ultimately leading to selection of the most appropriate technology(ies) to address the specific LNAPL concerns.

This guidance also includes relevant, state-of-the-science appendices for more detailed information on LNAPL specific topics:

  • LNAPL Technologies Appendix 
    This appendix describes in more detail each of the 21 LNAPL technologies introduced in the main document. The A-series tables describe information to evaluate the potential effectiveness of each technology for achieving LNAPL goals under site-specific conditions. Information includes the basic remediation process of each technology, the applicability of each technology to specific remedial goals, and technology-specific geologic screening factors. The B-series tables describe information to evaluate the potential implementability of each technology considering the most common site-specific factors. The C-series tables describe the minimum data requirements to make a final technology selection through bench-scale, pilot, and/or full-scale testing; they also describe metrics for tracking remedial technology performance and progress.
  • Natural Source Zone Depletion (NSZD) Appendix
    This appendix provides a technical overview of NSZD for LNAPL and the methods by which rates can be estimated and measured. It also provides a discussion of long-term LNAPL site management and how NSZD can be applied as a remedy including decision charts to support integration of NSZD and case studies demonstrating its use. For this document, the original ITRC NSZD document (ITRC LNAPL-1) was updated and incorporated into the main body and appendix.
  • Transmissivity (Tn) Appendix
    LNAPL transmissivity has application throughout the life cycle of a LNAPL project. This appendix provides an understanding of how transmissivity connects to the broader framework for LNAPL management including LNAPL recovery and mobility, and the potential for NSZD to decrease LNAPL transmissivity and mobility over time.
  • Fractured Rock Appendix
    This appendix describes the behavior and differences of how LNAPL behaves in fractured bedrock formations. While some of the same physical principles apply for multiphase flow in fractured aquifers as in porous aquifers, unique characteristics of finite and restricted fluid flow paths can lead to unexpected results in fractured settings.
  • LNAPL Sheens Appendix
    This appendix details how LNAPL sheens form, the concerns and challenges of sheens, and potential sheen mitigation technologies.

LNAPL Contamination of the Subsurface

Microbial Biotechnology in Environmental Monitoring and Cleanup

A new book on the advances in microbial biotechnology in environmental monitoring and clean-up has just be published by IGI Global.  The book is part of the Advances in Environmental Engineering and Green Technologies Book Series.

In the book, the authors state that pollutants are increasing day by day in the environment due to human interference. Thus, it has become necessary to find solutions to clean up these hazardous pollutants to improve human, animal, and plant health.

Microbial Biotechnology in Environmental Monitoring and Cleanup is a critical scholarly resource that examines the toxic hazardous substances and their impact on the environment. Featuring coverage on a broad range of topics such as pollution of microorganisms, phytoremediation, and bioremediation, this book is geared towards academics, professionals, graduate students, and practitioners interested in emerging techniques for environmental decontamination.

This book is a collection of various eco-friendly technologies which are proposed to under take environmental pollution in a sustainable manner. the role of microbial systems has been taken as a tool for rapid degradation of xenobiotic compounds. Application of microbes as bio-inoculants for quality crop production has been emphasized by some authors. Conventional method of bioremediation using
hyper-accumulator tree species has been given proper weightage. The emerging role of nanotechnology in different fields has been discussed. The contents of book are organized in various sections which deal about microbial biodegradation, phytoremediation and emerging technology of nanocompounds in agriculture sector.

Chapter 18, which covers phytoremedation, acknowledges that environmental pollution with xenobiotics is a global problem and development of inventive remediationtechnologies for the decontamination of impacted sites are therefore of paramount importance.
Phytoremediation capitalizes on plant systems for removal of pollutants from the environment.  Phytoremediation is a low maintenance remediation strategy and less destructive than physical or chemical remediation.  Phytoremediation may occur directly through uptake,translocation into plant shoots and metabolism (phytodegradation) or volatilization (phytovolatilization) or indirectly through plant microbe-contaminant interactions within plant root zones(rhizospheres).  In recent years, researchers have engineered plants with genes that can bestow superior degradation abilities. Thus, phytoremediation can be more explored, demonstrated, and/or implemented for the cleanup of metal contaminants, inorganic pollutants, and organic contaminants.

Topics Covered

The 400-page, 20 chapter book covers many academic areas covered including, but are not limited to:

  • Bio-Fertilizers
  • Bioremediation
  • Microbial Degradation
  • Microorganisms
  • Organic Farming
  • Pesticide Biodegradation
  • Phytoremediation

 

 

Contaminated sites could pose issue for Saskatoon’s transit plan

As reported in the Phil Tank in the Saskatoon Star Phoenix, the city of Saskatoon has tested the soil at several locations where transit stations are planned for the bus rapid transit (BRT) system. The results of the tests will not be known until later this month, but Mayor Charlie Clark says contaminated sites, like former gas stations, pose a big issue for Canadian cities.

The testing took place along the proposed BRT red line, which is expected to run on 22nd Street on the west side of the river and on Eighth Street on the east side.

“Brownfields (contaminated sites) along some of these major streets are a real problem,” Clark told reporters Tuesday at city hall. “We have a lot of gas stations that have been abandoned, left there and the owners are just sitting on them and not allowing them to be sold and redeveloped.”

The CP railway crossing on 22nd Street, one of the main routes of the BRT system. (Google Maps)

Clark, who was promoting an event to gather residents’ input on the city’s various growth plans, said he would like to see clearer rules from the province and the federal government on contaminated sites.

The City of Saskatoon has limited tools to force sites to be sold or redeveloped or to compel owners to clean up contamination, he said.

“We frankly don’t think the taxpayers of Saskatoon should have to pay to clean up contaminated sites where somebody was operating a gas station or a fuel distribution site for many years, generating a profit off of it, and then leaving it as a barren and wasted piece of land,” Clark said.

The city’s brownfield renewal strategy is among a number of different planks in its overall growth strategy, which was featured at a community open house in early March.

Brownfield Renewal Strategy

Saskatoon’s Brownfield Renewal Srategy (“BRS”) states that abandoned, vacant, derelict, underutilized properties shouldn’t stop revitalization.  The strategy supports redevelopment of brownfield sites to maximize their potential and revitalize the main transportation corridors within the City.  The goal of the BRS is to create environmental guidance manuals, provide advisory services, and implement incentive programs to encourage brownfield redevelopment.

The City of Saskatoon sees the BRS as requirement for achieving the City’s target of achieving 50% growth through infill.

The BRS will create a suite of tools and programs designed to assist prospective developers and property owners with the environmental requirements associated with impacted and potentially impacted brownfields.

Mayor Clark noted Saskatoon and its surrounding region has been identified as the fastest growing metropolitan area in Canada, with 250,000 additional residents anticipated in the next few decades.

Lesley Anderson, the director of planning and development with the City of Saskatoon, talks renewal strategy

Are You an Early Adopter? The growth of novel contaminant delineation technology

by Kevin French, Vertex Environmental

In the 1920s researchers became interested in the sociology of exactly how rapidly advancing technologies were dispersed and then adopted by farmers.

By the 1960s a theory known as diffusion of innovation detailed the process of how, why, and at what rate any new technology is spread to a community.

A key group in a community are known as Early Adopters. These folks, representing an estimated 13.5% of the population, are the first to embrace new advances and allow a technology to gain an early foothold. Early Adopters may also enjoy a competitive advantage in the marketplace.

In this article, on an animated map you can see how a novel contaminant delineation technology has spread across Canada since 2011. Were you one of the Early Adopters back in 2011?

Vertex started with High Resolution Site Characterization (HRSC) during a pilot-scale trial back in 2011. The technology is now used country-wide and has even been adopted into the CCME Guidelines for delineationpractices.

The Diffusion of High Resolution Technology in Canada.

The Toronto waterfront was the site of our first use of HRSC technology in Canada back in April of 2011. Early Adopter clients understood that real-time field readings could eliminate multiple mobilizations with a drilling crew. The iterative process of a delineation program suddenly had, well, fewer iterations.

Take a look at the map below showing the growth and spread of HRSC across Canada:

The number of new clients adopting HRSC technology across Canada has also generally followed the same lifecycle curve as shown above. Here is the number of meters profiled per year for a 6 year period:


The number of clients and number of annual meters profiled has increased each year since 2011, with over 11 km profiled during 2016 alone! It is interesting that innovation adoption lifecycle still holds true after 50 years – even with incredible advances in new technology that couldn’t even have been predicted back then. These advances we see in modern technology are partly due to the enhancements we can now make to printed circuit boards. Software, found from Altium and other companies providing similar services, now allows us to edit electrics and improve them, meaning that technological products are always evolving.

As with anything new, explaining the advantages and benefits requires answering a lot of good questions. Here are a few of the most common that we encounter:

  1. Can HRSC Replace Laboratory Analysis?

Yes and No. A major advantage is the collection of on-the-fly information. Massive amounts of HRSC data is collected, quickly and cost-effectively. When combined with traditional Phase II Environmental Site Assessment (ESA) methods, they greatly enhance the understanding of presence, concentration and distribution of contamination in the subsurface. The rapidly collected data in turn reduce the number of field mobilizations for drilling and sampling and the number of samples required for laboratory analysis. Laboratory analysis is required to validate field contaminant concentrations detected by the HRSC instrumentation. In some cases it is even possible to produce a correlation between HRSC readings and laboratory analytical data, greatly simplifying the approach to accurate delineation of contamination in the field.

  1. Is this Technology Accepted Practice in Canada?

Often this question is phrased along the lines of “where have you used this?” The real meaning of the question: “is this an accepted technology”? HRSC technology was first developed in the United States and was actively deployed in the U.S for at least a decade before we brought it to Canada full time. However, common practice in the U.S. does not necessarily translate into accepted practice in Canada. And certainly not right away.

By the end of our first year in 2011, we had successfully deployed the HRSC tools at fifteen sites. As we approach the end of 2017, we have now used the technology at over 170 sites! Whatever industry you find yourself in, you’ll realise that pretty much everything relies on technology and is implemented in many places. As the future of work looks like it will rely heavily on technology, it makes sense to stay up to date with some aspects of it. Click right here to find out more regarding the relationship between businesses and technology.

Many of these are situated in Southern Ontario and Quebec. But our clients have also applied the technology extensively at sites from Goose Bay, Labrador to Cold Lake, Alberta to northern British Columbia, to Whitehorse, Yukon. Site types vary from corner gas stations, industrial manufacturing facilities, upstream oil and gas facilities, highway maintenance yards to Canadian Forces Bases. Along with this variety of sites the geologies that Vertex has had to profile have varied widely across Canada. Everything from tight silt tills to glacial sand and gravel deposits. Each geology presents its own unique challenges and Vertex has been able to tackle them all learning more and more, and expanding HRSC capabilities along the way. Being able to capture these data sets for clients across Canada has been quite a journey and we can’t wait to see where it leads us in the future!

  1. How Much Does it Cost?

The cost of this type of investigation is quite affordable when comparing the amount of data collected with the HRSC instruments vs the data collected with traditional investigation techniques (drilling and sampling). We have mobilized and completed cost-effective HRSC programs on both the east and west coasts and in the arctic of Canada. The HRSC technology is very affordable when your site investigation or delineation program would otherwise require multiple mobilizations and iterations of testing or when a high level of detail is required to understand subsurface site conditions. For detailed costing and estimating please feel free to contact us and we will be happy to help out and design a HRSC program that fits your site needs and budget.

  1. What is Coming Next?

The world of HRSC is constantly moving forward with new technology and tooling being invented and tested. Recently, Vertex deployed a dual Laser Induced Fluorescence (LIF) probe to complete an interesting site investigation, the first of its kind in Canada. The dual LIF probe housing both a TarGOST and UVOST unit was deployed in Ontario to further investigate a large development site in Toronto. This dual LIF probe was able to simultaneously detect petroleum hydrocarbon Light Non-Aqueous Phase Liquid (LNAPL) and Dense Non-Aqueous Phase Liquid (DNAPL) products! The data was then used to refine in-situ pilot-scale remediation activities in order to better account for subsurface contamination conditions at the site.

Stay tuned to see what comes next in the world of HRSC!

_______________________

About the Author

Kevin French, B.A.Sc., P.Eng., has 25 years of experience in environmental assessment and remediation. Kevin holds a Bachelor’s Degree from the University of Waterloo where he studied Civil and Environmental Engineering. Since that time, Kevin has been involved in the design and implementation of remediation programs relating to chlorinated solvents (including DNAPL), petroleum hydrocarbons (including LNAPL), PAHs/coal tar, heavy metals, etc., at hundreds of sites across Canada.

This article was first published in Vertex Environmental Inc. Newsletter.

Mining company working with environmentalists to clean up old mining sites

As reported by the CBC, Calgary-based mining company Margaux Resources has announced a plan to clean up old tailings sites by using new mining technologies to extract the remaining minerals.

Tailings have long been known to cause environmental damage including loss of animal habitats and contamination of soil, groundwater and waterways.

Margaux has partnered with the Salmo Watershed Sreamkeepers Society — a non-profit engaged in protecting and maintaining the Salmo River in southeastern B.C.— for the remediation project.

“What we have here is an industry leader that is sympathetic and realizes the situation that historic mining efforts have left,” said Gerry Nellestijn, the coordinator of the Salmo Watershed Streamkeepers Society.

Margaux president and CEO Tyler Rice says the benefits are two-fold as the company hopes to profit from the extractions made.

“When this material was mined historically, they didn’t have 100-percent recovery of the elements … with advancements of technology we feel there is an opportunity to potentially extract the materials that weren’t fully recovered,” Rice said.

The first site scheduled for extraction and remediation is the Jersey-Emerald mine, located just outside of Salmo B.C., and once a large producer of tungsten.

Aerial view of the Jersey-Emerald tungsten tailings pile

Margaux has submitted an application to both the Ministry of Environment and the Ministry of Energy and Mines to take a bulk sample from the Jersey-Emerald site to, “assess the viability of remediating the tailings site and the potential to economically produce a marketable mineral concentrate,” according to a news release issued earlier this month.

Rice admits the site will likely not be fully remediated for a couple of years.

Meanwhile, the Salmo Watershed Society says there are over 40 tailings sites in the area and they are working to assess them.

“It’s an approach to actually go out there and assess tailings, size them, try to figure out what the pollution pathways may be, what the constituents of that tailing might be and look for remediation efforts that would be easy to implement,” said Nellestijn.

And both partners seem to be happy with the current government’s responsiveness to their project.

“We have a strong government that may very well be interested in participating with this kind of movement — it’s been a long time coming,” Nellestijn said.

Proposed U.S. Infrastructure Plan Supports Reuse of Brownfields and Superfund Sites

The Trump Administration released its ambitious $1.5 trillion infrastructure plan on Feb. 12, 2018 – a plan that includes many provisions focused upon encouraging the reuse of contaminated brownfields and Superfund sites.  On the same day, the Administration released its proposed budget for Fiscal Year (FY) 2019, which called for a 23 percent cut from FY 2018 levels in the U.S. Environmental Protection Agency’s (U.S. EPA) budget.  The U.S. EPA also released its final Strategic Plan for 2018-2022, emphasizing a focus upon the agency’s core mission, cooperative federalism and the rule of law.  What does all of this mean for the redevelopment of contaminated sites in the United States?

Infrastructure Plan

 Financial Incentives

The infrastructure program would establish an Incentives Program that could be very beneficial for state and local reuse of contaminated sites.  Up to $100 billion would be set aside for the Incentives Program, which would fund a wide range of projects, including brownfields and Superfund sites, stormwater facilities, wastewater facilities, flood control, water supply, drinking water supply and transportation facilities.  The funds would be divided among the U.S. Department of Transportation (U.S. DOT), the U.S. Army Corps of Engineers and the U.S. EPA.  The infrastructure plan suggests criteria by which applications would be evaluated, with substantial weight (70 percent) being given to obtaining commitments for non-federal revenue for sustainable, long-term funding for infrastructure investments and for operations, maintenance and rehabilitation. In order to motivate performance, the grant recipient would need to enter into an infrastructures incentives agreement with the lead federal agency and to agree to achieve progress milestones. If the milestones are incomplete after two years, the agreement will be voided unless there is good cause to extend the agreement for another year. No individual state could receive more than 10 percent of the total amount available under the Incentives Program.

Additional funds would be set aside for a Rural Infrastructure Program, including funds for brownfields and land revitalization as well as stormwater and wastewater facilities, drinking water, flood risk management and water supply.  States would be required to develop a comprehensive rural infrastructure investment plan (RIIP). Some funds would also be provided for tribal infrastructure and the infrastructure needs of U.S. territories.

Superfund, Brownfield, and RCRA Sites in the U.S. (U.S. EPA, 2013)

Yet another category of funds would be set aside for the Transformative Projects Program – projects that are likely to be commercially viable but have unique technical and risk characteristics that might deter private sector investment.  Projects that could be covered by this program could fall within commercial space, transportation, clean water, drinking water, energy or broadband.  A total of $20 billion would initially be set aside for this program, with the U.S. Department of Commerce chairing the program.  Funds could be used for demonstration, project planning, capital construction, or all three.  If a project receives financial assistance for capital construction, it would be expected to enter into a value share agreement with the federal government and would be required to publish performance information upon achieving milestones and finishing the project.

The federal government would also dedicate $20 billion from existing federal credit programs, and broaden the use of Private Activity Bonds, to assist complex infrastructure projects. These sources of funding would include: the Transportation Infrastructure Finance and Innovation Act (TIFIA); Railroad Rehabilitation and Improvement Financing (RRIF); Water Infrastructure Finance and Innovation Act (WIFIA); Rural Utility Service (RUS) lending; and Private Activity Bonds (PABs).

The Administration would amend TIFIA to make loans and credit assistance available for other types of projects – such as passenger terminals, runways and related facilities at non-federal waterways and ports as well as airport projects – until FY 2028.  Similarly, the Administration is proposing to amend RRIF to cover the credit risk premium for short-line freight and passenger rail project sponsors, thereby incentivizing more project sponsors to apply for RRIF credit assistance.  It would also like to amend WIFIA (33 U.S.C. 3905) to include flood mitigation, navigation and water supply, and to eliminate the requirement that borrowers be community water supply systems.  The Administration would like to make WIFIA funds available for remediation of water quality contamination by non-liable parties.  It would remove the current spending limit of $3.2 billion, which was put in place when WIFIA was a pilot program, and would amend the restriction upon using WIFIA funds to reimburse costs incurred prior to loan closing.

Liability Relief

The Administration proposes establishing a Superfund Revolving Loan Fund and Grant Program and authorizing sites that are on the National Priorities List (NPL) to be eligible for brownfields grants.  It would amend the Small Business Liability Relief and Brownfields Revitalization Act in order to do so. This would allow non-liable parties to tap into a low-interest source of funds to perform removals, remedial design, remedial action and long-term stewardship.  The program would be targeted toward portions of NPL sites that were not related to the response action; to portions that could be parceled out from the response action site; to areas where the response action was complete but the site had not yet been delisted; or to areas where the response action was complete but the facility was still subject to a consent order or decree.

The Administration would also propose additional liability protections to states and municipalities acquiring contaminated properties in their capacity as sovereign governments by clarifying and expanding the current liability protections in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 101(20)(D).  These governmental entities would be eligible for grants and would be protected from liability, so long as they meet the obligations imposed upon bona fide prospective purchasers (BFPPs), including exercising appropriate care with regard to releases, so long as they did not contribute to the contamination.

The Administration would also give EPA express authority to enter into administrative settlement agreements with BFPPs or other third parties who wish to clean up and reuse contaminated Superfund sites.  This could include partial and early remedial actions.

The Administration’s infrastructure proposal would encourage greater flexibility in funding and execution requirements, as infrastructure needs should be integrated into cleanup design and implementation. Better integration would allow third-party financing and promote site reuse.

Expedited Permitting

The Administration proposed a “one agency, one decision” environmental review structure, in which a single federal lead agency would complete the environmental review within 21 months and issue either a Finding of No Significant Impact (FONSI) or Record of Decision (ROD).  The lead agency would then have another three months to issue any necessary permits, including state permits issued under federal law pursuant to a delegation of authority.  The agency would not be required to evaluate alternatives outside the scope of the agency’s authority or the applicant’s capability.

The Council on Environmental Quality (CEQ) would be directed to revise its regulations to streamline the National Environmental Policy Act (NEPA) process to increase the efficiency, predictability and transparency of environmental reviews.  The Administration would eliminate what it considers to be duplicative reviews by EPA under Section 309 of the Clean Air Act.  It would also encourage each federal agency to increase its use of categorical exclusions (CEs) and would allow any federal agency to use a CE established by another federal agency without undergoing the CE substantiation and approval process.

The Administration would also recommend amending the law to allow federal agencies to accept funds from non-federal entities to support review of permit applications and other environmental documents to expedite project delivery and defray costs.

The Administration would also make changes under the Clean Water Act to eliminate redundancy and duplication. For example, it would allow federal agencies to select nationwide permits without the need for additional Army Corps review. It would authorize the Secretary of the Army to make jurisdictional determinations under the Clean Water Act and would eliminate EPA’s ability to veto a Section 404 permit under Section 404(c). It would allow the same document to be used for actions under Sections 404 and 408 of the Clean Water Act.  The Administration would lengthen the term of a National Pollutant Discharge Elimination System (NPDES) permit from five years to 15 years and provide for automatic renewals.

Similar changes would be made under the Clean Air Act. For example, the Administration would amend the Clean Air Act so that state departments of transportation (state DOTs) and metropolitan planning organizations (MPOs) would need only to demonstrate conformity to the latest National Ambient Air Quality Standards (NAAQS), rather than to old and new standards for the same pollutant. Similarly, MPOs would be allowed to demonstrate conformity in a newly designated non-attainment area within one year after EPA has determined that the emissions budget is adequate for conformity purposes.

The Administration proposes eliminating overlapping Section 4(f) review by the U.S. Department of the Interior, U.S. Department of Agriculture and U.S. Department of Housing and Urban Development before the DOT can be authorized to use parklands or historic sites unless there is no prudent or feasible alternative. This process can add an extra 60 days to the project development review process, even when those agencies have little direct involvement in the project. Another layer of review is required under Section 106 of the National Historic Protection Act (NHPA) for historic properties that is not aided by the Fixing America’s Surface Transportation (FAST) Act. The Administration recommends that an action taken under a Section 106 agreement should not be considered a “use” under Section 4(f), therefore eliminating some duplication and delay.

The Administration would expand the NEPA assignment program to allow DOT to assign, and states to assume, a broader range of NEPA responsibilities, including project-level transportation level conformity determinations as well as determinations regarding flood plain protections and noise policies to make the NEPA assignment program more efficient.

Also proposed by the Administration is a pilot program with up to 10 pilot sites that would be expected to meet performance standards and enhanced mitigation, in lieu of complying with NEPA and relevant permits or other authorizations.

The Administration also proposed judicial reforms, including limiting injunctive relief to exceptional circumstances and revising the statute of limitations to 150 days (rather than a statute of limitations of up to six years).

Proposed Budget

The Administration also released its “Efficient, Effective, Accountable: An American Budget” on Feb. 12, 2018, in which it proposed a 23 percent cut in EPA’s budget compared to FY 2018.  The White House added $724 million to EPA’s budget in a supplemental request, including $327 million for the Superfund program and $397 million for State and Tribal Assistance Grants for Clean Water and Drinking Water State Revolving Funds (SRFs).  At the same time, the Administration proposed cuts of 16 percent in grants to states (to $2.9 billion) and proposed cuts of 35 percent in funding to state and local agencies for air quality management (to $152 million).  The Administration requested $151 million for enforcement at Superfund sites and $20 million for the WIFIA program.

U.S. EPA’s Final Strategic Plan

The FY 2018-2022 EPA Strategic Plan, also released on Feb. 12, 2018, continued to emphasize three main goals: the agency’s Core Mission, Cooperative Federalism, and the Rule of Law and Process.  Among its two-year priority goals, The U.S. EPA intends to make an additional 102 Superfund sites and 1,368 brownfields sites ready for anticipated use (RAU) by Sept. 30, 2019. The U.S. EPA intends to use a “Lean” management system designed to deliver measurable results that align with the Strategic Plan.

Objective 1.3 is particularly relevant to the issues discussed above with regard to redevelopment of brownfields and Superfund sites. Objective 1.3 is to revitalize land and prevent contamination by providing better leadership and management to properly clean up contaminated sites to revitalize and return the land back to communities.  The strategic plan identifies both strategic measures and strategies for achieving these goals. First, it announces the number of sites the agency intends to have RAU by Sept. 30, 2022:

  • 255 additional Superfund sites
  • 3,420 additional brownfield sites
  • 536 additional Resource Conservation and Recovery Act (RCRA) corrective action facilities
  • 56,000 additional leaking underground storage tank (LUST) sites meeting risk-based corrective action standards

The U.S. EPA then announced the strategies by which it intends to achieve these goals, including the use of new technologies and innovative approaches; prioritizing sites that have been on the NPL for five years or more without significant progress; and reprioritizing resources to focus on remedial actions, construction completions, ready for reuse determinations and NPL site deletions.  The U.S. EPA will award competitive grants for the assessment, cleanup and reuse of brownfields sites, and will focus on sites subject to RCRA corrective action and LUST sites.  The U.S. EPA will review more than 12,500 risk management plans (RMPs) to help prevent releases and train RMP inspectors, and it intends to update its RCRA hazardous waste regulations to protect the health of the 20 million people living within 1 mile of a hazardous waste management facility. It will also issue polychlorinated biphenyls (PCB) cleanup, storage and disposal approvals, since this work cannot be delegated to states or tribes.  The U.S. EPA acknowledged that many of the sites that remain on the NPL are large, more complex and may contain multiple areas of contamination, and may contain emerging contaminants such as per- and polyfluoroalkyl substances (PFAS).  The U.S. EPA promised to engage stakeholders at all levels in making cleanup and land revitalization decisions.

As part of Objective 3.1, compliance with the law, the U.S. EPA stated that it would continue to follow an “enforcement first” approach under CERCLA to maximize the participation of responsible parties to perform and pay for cleanups. It indicated it would focus its resources on the highest priority sites that present an immediate risk to human health and the environment, and return these sites to beneficial use as expeditiously as possible.  It will also use advanced monitoring technologies to ensure compliance and work with the Environmental Council of the States (ECOS) and state associations to modernize ways to improve compliance.

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About the Authors

Amy L. Edwards is the co-chair of the firm’s National Environmental Team, as well as its Military Housing and Installations Redevelopment Team. She is a partner in the firm’s Public Policy & Regulation Group, which has been ranked among the top law and lobbying firms in Washington, D.C., by numerous publications. Ms. Edwards has been recognized as a leading environmental lawyer for several years by Chambers USASuper Lawyers and Best Lawyers. After holding several other leadership positions, she will become the Chair of the American Bar Association’s Section of Environment, Energy and Resources (SEER), the pre-eminent national organization representing lawyers in these fields, in 2018-2019.

Nicholas Targ is a San Francisco attorney with more than 20 years of experience assisting clients in the public and private sectors efficiently achieve their land use, environmental and policy goals. He co-chairs Holland & Knight’s national environmental team. Mr. Targ’s practice focuses on complex redevelopment projects, environmental compliance and government advocacy. His representative work includes strategic legal advice on brownfields redevelopment, Superfund compliance, and state and federal grant and policy advocacy. Mr. Targ has successfully advocated for infill funding and policy initiatives on behalf of public, private and nonprofit coalition clients.

This article was first published on the Holland & Knight LLP website.

CHAR Technologies Acquires The ALTECH Group

The ALTECH Group of companies (“Altech”) and CHAR Technologies Ltd. (“CHAR”) are now working together!  CHAR Technologies Ltd. (TSXV:YES) has acquired The ALTECH Group in an effort to expand the offering of cleantech environmental technologies, including SulfaCHAR and CleanFyre.  The ALTECH Group provides environmental engineering solutions to industry in North America in the areas of air pollution control, industrial energy efficiency, and process water recycling.  The new combined entity provides cleantech solutions to industrial environmental engineering challenges.

CHAR currently produces SulfaCHAR®, a bio organic product, similar to activated carbon, competing on cost and performance with other air pollution control solutions.  SulfaCHAR is specially designed to remove hydrogen sulfide from renewable natural gas (ie. biogas from anaerobic digesters and landfill gas, as well as other contaminants from industrial air emissions).  CleanFyre® is an exciting new bio-coal product that is a cost effective substitute with similar energy potential to coal as a fossil fuel.  The major advantage of bio-coal is that it is Greenhouse Gas (GHG) neutral.  Companies replacing coal with CleanFyre will be eligible to earn GHG Credits in the fight for Climate Change.  This is an important product advancement in the fight to significantly reduce Greenhouse Gases.

 

The merged entity has over 30 years of experience throughout North America in delivering full-service engineering and turnkey technology installations to corporations interested in sustainable and cost effective solutions.  As the holder of a number of patents, ALTECH and CHAR have unique, cost effective solutions for effluent air and water problems.  The combined entity has the ability to design, fabricate, and install leading edge cleantech solutions, solving complex environmental problems in very cost effective ways.  As a group that is constantly innovating, this partnership of cleantech firms continues to develop and apply world class solutions that make sense from a cost savings point-of-view.

 

 

 

Contact:

 

Mr. Alex Keen:   [email protected]

Mr. Andrew White:   [email protected]

 

Recent Trends in the Selection of Remedies at Superfund Sites

The U.S. Environmental Protection Agency (U.S. EPA) recently issued the 15th edition of its Superfund Remedy Report (SRR).  The report is a compilation of over 300 remedies selected in decision documents for contaminated sites on the National Priorities List (NPL) from October 2011 to September 2014.

Summary

Remedies included in the document relate to soil, groundwater, and sediment.  The remedies were counted by specific technology or approach, and also grouped into categories, such as treatment, on-site containment, off-site disposal, monitored natural attenuation (MNA), and institutional controls (ICs). The study analyzed remedies by media (i.e., soil, sediment, and groundwater), and the types of contaminants of concern (COCs) in those media. The evaluation also included vapor intrusion mitigation remedies.

The SRR compiles data on remedies and presents separate analyses for contaminants overall and contaminants in select media (soil, sediment and groundwater). This edition also includes a separate analysis of remedy and response action data for large sediment sites.

Dredging PCB-Contaminated sediment on the Hudson River

For the majority (78 percent) of the 1,540 Superfund sites with decision documents available, treatment has been selected, often in combination with other remedies. Most of these sites have more than one contaminated media, most frequently groundwater and soil. Most sites also have different types of contaminants of concern (COCs): more than half of sites address volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs) and metals, while a quarter of sites address two of these groups.

For FYs 2012 to 2014, remedies were selected in 308 decision documents, including 242 RODs and ROD Amendments, and 66 ESDs with remedial components. Of the 308 decision documents, 188 (61 percent) include a remedy for source materials (such as soil and sediment) and 160 (52 percent) for groundwater. Remedies were also selected for soil gas and air related to vapor intrusion.

Source Remedies

For this three-year period, nearly half of decision documents with source remedies include treatment. A quarter of all source decision documents include in situ treatment. Soil vapor extraction, chemical treatment, and in situ thermal treatment are the most frequently selected in situ treatment technologies for sources with soil being the most common source medium addressed. Physical separation, recycling, and solidification/stabilization (S/S) are the most common ex situ treatment methods. Metals, polycyclic aromatic hydrocarbons (PAHs) and halogenated VOCs are the COCs most commonly addressed.

Table 1: Summary of Source Control Remedies

Treatment
• Chemical, biological, or physical means to reduce toxicity, mobility, or volume of contaminated source media

• Can be either in situ or ex situ

• examples include chemical treatment and in situ thermal treatment

On-site containment
• Examples include the use of caps, liners, covers, and landfilling on site
Off-site disposal
• Includes excavation and disposal at an off-site facility
Monitored natural attenuation (MNA)
• Reliance on natural processes

• Natural attenuation processes may include physical, chemical, and biological processes

Monitored natural recovery (MNR)
• Reliance on natural processes to reduce risk from sediments

• Natural attenuation processes may include physical, chemical, and biological processes

Enhanced monitored natural recovery (EMNR)
• Combines natural recovery with an engineered approach for sediments

• Typically includes placing a thin layer of clean sediment to accelerate the recovery process

Institutional controls
• Nonengineered instruments, such as administrative and legal controls, that help minimize the potential for human exposure to contamination and protect the integrity of the remedy

• Examples for source media include land use restrictions and access agreements

Other
• Source control remedies that do not fall into the categories of source control treatment, on-site containment, off-site disposal, MNA, MNR, EMNR, or engineering controls

• Examples include wetlands replacement and shoreline stabilization

Sediment Remedies

Of the 188 recent source decision documents, 39 include a remedy for sediments. Most of the sediment decision documents (87 percent) include dredging, excavation, off-site disposal or on-site containment as part of the selected remedy. Some treatment was also selected — for example, in situ amended caps and ex situ and in situ S/S. Examples of other remedies include wetlands replacement and enhanced or monitored natural recovery (EMNR or MNR). Two-thirds of the sediment decision documents include institutional controls (ICs). Metals, PAHs and polychlorinated biphenyls are the COCs most frequently addressed.

EPA also analyzed newly acquired remedy and response action data on the largest sediment sites, known as Tier 1 sediment sites. The data include 112 actions for 66 sites. Some of these actions have progressed to design or implementation. Most remedies for these sites include dredging and excavation (84 percent), 48 percent include residual caps, and 29 percent include engineered caps designed to isolate contaminants from the waterway. A quarter of the Tier 1 sites include MNR and 18 percent include EMNR.

The U.S. EPA analyzed the contaminants of concern (COCs) addressed by sediment remedies in recent decision documents.  Over three-quarters of these documents include metals. PCBs and PAHs are the next most frequent categories of COCs with 44 percent each, as seen in the Figure below.

Figure 1: Detailed COCs in Decision Documents with Sediment Remedies

Groundwater Remedies

For the 160 groundwater decision documents signed in FYs 2012 to 2014, the groundwater remedies continue to be primarily a mix of in situ treatment, pump and treat (P&T), and monitored natural attenuation; most also include ICs. The use of in situ groundwater treatment continues to rise and is now selected in over half of groundwater decision documents. Of these, bioremediation and chemical treatment remain the most frequently selected. The majority of in situ bioremediation remedies specify anaerobic bioremediation, and more than half of chemical treatment remedies specify in situ chemical oxidation. The selection of P&T in groundwater decision documents has decreased significantly since the early 1990s and reached its lowest, 17 percent, in FY 2014. Containment technologies (vertical engineered barriers such as slurry walls) were selected at a few sites. By far, halogenated VOCs (primarily chlorinated VOCs) are the most common type of groundwater COC, addressed in 72 percent of recent groundwater decision documents.

Table 2. Summary of Groundwater and Vapor Intrusion Remedy Categories

Groundwater
In situ treatment
• Treatment of groundwater in place without extraction from an aquifer

• Examples include in situ chemical oxidation and in situ bioremediation

Pump and treat (P&T)
• Pumping of groundwater from a well or trench, followed by aboveground treatment

• Examples of aboveground treatment include air stripping and granular activated carbon

Monitored natural attenuation (MNA)
• Reliance on natural attenuation processes

• Natural attenuation processes may include physical, chemical, and biological processes

Containment
• Containment of groundwater using a vertical, engineered, subsurface, impermeable barrier
Institutional controls
• Examples include drilling restrictions and water supply use restrictions
Alternative water supply
• Examples include installing new water supply wells, providing bottled water or extending a municipal water supply
Other
• Groundwater remedies that do not fall into the categories of in situ treatment, P&T, MNA, containment, institutional controls, or alternative water supply

• Examples include drainage/erosion control and wetlands restoration

Vapor intrusion
Mitigation
• Mitigation of soil gas or indoor air to reduce exposure to vapor contamination in buildings

• Examples include active depressurization technologies and passive barriers

Institutional controls
• Examples include land use restrictions and vapor intrusion mitigation for new buildings

Vapor Intrusion Remedies

EPA selected vapor intrusion mitigation for existing structures in nine of the recent decision documents, and ICs for either existing structures or future construction in 34 of these documents. Some ICs restrict the future use of structures to avoid vapor intrusion exposure and others require the installation of mitigation systems as part of future construction. Active depressurization was the most common mitigation method specified, followed by passive barriers and subslab ventilation systems.

Combined and Optimized Remedies

In this report, the U.S. EPA also discusses the use of combined remedies and optimization reviews. The combined remedy highlights provide examples of recent decision documents where remedies are combined spatially or in sequence. The optimization highlights provide examples of how optimization efforts have informed remedy decisions in recent decision documents.

The remedy and site information provided in this report can help identify program needs for expanded technical information and support. For example, growing use of in situ groundwater technologies suggests the need for additional knowledge and support associated with those technologies. This analysis also provides information of value to stakeholders including technology developers; consulting and engineering firms; and federal, state, and tribal remediation professionals. In particular, developers and service providers can gain insight into the demand for specific remedial technologies.

 Conclusions

The analysis of most recent Superfund decision documents shows continued selection of a full range of treatment, containment, and disposal technologies and approaches for both source material and groundwater. Selection of some remedies is increasing in frequency (such as in situ groundwater technologies), while others are decreasing (such as pump-and-treat). Remedial approaches, including in situ bioremediation, are often combined in time or space to address different areas of the site or applied sequentially. Remedy optimization and reevaluation has resulted in changes to previously selected or implemented cleanup approaches. Overall, most Superfund sites contain different types of COCs: more than half of sites with remedies address VOCs, SVOCs, and metals/metalloids, and almost a quarter of sites address two of these groups.

 

 

Successful Demonstration of Enhanced Soil Vapour Extraction

Researchers at Integrated Science & Technologies Inc. recently presented the findings from a field demonstration project that showed that enhanced soil vapour extraction significantly reduced the concentration of 1,4-Dioxane in soil.

1,4-Dioxane is often called simple dioxane because the other dioxane isomers (1,2- and 1,3-) are rarely encountered.  1,4-Dioxane is a synthetic industrial chemical that is completely miscible in water.  It is used as a solvent for a variety of applications.  1,4-Dioxane is a likely contaminant at many sites contaminated with certain chlorinated solvents (particularly 1,1,1-trichloroethane [TCA]) because of its widespread use as a stabilizer for chlorinated solvents

With respect to remediation, some 1,4-dioxane can be removed from pore water found in the vadose zone (unsaturated zone) in the subsurface by conventional soil vapor extraction (SVE), remediation is typically inefficient.  SVE extracts vapors from the soil above the water table by applying a vacuum to pull the vapors out.

SVE is inefficient at removing 1,4-dioxane from pore water in the subsurface vadose zone.  1,4-dioxane has a low Henry’s Law constant at ambient temperature.  This means that there is a low concentration of dissolved 1,4-dioxane gas proportional to its partial pressure in the gas phase.

To enhance the extraction for 1,4-dioxane in the subsurface, the researchers used heated air injection and more focused SVE extraction (XSVE).  The pilot teste was conducted at the former McClellan Air Force Base located in the North Highlands area of Sacramento County, 7 miles (11 km) northeast of Sacramento, California.

Soil Vapor Extraction unit at former McClellan Air Force Base, Calif. (U.S. Air Force Photo by Scott Johnston)

The pilot test consisted for four peripheral heated air injection wells of the XSVE system surrounded a 6.1 m x 6.1 m x 9.1 m deep treatment zone with a central vapor extraction well.

Soil temperature measurements were taken during the pilot test.  Soil temperatures reached as high as ~90°C near the injection wells after 14 months of operation and flushing of the treatment zone with ~20,000 pore volumes of injected air.  Results post treatment showed dioxane reductions of ~94% and ~45% decrease in soil moisture.  See additional information in slides at http://www.contaminantssummit.com/images/presentations/3_RobHinchee.pdf .

Who is Charge of Harbour Clean-ups in Ontario?

As reported by the CBC, Environment and Climate Change Canada (ECCC) does not consider itself as the lead for the clean-up of Hamilton Harbour or Thunder Bay harbour.  ECCC says, while it is leading an ongoing harbour cleanup in Hamilton, it’s not a role the federal agency usually assumes.

That comes as proponents of cleaning up historical pollution in the harbour in Thunder Bay, Ont., try and sort out who is responsible for spearheading similar efforts in the northwestern Ontario city.

“If your question is, does it need a champion? It absolutely does,” Hamilton Mayor Fred Eisenberger said of the importance that an organization with jurisdiction over a polluted site push for a cleanup. “It needs one organization to keep pushing it along.”

“If it continues to be work that is just secondary work for someone off the corner of their desk, then it’s going to be a long, hard, arduous process.”

Efforts to clean up historical industrial pollution at the Randle Reef site in Hamilton’s harbour date back at least 15 years, said Eisenberger, who also used to be the chair of the board for the Hamilton Port Authority.  For years, he said, the port effectively served the lead agency role, coordinating local stakeholders and senior levels of government to move the project forward.

Environment Canada took the reins well into the project’s lifespan, according to Eisenberger and a spokesperson with the federal agency, and only after the involvement of the Hamilton port — who owns the harbour bed at Randle Reef.

In Thunder Bay, determining who should be that advocate has been difficult; the water lots where 400,000 cubic metres of mercury-contaminated pulp fibre sit in the harbour’s north end are owned by Transport Canada but administered by the Thunder Bay Port Authority.

Transport Canada has told CBC News spearheading a cleanup is up to the port, while port officials say they’ve been told by Transport Canada to advise on — not lead — remediation efforts.  The port has pointed to Environment Canada as the most appropriate lead agency, citing its role in Hamilton.

Approximate Area of Contaminated Sediment in Thunder Bay Harbour

‘No standard model’

Just because Environment Canada takes a leadership role in one project doesn’t necessarily mean it will in all cases, a spokesperson with the agency said.

“There really is no standard model for remediating contaminated sites other than that governments try to apply, where possible, the polluter-pay principle,” Jon Gee, Environment Canada’s manager of the Great Lakes area of concern wrote in an email to CBC News.

In Thunder Bay, the industrial companies largely responsible for the legacy pollution no longer exist.

Environment Canada’s lead role in Hamilton was the result of “a long negotiation between the Government of Canada and the other organizations,” Gee wrote. “It is not a role that the Department usually undertakes.”

The jurisdictional confusion in Thunder Bay has caught the attention of at least one legislator in the area.  Officials with the office of Thunder Bay-Superior North MP Patty Hajdu said she has met with members of the Thunder Bay Remedial Action Plan’s public advisory committee and that she will also discuss the matter with the federal ministers of transport and the environment.

Construction of the Randle Reef cleanup project in Hamilton Harbour

Gee said Environment Canada “remains committed” to working with government and other stakeholders on the project.

In Hamilton’s case, funding for the $139 million Randle Reef project is being split among the federal and provincial governments, as well as Hamilton, Burlington, the Hamilton Port Authority and Stelco, a steel company based in Hamilton. It’s expected to be complete in 2022.

In Thunder Bay, a number of remediation options were presented in 2014 to the public, with feedback going into a report.  Environment Canada has said no preferred option was identified because there is no lead agency on the project. Cost estimates at the time ranged anywhere from $30 million to $90 million.

Status of Hamilton Harbour Clean-up

As reported in the Hamilton Spectator, Hamilton Harbour still has an undetermined number of years to go before it can meet water quality and ecological standards acceptable to the International Joint Commission.  The Canada/U.S. bilateral agency that oversees cross-border water issues said in a statement this week that — after three decades — it is growing restless about the slow pace of Great Lakes water improvements on both sides of the border.

“The IJC identifies specific gaps in achieving the human health objectives … for drinkable, swimmable and fishable waters, and recommends that the governments set an accelerated and fixed period of time for effectively achieving zero discharge of inadequately treated or untreated sewage into the Great Lakes,” the agency says.

More than 30 years ago, the commission deemed 43 “areas of concern” on the Great Lakes — including Hamilton Harbour — and only seven sites have so far been delisted, three of which are in Canada.

Two big projects currently underway in Hamilton harbour are expected to lead to major improvements in its water quality. The first is the ongoing work encapsulating the highly toxic coal tar blob at Randle Reef. The Randle Reef Contaminated Sediment Remediation Project is scheduled for completion in 2022 at a total cost of $138.9 million spread out over three phases.

The other ongoing big-ticket item is Woodward Avenue Wastewater Treatment Plant, which is in the second year of a five-year, $340-million upgrade that will raise treatment to a modern tertiary level. This is expected to dramatically reduce discharges into the bay with most notably a reduction of 65,000 kilograms of phosphorus per year.

Status of Thunder Bay Harbour Clean-up

As reported in TB News Watch, the recommendations in a clean-up report of mercury in Thunder Bay, Ontario harbour have yet to be acted upon.  It has been more than three years since a consultant’s report identified options for the management of 400,000 cubic metres (14 million cubic feet) of mercury-contaminated sediment.

Thunder Bay is located at the northwest corner of Lake Superior and has a population of approximately 110,000.

The source of the mercury in the sediment was industrial activity along Thunder Bay’s north harbour for over 90 years including pulp and paper mill operations.  The sediment is contaminated with mercury in concentrations that range from 2 to 11 ppm at the surface of the sediment to 21 ppm at depth and ranging in thickness from 40 to 380 centimeters and covering an area of about 22 hectares (54 acres).

The preferred solution in the consultant’s report was to dredge the sediment and transfer it to the Mission Bay Confined Disposal Facility (CDF) at the harbour’s south end.  That came with an estimated cost of $40 million to $50 million, and was considered the best choice based on factors such as environmental effectiveness and cost.  The consultants also looked at other options, including building a new containment structure on the shoreline adjacent to the former Superior Fine Papers mill.