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Remediation Report Preparation:

Among Hanover Environmental Services, Inc.'s areas of specialty is the assessment and remediation of soil and water pollution associated with a variety of pollution sources. Hanover Environmental Services, Inc., has managed the clean-up of hundreds of contaminated sites, including underground storage tanks (UST), lead, dissolved solvent plumes, industrial and agricultural waste dump sites, and burn-dump sites. We have a proven clean-up track record for clean-up and have completed the successful closure, per State agency requirments, of dozens of polluted sites.

In addition, Hanover Environmental Services, Inc.'s geologists and project managers have extensive experience in meeting the requirements for documenting and reporting clean-up activities, including the extensive requirements of the State Water Resources Control Board (SWRCB) Underground Storage Tank Cleanup Fund Program (Fund).

All clean-up projects require the preparation of a variety of studies and technical reports documenting the assessment and clean-up process. Hanover Environmental Services, Inc. conducts the technical analyses for these reports, prepares all appropriate permitting and documentation, and compiles the reports for submittal to the appropriate State and local agencies. These reports include the following:

Workplans

Section 25299.37(c)(1) of the Health and Safety Code specifies that when a responsible party undertakes corrective action, including preliminary site assessments and investigations, they "shall prepare a workplan that details the actions to be taken by the...responsible party to achieve the required corrective action." Section 2722 of Article 11 California Code of Regulations (CCR) requires submittal of a workplan for proposed underground storage tank clean-up activities.

Generally, Hanover Enviornmental Services, Inc., prepares a workplan during the Preliminary Site Assessment Phase, the Soil and Water Investigation Phase, and the Verification Monitoring Phase. Hanover Environmental Services, Inc.'s project managers submit workplans for approval by the regulatory agency.

Workplans include a Site Conceptual Model that presents a summary of the site's current geologic and hydrogeologic conditions, suspected contaminant sources, potential migration pathways, receptors and sampling constraints. The workplan also includes a narrative of the goals of the investigation activities and how the work will accomplish those goals. The workplan also includes a description of the proposed work including methods, locations, sampling protocols, laboratory analysis, etc. and may, as necessary, include management of contaminated soil and water generated by the clean-up activities, clean-up schedules, interim remedial actions, and health and safety plans. The actual detail of the workplan depends upon the scope and type of activity to be conducted. Site Characterization activities such as pump tests, air sparging tests, slug and bail tests, and vapor extraction tests are commonly performed during Phase II activities.

In addition, many of Hanover Environmental Services, Inc.'s workplans also contain the following, as necessary:

  • Interim Remedial Action Plans
  • Community Health & Safety Plan

Periodic Groundwater Monitoring Report:

The most common report that is required on sites where groundwater has been impacted is the Quarterly Groundwater Monitoring Report. Hanover Enviornmental Services, Inc., has staff specifically dedicated to reporting. A Quarterly Monitoring Report is normally submitted each quarter (every three months) to the regulating agency and/or the Regional Water Quality Control Board (RWQCB). Other reporting schedules include semi-annual (twice a year) or annual (once a year) and are similar to the quarterly reports. Generally, these reports include: Graphic Presentation: Include site maps (plot plans). The maps shall include: potential contaminant sources, b) well locations, groundwater elevation contours, groundwater flow direction(s), extent of phase separated product and extent of dissolved chemical constituents. Selected analytical results are included on the plot plan. The use of line or bar graphs is also used to illustrate variations in groundwater elevations, product thickness, and dissolved chemical concentrations with time. Cross sections are provided to illustrate if subsurface conditions.

Site Investigation Report

Hanover Environmental Services, Inc. team of geologists and environmental scientists conduct site investigations and prepare the site investigation reports for our project sites. Most site investigation reports are details regarding the site and the activities that took place. A typical site investigation report includes:

  • Section Content: Site Identification address, name, business, regulatory agency identification number, owner, operator, responsible party, contact person and location.
  • Site History: Historical and current site and adjacent property use.
  • Release Description: Substance, characteristics, quantity, location(s), and how and when release occurred and abated.
  • Site Plot Plan: Site plans are drawn to scale, and include streets, structures, utilities, excavation and stockpile locations, tank and piping (past, existing, proposed), and well boring and samples.
  • Geology Regional: Site geology and topography.
  • Hydrogeology: surface drainage, adjacent and water bodies, basin plan, hydrographic unit and sub-unit, groundwater elevations and gradient, migration patterns, and sources of information.
  • Contamination: Summary of analytical data with locations, analysis, and results, maps and delineation cross sections showing extent of contamination, potential sources, pathways, boring locations, lithology, water table, groundwater contours, environmental parameters, man-made features, and estimated volume and mass of contaminated media.
  • Exposure Concerns: migration and natural pathways (air, soil, surface water, bedrock fractures, groundwater, etc.), man-made pathways (conduits, utilities, vaults, piping, storm drains, etc.), impacts on biological receptors (people, plants, animals), potential nuisance and water wells.
  • Sampling: protocol, methods, preservation and transport, analysis, chain-of-custody, matrix, lab reports and quality assurance/quality control.
  • Waste Management: volume, location, methods to prevent run-off or public access, disposal methods, copies of manifests.
  • Site Safety: safety and security description, community health and safety, monitoring equipment, protective equipment, public agency notification and utility notifications
  • Summary: conclusions and recommendations, horizontal and vertical extent of contamination, additional assessment recommendations and mitigation alternatives.
  • Appendix: well boring logs, manifests, permits, lab data sheets, chain-of-custody forms

Corrective Action Plan Preparation

The Fund Regulations require that a Corrective Action Plan (CAP) be prepared before initiating corrective action. As part of the CAP process is the evaluation of the remediation technology alternatives that will be part of the corrective action process. Hanover Environmental Services, Inc. prepares the CAP after the implementation of the preliminary site assessment and soil and water investigation phases and after the regulatory agency has concurred that the lateral and vertical extent of contamination have been adequately assessed. The CAP effectively incorporates all past regional and site-specific data and identifies the most feasible and cost-effective remediation method for a project site.

The level of effort and detail necessary for each CAP varies depending upon the site conditions, the extent of contamination, and the requirements of applicable regulatory agencies. Generally, a CAP provides an assessment of the impacts, a determination of applicable cleanup levels, a feasibility study and workplan, and monitoring and reporting of CAP effectiveness.

At a minimum, the content of a CAP includes:

Assessment of the impacts:

a) Hydrogeologic characteristics of the site:

  1. Indicates current and potential beneficial uses of the ground and surface waters
  2. Tabulates existing groundwater data, including existing well gauging data and construction details
  3. Provides a narrative description of the topographic characteristics in the vicinity of the site
  4. Includes a map illustrating the topographic characteristics and location of groundwater supply wells in vicinity
  5. A description of the lithology of the site
  6. Cross section of the lithologies present at the site
  7. Map(s) illustrating groundwater flow direction and gradient
  8. Discussion of the groundwater data in regional context, considering regional climatic cycles

b) Contaminant characteristics:

  1. Identifies the contaminants of concern at the site, tabulates existing contamination data, and provides analysis of trends in contaminant concentrations
  2. Narrative descriptions of the chemical and physical characteristics of the contaminants, discusses toxicity, persistence, and potential migration
  3. Impacts of the contaminant at the site to the soil, groundwater, surface water and air. Impacts to utilities. Provides maps and cross sections of contaminant plumes.
  4. Descriptions of the potential impacts of the contamination at the site, which may include a Fate and Transport study.

Determination of applicable cleanup levels: Cleanup levels for groundwater surface water, and soil are performance standards to be considered when completing a feasibility study. Strategies considered must be technically capable of reaching the established level. Regulatory agency approval is obtained for any target level prior to implementing corrective action.

Feasibility Study and Workplan: In areas designated as beneficial use, or where the waters are being used, the feasibility study evaluates the appropriateness and cost-effectiveness of at least two alternatives. The Feasibility Study only considers alternatives capable of achieving the target cleanup levels established and includes evaluation of the most cost effective alternatives available based on existing technology. A Feasibility Study and Workplan includes:

  • A description of each proposed corrective action strategy.
  • A justification for the selection of each corrective action strategy as an appropriate method to restore or protect existing or potential beneficial uses and to protect human health.
  • An estimate of the time required to complete remediation for each corrective action strategy.
  • A comparative analysis of the total costs of each corrective action strategy, presented in terms of starting and operating costs.
  • A selection of the most cost-effective strategy and the preparation of a detailed workplan describing the specific tasks to be performed during implementation of the selected remediation alternative.

Monitoring and Reporting of CAP Effectiveness: Hanover Environmental Services, Inc., serving as the responsible party, proposes a strategies for monitoring and evaluating the effectiveness of the corrective action. The strategy usually describes the key indicators and the monitoring methods to be used in evaluating the effectiveness of the work and describes the criteria to be used in determining when site cleanup is complete, or when the corrective action has become ineffective. Hanover Enviornmental Services, Inc. proposes a schedule for reporting and monitoring and an evaluation of the results of such monitoring. Hanover Environmental Services, Inc., works with regulatory agencies to obtain any required approvals prior to implementing corrective action.

Remedial Action Plan Preparation

A Remedial Action Plan (RAP) is developed if the workplan included in the CAP requires additional design specification to allow the regulators to fully approve the chosen remedial alternative. A RAP completes the design of the chosen remedial alternative for approval by the regulatory agency. In some cases the "Remediation Workplan" or RAP may be part of the Corrective Action Plan.

 



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