A citizen complaint in 2011 after oil was observed seeping from the property into the adjacent stream triggered an inspection by the USEPA and subsequent issuance of a Clean Water Act Administrative Order for Compliance. Lawhon was retained by counsel to prepare a Site Investigation Report and Remediation Work Plan for review and approval by USEPA.
L&A first conducted a site investigation which included the completion of soil borings, the collection of ground water samples and a geophysical survey. Although the site’s historical use included the storage of crude oil collected from the surrounding area, it had not operated for nearly 40 years. Based on the results of the investigation, it was determined that the source of the observed discharge was residual crude oil in the ground from previous operations.
It was determined that the most cost effective remedial solution was the installation of a passive product recovery system located between the source area and the stream, including an 18 inch diameter product recovery well. Approval of this mitigation plan was obtained from the USEPA prior to implementation. Contaminated soil removed from the bottom of the excavation during installation of the collection system was stockpiled and subsequently transported to a licensed landfill for proper disposal.
To reduce costs associated with the operations and maintenance of this collection system, L&A trained facility personnel to safely and effectively complete the O&M tasks as they routinely managed petroleum products during daily activities. A log book of activities is maintained at the site for tracking purposes. The project is ongoing.