Site Closure Strategies: Reducing Remediation Liabilities & Costs

Industrial companies face the daunting task of managing investigations and clean-ups at thousands of contaminated properties. In staying abreast of new technology and ever-evolving regulatory programs, companies must address many challenges involving regulations, technologies, and expenses. To successfully manage the costs and risks for each project, it is important to:



1) Focus on the ultimate goal of regulatory closure, using an integrated site closure (ISC) approach;

2) Periodically revisit and re-assess the design basis for the remediation strategy, with a remediation system evaluation (RSE), and

3) Carefully manage and control operations and maintenance (O&M) costs and performance.



Integrated Site Closure (ISC)

Integrated site closure (ISC) refers to the seamless integration and delivery (either by self-performing or by subcontracting) of the chain of remediation activities needed to achieve “regulatory closure” at contaminated properties. These activities include: agency negotiation, site investigation, risk assessment, feasibility evaluation, design engineering, remediation, operation and maintenance, and monitoring. In essence, ISC starts with the end in mind.



Recognizing the interrelation- ships of the steps of the remediation process, an ISC approach combines assessment and remediation in a comprehensive site closure strategy to develop a more responsive, accurate, and cost-effective solution than can be achieved by a traditional remediation approach. ISC projects often involve a multi-disciplinary team of scientists, engineers, and regulatory experts working on agency negotiations, site investigation, risk assessment, feasibility evaluation, design engineering, remediation, and the operation and maintenance of hazardous waste sites — all in order to move the project steadily toward the goal of efficient site closure.



ISC Case Study: Saving $165K While Turning a Brownfields Green

ENSR’s ISC approach saved The Fort James Company time and money during the closure of a former paper-manufacturing site that had operated as a mill for over 100 years in a historic area of wetlands and floodplain in New Jersey. Over many years of operation, the buildings, nearby soils, and riverbanks were contaminated with PCBs and, to a lesser degree, heavy metals. ENSR worked closely with the client, regulatory agencies, and the NJ Historic Society from the initial assessments through the final construction, successful closure, and disposition of the property to the NJ Green Acres Program.



According to a Fort James project manager, “There were many key steps in this project that resulted in cost avoidances/reductions and the turn-key approach ENSR provided to us for the project..kept the cost down and the production up on the site.” In a key cost-saving step, the ENSR ISC team conducted baseline ecological and human health risk assessments for Alternative Cleanup Criteria documentation, and used these findings to successfully negotiate site-specific alternate clean-up standards with the NJ Department of Environ-mental Protection. ENSR also worked closely with the NJ Historical Society to preserve the building footprint and foundations; this kept the project schedule on-track and resulted in additional savings.



The bottom line: ENSR’s ISC team saved The Fort James Company $165,000 in remediation costs, and kept the project schedule on track.



Remediation Systems Evaluation

A key component of ISC is a Remediation Systems Evaluation (RSE). An RSE is a proven strategy to help businesses save significant money and time at remediation sites. In addition, RSEs help companies improve the effectiveness of their clean-up plan, reduce their liabilities, and achieve site closure. These reviews are crucial, because even a five-year-old remediation program may no longer be the most cost-effective strategy, due to changes in operating and monitoring requirements, si