SIMPLIFY - Brown and Caldwell

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U A R T E R L Y

Whether you’ve got single ormultiple emission sources,Brown and Caldwell’s latestEMIS for Title V Air EmissionReporting handles varyingdegrees of monitoring, recordkeeping and reporting withaccuracy and ease.

• Manages air emission data • Tracks compliance status against

permit-specific Title V limits • Generates agency certification

forms • Fast ROI–save hundreds, if not

thousands, of labor-hours

“At last… an easy and intuitive Title Vcompliance management tool thatadjusts to changing operating andpermit conditions.”

OPERATIONSAutomatically checks emission pointdata against a plant’s Title V airpermit limits. Automatic operatorprompts for corrective action when noncompliant data is entered.

CONTROLMonitor plant performance, conducttrend analyses, assess compliancecapability, identify operations issues,generate reports and validate dataentries.

REPORTINGAutomated production of Annual Title V ComplianceCertification Forms for the U.S. EPAand agencies in all 50 states.

There’s more! Contact Jim Claffey inAtlanta at (770) 673-3663 [email protected].

SIMPLIFYTITLE V AIR EMISSION REPORTING

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SMART STEPSSAVE INVESTIGATION AND REMEDIATION COSTSby Ed Ricci, Environmental Services national practice leader

know what additional information may be needed.Also consider using mathematical modeling of

the site and visualization of existing data.Plan efficient field programs.

Each site is different, and investigation isoften phased to delineate what has pre-viously been found. New field tech-

niques, however, can minimize mobiliza-tion and remobilization costs by providing

more real-time data, helping you decidewhere to go and when to stop while you’re still

in the field. Also consider the cost-benefit mer-its of innovative soil and groundwater remedial

approaches.Combining business planning, life-cycle costs, con-

ceptual modeling and efficient field planning will pro-duce a crisp game plan that keeps your goal in constant

focus—shortening the process, increasing efficiency andminimizing total investment, with your preferred end use

in mind.

2. Take the easy road whenever possible.With a solid business plan and clear objective, work throughtechnical approaches that can save you the most time andmoney. This business-plan approach can be especially helpfulwith Superfund’s cumbersome RI/FS (RemedialInvestigation/Feasibility Study) protocols, helping you pinpointminimal-action alternatives consistent with your operation’s cashflow, equity plans and schedule targets.

Cost-efficient approaches like intrinsic or enhanced bioremediation and insitu remediation are practical and widely accepted. In fact, in situ approachescan be much quicker and more effective than traditional pump-and-treat tech-nology. And depending on a site’s equity plan, redevelopment use and

BROWN AND CALDWELL QUARTERLY 1

• The U.S. Army Corps ofEngineers is restoring theenvironment of California’shistoric Benicia Arsenal

• Brown and Caldwell person-nel pioneer efficient newremediation techniquesand tools

Marketing Terry PeckhamCommunicationsDirector

Editor Susan Wels

Art Direction & Design Calvin Ng

Copy Editor Dan Foscalina

Illustration Mark StearneyFrancisco Loureiro

Photography Jeff AlexanderDan Milburn

Daniel BellJ. Emilio Flores

Writers Susan WelsTerry PeckhamDan Foscalina

Distribution Kristy Oshiro

Printing Bacchus Press

To speak with a Brown and Caldwell

representative, call us at (800) 727-2224 or visit our Web site at

www.brownandcaldwell.com.

Brown and Caldwell providesenvironmental engineering and

consulting services to public agencies, the federal

government and industry.

Quarterly is published byBrown and Caldwell, P.O. Box 8045,

Walnut Creek, CA 94596-1220; tel. (925) 937-9010.

Subscriptions are free. © Brown and Caldwell 2004. Please contact Terry Peckham

at (925) 210-2514 or [email protected] for permission to reprint.

Brown and Caldwell is an equal opportunity employer and values

work force diversity.

QUARTERLY

SMART STEPS SAVE INVESTIGATIONAND REMEDIATION COSTSPractical, successful tips for saving environmental costs in a tough economy

• New air emission controlrules regulate industrialwastewater systems

• The Fixed-price RemediationMethod (FIRM) offers solu-tions, guarantees and nosurprises

• BC’s EnvironmentalManagement InformationSystem (EMIS) makes keepingtrack air-quality data fastand simple

• Managing sediment sites is agrowing concern

THE PATH TO COMPLIANCEAdvanced planning helps clients navigate confusing federal, state and localreporting requirements

CAPPING LANDFILL COSTSNew advances improve leachate treatment and operations efficiency

QUARTERNOTES

e’ve all experienced the effects of tough economic conditions. Belt-tightening has led many private- and

public-sector operations to test and put in place moreefficient environmental services approaches. At BC,

we’ve learned a lot about saving clients’ environmental costs. Here arethree of the most practical and successful approaches thatwe’ve used:

1. Know where you’re going before you get there.Investigation and remediation of Superfund, RCRA(Resource Conservation and Recovery Act) andVoluntary Compliance sites can cost millionsof dollars. The conventional phasedapproach, which hinges on previous andfuture actions, can be costly, inefficient andrepetitive. The solution? Turn this equationaround and base your environmental mitigationdecisions on forward projections, notretrospective thinking.

Create an overall site business plan, including life-cycle costs. Look at each site cleanup as a business case.Your business plan should include projected life-cyclescope and costs, as well as a schedule and the ultimateintention for developing or disposing of your property. Asite’s life cycle can include various pathways and end-points, depending on technical and regulatory variables.Develop your endpoint objectives early. Involve peoplewho’ve dealt with similar sites, front to back, to get a betterfeel for what lies ahead. Life-cycle costs should include capital and O&M costs,cash flow considerations and alternative remedial scenarios.

Building a solid, realistic business plan requires that you knowthe site. Start by developing a detailed conceptual model of the site based onwhat you already know about it. The gaps will quickly be apparent, and you’ll

W

Continued on page 17

Ed RicciEnvironmental Servicesnational practice leader

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ADVANCED PLANNING HELPS

CLIENTS NAVIGATE CONFUSING

FEDERAL, STATE AND LOCAL

REPORTING REQUIREMENTS


threat to surface water, groundwater orhuman health. But in many states,Marrou notes, “reporting of historicalcontamination is a horse of a differentcolor compared to a new spill orrelease…and it’s often gray.”

Get legal counselIn many cases, state,federal and local report-ing requirements areunclear because: • either the magnitude

of the contaminantrelease is unknown

or it falls below various reporting thresholds

• the circumstances of the release areuncertain or unknown

• or responsibility for the release isunknown or unclear.

As a first step, Fields advises, clientsshould discuss the following questionswith legal counsel:

• Is the release on land, water or both?

• Does the release violate applicablewater quality standards?

• Do the circumstances of the con-tamination (setting, concentration,constituents, etc.) suggest thatgroundwater may be impacted? If

so, does your state's groundwaterstatute include formal reportingrequirements?

• Do you have reason to believe thatthere is an imminent threat to pub-lic safety as a result of the contami-nation? If it’s not specifically laidout in your state’s environmentallaw, general duty requirements ofother statutes can usually be inter-preted to imply a reporting obliga-tion to safeguard public health.

• Does the spill threaten or adverselyimpact owners or occupants ofproperty not owned by the client?

According to environmental attor-ney Greg Patterson, a partner withMusick Peeler & Garret in LosAngeles, it’s often in a client’s bestinterest to be proactive in the event ofnew or historical contamination.

“When in doubt, report,” he recom-mends, especially in the case of a newspill, “and make sure that you reportto every agency that may have jurisdic-tion and separate, often varying,reporting requirements.

“The likelihood is that you’ll needto report it anyway, and you’ll alsoneed the agency’s sign off on remedia-tion plans. Even if the reporting wasn’tnecessary,” he adds, “there are few

negative repercussions, and there’s verylittle down side to this approach–com-pared to your significant, potential lia-bility if the agency asserts that youshould have reported contamination,but didn’t.”

In the case of historical contamina-tion, Patterson advises reporting ifthere’s any chance of subsurface con-tamination posing a threat to ground-water, a potential health risk or ambi-guity in statutory reporting obliga-tions. “The risks of not reporting,” henotes, “include high penalties and get-ting on an agency’s bad side.”

If the historical contamination posesno immediate or significant threat,however, clients should take advantageof the more relaxed reporting time-frame to develop a response and reme-diation plan.

“They can then present the responseplan to the agency at the same timethat they report the preexisting con-tamination,” Patterson advises. “It’s aproactive strategy that can help clientsguide the process.”

Be preparedThe best strategy ofall, however, is toplan far ahead forthese difficult, con-fusing situations.That way, Marrounotes, you’ll havepolicies, decision

trees and emergency procedures inplace so you won’t have to make com-plex, potentially costly decisions onthe fly. He recommends followingthese basic steps to be prepared inboth proactive and reactive situations:

Tips for planning areportingstrategy1. Review yourcompany’s poten-tial liabilities andexposure in rela-tion to currentchemical handlingand past waste-handlingpractices.

time. “Have your ducks lined up,” herecommends, “before you’re ever facedwith an emergency.”

That, he acknowledges, can be achallenging task, especially for envi-ronmental managers responsible formulti state facilities. As the chart illus-trates, every state and many localitieshave their own, individual require-ments, and the path to compliance isusually far from clear. “Each situationneeds to be evaluated individually,” hesays, “and there’s not an easy answer inmany cases.”

Decisions about environmentalreporting, moreover, are mainly legalin nature, not engineering or environ-mental, adds BC’s Houston OfficeManager Tom Marrou.

“As environmental consultants,” hesays, “we can quantify or estimatereleases and provide examples of envi-ronmental issues and regulations. But,bottom line, it’s the role of a client’slegal counsel to decide what sorts ofsituations to report.”

The same, Ricci says, is true when aclient discovers preexisting contamina-tion on a site. “A client may be dig-ging the foundation for a new build-ing and comes across some discoloredsoil. The question then,” he says, “is‘what do I do?’”

In some states, such as Texas, newreleases must be reported if there’s any

ecently, a small marinefueling company in SanDiego accidentallyspilled about 75 gallonsof oil, which flowed

into surrounding soil and shallowgroundwater. The spill was relativelyminor and should have cost about$1,000 to clean up. But because thecompany didn’t have any spill report-ing procedures in place, it missed anumber of critical local and statereporting deadlines. The result? A$1,000 headache mushroomed into acostly $100,000 legal problem.

This situation is more commonthan many clients realize, says Brownand Caldwell Client Services ManagerJohn Fields. “Local, state and federalspill-reporting regulations have evolvedin a completely hodge-podge fashion,”he explains. “As a result, environmen-tal managers faced with contaminationissues have the difficult task of navigat-ing this maze of confusing and over-lapping regulations.”

That’s a tall order, especially whensome municipalities and states requirespill reporting within 24 hours, andnumerous agencies may each requirenotification. “Under pressure likethat,” Fields states, “it’s far too easy tomake costly mistakes and end uppainfully second-guessing yourself afterthe fact.”

To help clients respond, says EdRicci, BC’s national practice leader forEnvironmental Services, BC has devel-oped a state-by-state reporting proto-col (see chart on inside back cover)based on its experience managingnationwide compliance projects.

“This key information guides clientswhen a spill, leak or release occurs,” headds, “and helps clients avoid futurereporting problems.”

Plan ahead forproblemsIf you are handlingchemicals or petroleumproducts, he advises, thebest strategy is to planspill and contaminationreporting policies andprocedures well ahead of

2. Think through and plan ahead forpotential spills and historical contami-nation.

3. Be aware of federal, state and localreporting regulations and have a clearreporting policy that all employeesunderstand.

4. Have emergency spill procedures inplace and routinely update training foron-site personnel who may be responsi-ble for responding to the situation.

Tips for strategicreporting after arelease1. Immediately controlthe extent of the release.

2. Consult with scienceand engineering special-

ists to determine the chemical natureof the release, environmental effects,pathway analysis control technologies,the potential impact of the spill andultimate cleanup scenarios.

3. Consult with an attorney aboutreporting requirements and regulatoryinterpretation.

4. File the necessary or prudentreports within the required reportingtime period.

Put policies andprocedures in place“By being proactive,” Marrou explains,“you can avoid violations and savemoney by being ahead of the game.”

It’s a big task, Fields acknowledges,but it can be a very savvy business deci-sion long term. “It’s hard to appreciatethe wisdom of this approach,” henotes, “unless you’ve already had yourbusiness disrupted as a result of under-reporting or not reporting a release.The smartest move is to be preparedfor the unexpected before it ever hap-pens to you.”

For more information, contactEd Ricci at (602) 567-3917 [email protected].

RRR

BROWN AND CALDWELL 54 QUARTERLY FALL 2004

T H E P A T H T O C O M P L I A N C E T H E P A T H T O C O M P L I A N C E

“It’s far too easyto make costlymistakes andend up painfullysecond-guess-ing yourselfafter the fact.”


New advances improve leachate treatment and operations efficiency


Ron Crites, BC’s Natural Systemsservice leader.

“After the initial capital expendi-ture,” he adds, “the system has mini-mal operating costs and can easilypay for itself over a relatively shortperiod of time.”

Increasing landfill efficiencyAnother advance, adds Brown andCaldwell Senior Associate AlanKirschner, speeds up landfill degrada-tion and gas production, increasesdensities, extends the length of oper-ation and enhances revenues andprofits.

“Because landfill space is gettingscarcer,” he explains, “it’s often easierto extend a site’s useful life than toget permits for constructing a newlandfill.”

One new approach uses nonhaz-ardous liquid waste, in addition toleachate recirculation, to increasemoisture levels in the landfill—sig-nificantly speeding biological decom-position.

“Landfill densities go up,” he says,“allowing more waste in a given vol-

any landfill operatorsface the challenge of treating and dis-posing of leachate—a task thatbecomes especially costly and bur-densome once a landfill closes and itsrevenue streams disappear.

The expense of tank trucking andtreating leachate off-site, then dis-charging it into sanitary sewers, canadd up to 20 percent of landfill oper-ation and maintenance costs and lastyears beyond a landfill’s useful life.

New technologies, however, areoffering cost-saving alternatives totraditional leachate disposal. Otheradvances, adds Brown and CaldwellDesign and Solid Waste ManagerBob Ash, can significantly extend theoperating lifespan of a landfill,increasing owners’ revenues andprofits.

“By considering these cutting-edge approaches,” he says, “clientscan potentially enhance the cost- andoperational efficiency of their land-fills without making a huge capitalinvestment. The savings go right tothe bottom line.”

On-site leachate treatmentNew vertical wetland systems, in par-ticular, are promising methods forreducing the cost of treating leachate.Developed in Germany in 1974 andfurther refined in Finland in 1991,vertical-flow wetland designs havebeen extensively tested in Canada.

“These biological treatment sys-tems can enable landfill operators totreat and discharge leachate on-site,”says Brown and Caldwell SeniorConsultant John Baker. “Since theyhave very low operating costs and

require only limited maintenance,they also reduce treatment costs.”

Vertical-flow wetlands, heexplains, are a major improvementon constructed wetland designs.Traditional systems are essentiallyopen ponds filled with wastewater

that flows horizontally throughaquatic vegetation, removing sus-pended solids and ammonia whilereducing biochemical oxygendemand. Some designs mimic naturalwetlands, while others have subsur-face flow and filter wastewaterthrough gravel.

“The traditional systems can do agreat job in warmer months,” he

explains, “but in winter, when thevegetation isn’t as active, they’re oftenineffective in removing the ammoniato required levels.”

The low-velocity flow of naturalfree water surface wetland designsalso requires extensive surface area

and can cause problems with odorand mosquitoes. Vertical-flow wet-lands, however, avoid mosquito prob-lems because water is not ponded onthe surface. In these systems, Bakerexplains, leachate percolates down-ward through gravel, which liesbelow ground.

The system also increases treat-ment effectiveness by evenly distrib-

uting the leachate and allowing oxy-gen to enter the full depth of the soil,creating enhanced aerobic zones.Bacteria in the root zone functionwell in the winter and keep the treat-ment processes going even when thewetland plants are dormant. The ver-tical-flow wetland design actuallymimics a trickling-filter wastewatertreatment system, Baker notes, withtwo treatment units and a polishingstep.

“The end result,” he says, “is highperformance and low costs, sincethere’s no need for off-site disposaland no need to heat the system for itto work effectively.”

The vertical-flow wetland designhas been extensively tested withswine manure, sanitary sewage, win-ery process wastewater and green-house leachate, and is an increasinglypopular choice in Europe for munici-pal wastewater treatment, notes

ume and increasing the profitable life-time of the landfill.”

The strategy takes advantage of anew EPA rule allowing permits foralternative landfill design and operat-ing requirements. These alternativeapproaches include:• improvements in liner system design

and materials• improvements in design and materi-

als of leachate drainage and recircu-lation systems

• enhanced processes for more rapiddegradation of waste

• flexibility for alternative caps• new liquid distribution techniques

States implementing the new rulecan allow operation of these newtechnologies in municipal solid wastelandfills, so long as there is noincreased risk to human health andthe environment.

The new permits allow the addi-tion of nonhazardous liquids to accel-erate decomposition in landfills withappropriate liners. Owner/operatorsinterested in this approach arerequired to demonstrate propergroundwater protection, landfill sta-

bility and enhanced landfill gas col-lection and control.

The new EPA rule limits the dura-tion of initial permits to three years,so landfill operators can test andassess the performance of an innova-tive technology or process. The per-mit may be renewed for three years,up to three times, allowing for a max-imum permit period of 12 years.

Boosting capacityOther approaches include using low-profile liner systems to boost capacityand vertically expanding existingsites—increasing their volume withthe thinner liner systems, heightenedperimeter berms and steeper sideslopes.

“Over time,” Kirschner explains,“the 33 percent slope of a landfill willsettle into a 20 to 25 percent grade,diminishing the facility’s capacity. Bybuilding landfills with a 40 to 50 per-cent slope, we can design it to settleinto a 33 percent grade, significantlyincreasing the long-term volume ofwaste that it can handle.”

Brown and Caldwell, Ash adds, is

well-positioned to help clients imple-ment these promising new landfillstrategies.

“With our extensive benchstrength and experience in both solidwaste management and water andwastewater treatment,” he explains,“we can help clients successfully eval-uate and employ the latest, most cost-effective methods for managing andoperating their landfills. It’s all aboutadding quantifiable, bottom-linevalue for our clients, and it’s part ofour ‘best brains’ approach at Brownand Caldwell.”

For more information, contact Bob Ash at (615) 250-1206 [email protected].

Left: A three-cell vertical wetland under construction, including pump chambers, perforated collection pipes and a 30-mill PVC liner that is flexible for easy installation and pliable incold weather. Center: The vertical wetland components are covered with filtering media, which varies depending on treatment objectives and wastewater characteristics (i.e., particlesize, porosity and aluminum, iron and calcium content) and treatment objectives. Right: The vertical wetland is planted with cattails (Typha sp.) or reed grass (Phragmites sp.), againdepending on wastewater characteristics (Phragmites, for example are more tolerant of high ammonia concentrations).

Brown and Caldwell's vertical wetlands designs (above) allow leachate to be treated and discharged on-site, savingmoney for landfill owner/operators.

“Clients can potentially enhance the costand operational efficiency of their landfillswithout making a huge capital investment.”

MMMC A P P I N G L A N D F I L L C O S T S C A P P I N G L A N D F I L L C O S T S



BROWN AND CALDWELL 1 110 QUARTERLY FALL 2004

Q U A R T E R N O T E S

The National EnvironmentalPolicy Act (NEPA) can be acompliance roller coaster,often driven by politics.Brown and Caldwell, how-

ever, has assembled a national team ofexperts to help smooth the ride.

Created in 1969 and enacted in 1970,NEPA requires federal agencies to con-sider a project’s impacts on environ-mental values such as land use, geolo-gy, biology and cultural resources.NEPA documentation includes environ-mental impact statements, environmen-tal assessments and categorical exclu-sions, and it is triggered by proposedfederal actions, such as funding or per-mits. Examples of projects that couldrequire NEPA compliance include trans-mission lines, gas pipelines, highways,power generation plants, communica-tion towers and water treatment plants.

Regulatory experienceBrown and Caldwell’s capabilities inte-grate NEPA, Endangered Species Act(ESA) and Clean Water Act documen-tation and environmental planning serv-ices with agency coordination and pub-lic involvement. “Our NEPA services aregaining ground in the competitive mar-ket of regulatory compliance,” says BCNEPA Specialist Mike Strand.

While BC’s national team is relativelynew, the company’s NEPA experience isextensive. In Arizona, for example, BCcompleted an environmental assess-ment for the City of Tempe’s 212-acreBrownfield Redevelopment Project. InIdaho, team members performed NEPAdocumentation and coordinated bio-logical survey efforts between a client

and subcontractors for a 60-mile, 138kVtransmission line (pictured). And inColorado, BC helped the cities ofLittleton and Englewood stay in compli-ance with NEPA regulations during awastewater treatment plant expansion.

Multidisciplinary team“In addition to our NEPA capabilities,our biological team includes experts inthe ESA and associated documenta-tion,” Strand notes. BC specialists havealso written biological assessments andconducted consultation and confer-ences with the U.S. Fish and WildlifeService under the ESA Section 7.

“But what sets our team apart isnational experience,” he adds. Teammembers are well versed in NEPA com-pliance with a wide variety of federalagencies, including the Bureau of LandManagement, U.S. Forest Service,Environmental Protection Agency andthe U.S. Department of Housing andUrban Development.

“What’s more,” he says, “BC under-stands the relationship between andcompliance with NEPA and variousstate environmental laws, such as theCalifornia Environmental Quality Actand the Montana Environmental PolicyAct. We’re familiar with all aspects ofcompliance and permits needed forsuccessful completion of a project.”

For more information, contactMike Strand at (208) 336-1340 [email protected], orKatherine Beisel at (714) 689-4868 [email protected].

NATIONAL NEPA NETWORK Expert team eases compliance

There’s nothing like being rec-ognized for a job well done—especially when the honor

marks your career and is bestowedby two of the most renowned agen-cies in the environmental industry.The American Water WorksAssociation and the NationalAcademy of Engineering recentlytook their hats off to two Brown andCaldwell specialists for their distin-guished work in advancing the fieldsof engineering, wastewater andwater supply management.

National Academy ofEngineering taps ParkerDenny S. Parker, Ph.D., P.E., has beenelected to the National Academy ofEngineering, the profession’s highestdistinction, in honor of his "significantadvances in the scientific understand-ing, engineering development, andprocess design of chemical, physicaland biological processes for the treat-ment of wastewater." He joins 76 othernew members and 11 foreign associatesin the Class of 2004.

Parker has consulted on hundreds ofwastewater-related investigation, designand planning projects in his 30 years inthe industry, and he's built an unprece-

HIGH HONORS FOR BC EXPERTS

When a former hazardous-waste landfillthreatened the state Botanical Gardenat the University of Georgia (UGA),Brown and Caldwell engineers devel-oped an award-winning system to pro-tect the preserve and its surface andgroundwater from future chemicalreleases—at a cost savings of more than$20 million.

“The integrated remediation systemhas improved surface water quality,eliminated further landfill releases, con-trolled long-term groundwater risks andpreserved the integrity of the botanicalgarden grounds,” says BC Client ServiceManager Jim Claffey, Ph.D.

Growing threatFor more than 20 years, UGA disposedof laboratory chemicals and low-levelradiological isotopes at its hazardous-waste landfill on Milledge Avenue. In thelate 1980s, the Georgia EnvironmentalProtection Division (EPD) determinedthat chemicals from the one-acre sitewere seeping into groundwater andthreatening a stream in the botanicalgarden.

In response, Brown and Caldwell con-ducted groundwater monitoring of thesite for more than a decade as part of aRCRA (Resource Conservation andRecovery Act) investigation. Then, in1998, ongoing plume migration prompt-ed UGA to take more aggressive action. That year, BC began working with the

university to develop and implement acomprehensive remedial design pro-gram. The $3 million system included aRCRA-compliant landfill cap, a first inthe state of Georgia; a phytoremedia-tion system that uses plants to absorband break down hazardous chemicals; asurface-water collection and treatmentsystem; and a groundwater recoveryand treatment system to halt plumemigration.

Award-winning, cost-saving design“Technical information and site monitor-ing data prove that the landfill cap isalready effective and will provide pro-tection of human health and the sur-rounding habitat for many, many yearsto come,” says Ken Scott, UGA associ-ate VP and director of theEnvironmental Safety Division.“Environmentally speaking,” he adds,“we made the right move.”

The design also proved to be a farless costly alternative to the EPD’s rec-ommended approach of excavation anddisposal, which was estimated to costas much as $28 million.

The project was honored by theGeorgia Chapter of the American WaterResources Association as the 2003Water Resources Project of the Year. Italso won the 2004 EngineeringExcellence Award presented by thestate chapter of the American Councilof Engineering Companies (ACEC) andan Honor Award from ACEC’s nationalchapter.

For more information, contact JimClaffey at (770) 673-3663 [email protected].

dented reputation for process innova-tion. His research helped develop theflocculator clarifier and the TricklingFilter/Solids Contact process, both ofwhich are used in hundreds of plantsacross North America.

AWWA honors Willis At its annual convention in June, theAWWA recognized Brown andCaldwell’s Potable Water Leader BobWillis for his knowledge, dedication andaccomplishments in the field of watersupply, presenting him with its HonoraryMember Award.

“Few individuals in the PacificNorthwest have given more to our asso-ciation and the water industry than BobWillis during his 30-plus-year career,”said AWWA Executive Director JackHoffbuhr.

Willis was nominated by the AWWA’sPacific Northwest Section, confirmed bya panel that included two past presi-dents and current president MarlayPrice, and approved by the AWWAboard of directors.

A past president and five-year officerof the American Water WorksAssociation, Willis spent 28 years withthe City of Portland Bureau of WaterWorks. He has worked with hundreds ofutilities in the United States and Canada,helping managers and staff improvewater quality and utility operations.

PLANT PROTECTIONLandfill remediationdesign safeguardsGeorgia’s StateBotanical Garden

BobWillis

Denny Parker

UARTERNOTES


Established in 1849, the2,700-acre BeniciaArsenal—the first U.S.Army arsenal on thePacific Coast—is nowa mixed-use commer-cial and residential site

in the San Francisco Bay Area. Since1997, the U.S. Army Corps of Engineers(USACE) has been working to eliminaterisks to human health and the environ-ment on the property as quickly andeconomically as possible. Brown andCaldwell has been the primary consult-ant for the project, partnering withForsgren Associates.

“The site and remediation investiga-tion has been a very careful process,”explains Project Manager Wendy Linck.“We’ve been working closely with allstakeholders, including the Army Corpsof Engineers, landowners, the commu-nity and regulatory agencies.”

Quality and cost-efficiencyAs part of the remedial investigation,BC assessed the nature and extent of

chemicals linked to past Department ofDefense activities, analyzed subsurfaceconditions and the movement ofgroundwater and contaminants, devel-oped health, safety and quality assur-ance plans and evaluated some 300sites within the arsenal for field investi-gation, ultimately assessing about 60.BC also developed an environmentaldata management system for the project, as well as an interactive data-base/GIS web site, and is providingextensive outreach to the localcommunity.

“We have a most competent andcapable consultant on board in FA/BC[Forsgren Associates/Brown andCaldwell],” states Michael Mitchener,manager of the USACE Benicia Arsenalproject. “They have a long history ofinvolvement at the Benicia Arsenal anda history of exceptional performancewith us.”

For more information, contactWendy Linck at (916) 853-5325 [email protected].

CORPS CLEANUPThe U.S. Army Corps of Engineers is restoringthe environment of historic Benicia Arsenal


Since July 2002, when the U.S.

Environmental Protection

Agency (EPA) amended the

oil pollution Spill Prevention

Control and Countermeasure

(SPCC) Plan regulations, many compa-

nies have been unsure how these rule

changes apply to their facilities.

Those subject to the rules have to

review and make changes, if needed,

to their SPCC plans by August 17,

2005, and implement those plans by

February 18, 2006. The plans outline

each facility’s policies and proce-

dures for preventing spills and con-

trolling any that occur.

“The new regulations set require-

ments and procedures for prevent-

ing oil discharges,” explains Tekla

King, Environmental Services

manager for Brown and Caldwell.

“Permitting and compliance issues,

however, can be confusing, complex

and expensive.”

COMMUNICATING COMPLIANCE STRATEGICALLY MANAGING SEDIMENT SITESSome consider sediment the fourthenvironmental medium after soil, waterand air. The reason is that, in aquaticenvironments, chemicals from uplandsources—such as direct discharges,spills, surface runoff, air pollution andaffected groundwater—can adhere tosediment particles. These chemicals insediment can then contaminate fish,potentially endangering any humansand wildlife that eat them.

As a result, the need to successfullymanaging sediment sites is a growingconcern. It can be a complex process,however, since it often means dealingwith unsteady hydrodynamic condi-tions, sensitive ecosystems and multi-ple stakeholders.

Saving money“Brown and Caldwell,” says BC’s LeadSediment Expert Kendrick Jaglal, “hasexceptional expertise that can helpclients successfully limit their liabilities

at sedimentsites, eventhose withthe mostcomplex andchallengingissues.”BC’s sedi-ment team,he adds,

comprises an oceanographer, civil andenvironmental engineers, hydrogeolo-gists and scientists, including toxicolo-gists, modelers and hydrologists.

“We work with clients across thecountry,” he says, “to develop andimplement strategic sediment investi-gation programs and cost-effectiveremedial designs. We also assist withother issues, such as cost allocation,consent order negotiation, litigationsupport and natural resource damage.”

Brown and Caldwell, for example,has used innovative risk assessmenttechniques to significantly reduce thescope of remediation at the LongBeach Naval Complex (pictured), sav-ing the Navy millions of dollars incleanup costs. BC has also helped theU.S. Army Corps of Engineers, as well

as several utilities, private manufactur-ers, ports and law firms, address sedi-ment issues.

“We’ve dealt with a wide range ofchemicals at inland and coastal sitesacross the country,” he says. “We alsoconduct research on new approaches,such as sediment capping, that can saveclients money while meeting the chal-lenge of managing sediment sites.”

For more information,contact Kendrick Jaglal, P.E., at (315) 449-3010 ext. 113 [email protected].

PHARMACEUTICAL PHENOMBC treatment system helpsclient win highest EPA award

Engineers at Brown and Caldwell hadto smile when they learned that PuertoRico-based IPR Pharmaceuticals Inc.-Canovanas won the prestigious EPARegion 2 Environmental Quality Award,the agency’s highest honor for environ-mental protection. After all, it was a BC-designed treatment system thathelped the company earn the award forreducing pharmaceutical activeingredients (PAI) in its effluent andthe environment.

The official honor, however, belongedto IPR, a subsidiary of AstraZeneca. Thefirm created the Pharmaceuticals-in-the-Environment initiative, under whichpharmaceutical companies determineacceptable levels of unregulated PAIs inprocess waste material. They complywith these voluntary standards usinganalytical models to detect and moni-tor waste materials and treatmentprocesses that reduce the concentra-tions and environmental impacts of PAI.

Brown and Caldwell played a keyrole in developing the treatment systemat IPR’s manufacturing facilities, includ-ing treatability testing, process designand preliminary engineering design.The system segregates specific wastestreams for equalization and controlstheir release to the publicly ownedtreatment works to ensure acceptablePAI concentrations in the ocean.

For more information, contactJoe Cleary at (201) 574-4721.

Poster and planning packages help clientsmeet new SPCC requirements

UARTERNOTES

Compliance helpMany facilities, she notes, are subject

to the SPCC regulations, including

those with:

• a total aboveground storage tank

capacity of 1,320 gallons or more,

counting only containers with

55-gallon or more capacity

• a total underground storage tank

(UST) capacity of 42,000 gallons

or more—excluding most gas sta-

tions and other USTs regulated

under 40CFR Parts 280 or 281 or

equivalent state programs

Brown and Caldwell, she says, can

help clients comply with the new

SPCC rules. BC, for example, has devel-

oped and copyrighted a simple-to-use

and easily updatable poster format for

SPCC plans, along with a record-keep-

ing package and training module that

meets SPCC requirements.

“To be useful,” King explains, “spill

prevention and cleanup information

should be posted and visible in any sit-

uation. The SPCC Poster Plan makes

this key information easily accessible in

a cost-efficient way, especially for com-

panies that have multiple sites.”

For more information, contactTekla King at [email protected] or (602) 567-3848.



Typical cross-section of ISCO application with fracturing in trichloroethylene plume

Shallow Injector

Satu

rate

d Zo

neVa

dose

Zon

e

Fractured Zone

Fractured Zone

Fractured Zone

Intermediate Injector Deep Injector

Sand and Gravel

Silt and Clay

Fill

Bedrock

C CI H2 3

CO22H OCI_+ +

Fe+3OH_

OH+ +

Fe+22H O2+


UARTERNOTES

When a small East

Coast municipality

needed to remediate

a former industrial

site before redevelop-

ing it as affordable senior housing,

Brown and Caldwell personnel used

quick, cost-effective ISCO in situ chemi-

cal oxidation technology to clean up its

chlorinated solvent-contaminated

groundwater.

The result? The site was remediated

within a year—the state’s first successful

site closure using an ISCO process.

Thanks to the success and speed of the

remediation, notes Jerry Vorbach, P.E.,

CHMM, BC’s manager of In Situ

Remediation Services, “the municipality

THE LEADING EDGE

obtained hundreds of affordable hous-

ing units for its low-income senior citi-

zens. The developer qualified for tax

credits and a low-income loan. And the

chlorinated solvent contamination was

destroyed, with no need for ongoing

groundwater monitoring.”

Chemical oxidation is a process that

removes electrons from contaminants

and helps break them down into harm-

less minerals, water and carbon dioxide.

New techniques, developed by Vorbach,

make the process even more efficient

and less costly by pumping liquid oxi-

dants directly into the source areas of

contaminated soil and groundwater,

controlling their flow rates and ensuring

the most uniform distribution.

“With these new techniques,”

Vorbach explains, “we can remediate

every type of organic contamination in

any geographic setting, even under-

neath buildings where you can’t dig out

the soil. It’s the fastest in situ remedia-

tion technology, and it’s lower in cost

than other methods. It’s a win-win inno-

vation for our clients—both municipali-

ties and developers—as well as for regu-

latory agencies.”

Detecting DNAPLBC experts have also developed a new

method for locating DNAPLs (dense

non-aqueous phase liquids) in subsur-

face contamination. The approach,

called a single-well surfactant push-pull

DNAPL test, is based on a mathematical

model and uses a surfactant solution to

verify the presence of residual DNAPL

at radiuses potentially up to 10 feet

from a test well.

“Until now,” says BC Principal

Geologist Greg Christians, “it’s been dif-

ficult to determine the actual presence

and location of residual DNAPL in the

saturated subsurface, even though it’s

the primary source of groundwater con-

tamination at many, if not most,

DNAPL sites.

“With this test,” he explains, “clients

can positively identify the presence of

residual DNAPL and, in some cases,

even potentially estimate the quantity of

residual DNAPL on their property.”

For more information, contactJerry Vorbach at (201) 574-4744or [email protected], orGreg Christians at (615) 250-1216 or [email protected].

Brown and Caldwell personnel pioneer efficient newremediation techniques and tools

For many large manufactur-ing and other compliance-driven organizations, man-aging Title V air-quality datais a major challenge.

Manufacturing plants typically havemultiple emission sources, and eachrequires varying degrees of monitoring,record keeping and reporting.

Brown and Caldwell is helping clientsspeed and simplify this task with thenewest version of its air emission track-ing and reporting software. Originallydeveloped four years ago for PCSNitrogen, a chemical processing plantin Augusta, Ga., the program allowsclients to manage air emission datarequired for Title V monitoring. It alsoenables them to track their compliancestatus against limits defined by their

MANAGING AIR QUALITY DATABC’s Environmental Management InformationSystem (EMIS) makes it fast and simple

Title V air permits. “The EMIS system,” notes BC Client

Service Manager Jim Claffey, “can saveclients up to one man-year of work, sotheir return on investment is relativelyquick. PCS Nitrogen has already realizeda great deal of value from the program.”

Speed and efficiencyTo use the system, plant operators sim-ply enter information relating to emis-sion points. The software then automati-cally checks the data against the plant’sTitle V air permit limits. If the data is outof compliance, the operator can enter acause and take corrective action tobring the reading back within permitboundaries. Automated data entryoptions are also available to furtherboost operating efficiency.

Recently, a manufacturingfacility in Los Angeles dis-covered PCE (perchloreth-ylene) contamination onproperty it leased from a

local landowner. The PCE had alsomigrated into soil and groundwater onan adjacent property, and before toolong, lawyers for all three parties weredeadlocked in complex litigation.

Fortunately, they were all able toagree on a solution—a fixed-priceremediation method that guaranteesperformance milestones and completecleanup of the site at a fixed cost.

“FIRM was an ideal solution, becauseit guarantees no change orders and noextra expenses,” says Steve Figgins,BC’s Western Business UnitEnvironmental Services practice leader.Brown and Caldwell proposed thefixed-price remediation approach andwill complete the work.

“We will be paid when we meet setperformance milestones throughoutthe project. The final milestone,” headds, “will be a closure letter from theregional water quality control boardstating that no further action will beneeded.”

Transferable guaranteeThe remediation plan includes dualphase, vacuum-enhanced soil vaporextraction, injection of HydrogenRelease Compound™ into groundwa-ter injection wells, monitoring andrestoration of the site. The cleanupprocess, Figgins adds, should takeapproximately seven years.

“An added benefit of the FIRMapproach,” he explains, “is that it’stransferable from seller to buyer. If thelandowner sells the property at anytime during the remediation project,the new owner will enjoy the samefixed price and guarantees.”

For more information, contactSteve Figgins at (714) 689-4863or [email protected].

FIRM ANSWERThe Fixed-price RemediationMethod (FIRM) offerssolutions, guaranteesand no surprises O

ne of the most commongeologic materials onearth, silica is the main nat-ural ingredient found inmore than 75 percent of

soil and rock materials. Any processthat digs, drills or crushes rock, sand orsoil—or that uses silica-based com-pounds in grinding or sanding—canproduce fine particles of silica dust.And prolonged, unprotected exposureto high concentrations of crystalline sili-ca dust can cause silicosis, an occupa-tional illness that inhibits the lungs abili-ty to absorb oxygen.

“This isn’t a new issue,” notes SteveTrussell, Community Relations directorof the Arizona Rock ProductsAssociation (ARPA). The federal gov-ernment, he adds, has been regulatingoccupational exposure to silica dustsince the 1970s.

Many years ago, however, “employers

didn’t always take appropriate action,”says Corporate Attorney Luke Narducciof Bryan Cave. “As a result, we’re notingincreased occupational health claimsfrom previous silica dust exposure.”

High priorityToday, explains Trussell, protectingworkers and the surrounding communi-ties from exposure to silica dust is a toppriority.

“The mining industry,” he says, “is fullyaware of the potential health effectsand is taking every precaution to reducesilica dust emissions and exposure.These include the most up-to-date sup-pression methods and a great deal ofemployee training.”

A lot of controls are already in place,says Eric Mears, BC’s national miningmanager. “But with all the new case lawand litigation, we need to help compa-nies focus more effectively on a wide

SILICA SAFETYReducing exposure to dust

range of solutions—monitoring airemissions, designing engineering con-trols and creating targeted outreachand training programs.”

Companies, he says, can minimize oreliminate dust sources by employinglow-cost control methods like wet sup-pression, as well as more modern dust-control methods like filters and dry col-lection enclosures. Other steps includethorough maintenance and housekeep-ing practices, regular education ofemployees and mandatory use of per-sonal protection equipment.

Brown and Caldwell, adds Trussell,has already helped ARPA create educa-tional materials, as well as training andoutreach programs, for members andthe public on the silica dust issue.

“By employing aggressive dust-con-trol practices and working cooperativelywith federal, state and county agencies,”he says, “we’re working to ensure com-pliance and meet all government emis-sions and exposure standards.”

For more information, contactEric Mears at (602) 567-3859 [email protected].

“Supervisors can also use the systemto monitor plant performance, conducttrend analysis, assess compliance capa-bility, identify operations issues, gener-ate reports and validate data entries,”explains Dennis Mulacek, developmentand technical support leader for theprogram.

In addition, the system’s data-entrymodule communicates directly with itsreporting module to produce theAnnual Title V Compliance CertificationForm for submission to the U.S.Environmental Protection Agency, as well as state-specific agencyreporting forms.

“EMIS is an attractive alternative formanaging compliance,” Claffey says,“and has the flexibility to adjust tochanging operating and permitconditions.”

For more information, contactJim Claffey at [email protected] (770) 673-3663.



configuration, these methods may be the best technical and most pragmaticoptions.

So, what if the regulatory agency doesn’t accept your proposed minimal-action alternative? Answer: negotiate, negotiate, negotiate. And be sure to do alittle “selling” along the way. Many regulators today are driven to get “businessdeals done.” In some states, priority projects are those involving property trans-actions that fuel the “business engine.”

Bring regulatory agency decision makers into discussions early and often. Sellthem on your conceptual model and corrective action plan early, and provideinstructive materials on the successes of the remediation method you’re propos-ing. Their goal is to clean up the site—so show them how you’re going to getthem there, even if your proposed methods don’t match their concepts or expe-rience. In short, use the regulatory process to your best advantage, always keep-ing the site’s end use in mind.

3. Be proactive.The largest environmental costs are often those that are reactive and unplanned.Since many Superfund-type discoveries are behind us, hopefully fewer opera-tions will fall into this trap. Nevertheless, many spills, leaks, discharges andcommunication breakdowns can be prevented with a structured environmentalprogram.

Instituting an environmental program, or beefing up a current one, can becostly. Therefore, it is critical to establish metrics and a measurement programto clearly quantify the costs and benefits. Cost aversion and liability reductioncan be tricky to quantify. Key cost metrics for an operation, however, can bereflected in fines assessed and paid, worker compensation claims, waste disposaland remediation costs and historical trends in the number of Notices ofViolation issued.

A structured environmental program can positively affect these trends. Oneimportant strategy is to conduct annual, active compliance audits of your facili-ties—considering air, soil and water matrices—with a focus on waste generationand product life cycle. The program might also include more due diligence andrisk assessment of property transactions, including acquisition, divestment orleasing scenarios.

Programs pay offBrown and Caldwell has been working closely, for example, with Rental ServiceCorporation (RSC)—a large tool and equipment provider—to put environmen-tal programs in place at its 500 rental locations throughout the United States,Canada and Mexico.

As RSC’s Risk, Safety and Environmental Director Pricilla Oehlert recentlystated, “The costs for these environmental programs clearly show dividends byreducing your activity on the radar screens of the regulators. We are avoidingfuture remediation costs because we are advancing environmental policies andprocedures that create a heightened culture of awareness.”

Adopting a strategic environmental management system can also align yourentire organization, from suppliers to consumers, with your operation’s environ-mental policies and procedures (see sidebar). In every case, a more structuredenvironmental program can help you make incremental programmatic changesthat bring bottom-line value to your operation.

At BC, our seasoned technology and business leaders deliver services national-ly, regionally and locally, using our teamwide expertise to provide clients withthe best, most efficient technical solutions. Feel free to contact any of ourregional Environmental Services practice leaders. They’ll show you what we cando to help lower your environmental costs.

The Benefits of Strategic EnvironmentalManagementA wide range of operations, in both the public and private sectors, are reap-ing the benefits of strategic environmental management. It’s a way of cap-turing your environmental information, planning your environmental strate-gies and linking your environmental programs to your overall operation.

Many enterprises, including international businesses like Ford MotorCo., have adopted formal environmental management systems such as ISO14001, a standard that was developed in Europe. Others have opted for lessformal, more tailored approaches that incorporate the key concepts andprocesses of strategic environmental management.

Direct cost savingsIn all cases—whether the operation is in the federal, municipal or privatesector—it’s an approach that deals proactively with environmental issues,problems and challenges. The result? Significant direct cost savings by:

• avoiding liability• reducing insurance costs• eliminating fines• avoiding spills and cleanups• lowering worker’s compensation costs• reducing lost-time incidents

Benefits also include improved productivity, community and public relationsand an internal culture of environmental awareness and responsibility.

Brown and Caldwell’s team of environmental experts can help youplan, implement, measure and monitor a strategic environmental manage-ment system that’s tailored for your operation. It’s a cost-effective solutionthat can minimize reactive, expensive incidents, employ the best informationtechnology approaches and link your environmental decision making toother strategic aspects of your enterprise.

For more information, contact Ed Ricci at (602) 567-3917or [email protected].

Steve FigginsWestern EnvironmentalServices practice leader, (714) 689-4863

Phil LagasSouthwest EnvironmentalServices practice leader,(602) 567-4000

Jeff PintenichEastern Environmental Servicespractice leader, (615) 255-2288

Continued from page 1


Many smaller organicchemical manufacturingplants, including batchproducers of specialtychemicals, will face new

wastewater system compliance issuesas a result of the MON—MiscellaneousOrganic NESHAP (National EmissionStandards for Hazardous AirPollutants).

The MON is a new MaximumAchievable Control Technology (MACT)regulation addressing hazardous airpollutant (HAP) emissions. Althoughprevious rules regulated HAPs at chem-ical manufacturing facilities, there weregaps in emission sources that were cov-ered. The MON is intended to addressthose regulatory gaps.

As a result, many affected chemicalplants will face compliance issues newto them. They must make precisedeterminations regarding how theMON’s concepts of a “process unit”apply to their specific operations. Then,for the MON’s wastewater provisions,they need to establish characteristics ofthe waste stream leaving the processunit to determine whether air emissioncontrols are required.

THE NEW MONMeeting new air emission control requirements for wastewater systems

Expert assistanceAccording to BC’s Industrial WaterQuality Practice Leader Joe Cleary, P.E.,D.E.E., each one of these decisions willhave costs and may significantly impactthe profitability of particular products.

“In-process wastewater managementis crucial to cost-effective MON compli-ance,” he explains. “The MON definesthe ‘process’ in such a way that includesactions sometimes considered to bewastewater management or treatment.As a result, strategies for MON compli-ance require fresh looks at the wholemanufacturing system.

“Brown and Caldwell,” Cleary adds,“has successfully navigated MACT com-pliance pathways to the benefit ofclients in the organic, chemical, refineryand pharmaceutical industries. With ourfamiliarity with chemical processes andexpertise in wastewater conveyance andtreatment, we’re able to deliver innova-tive designs and operational support toclients as they begin planning their newstrategies for MON compliance.”

For more information, contactJoe Cleary at (201) 574-4721.

In May, 20 Brown and Caldwell

Environmental Services staff

took center stage in Monterey at

the prestigious Fourth

International Battelle Conference

on Remediation of Chlorinated and

Recalcitrant Compounds.

BC’s participation in the three-day

conference included five podium pre-

sentations, 11 posters and four session

co-chairs. BC also sponsored a techni-

cal breakfast highlighting innovations in

site investigation and remediation.

Several BC papers demonstrated the

application of innovative technologies

developed by BC personnel.

FOCUS ON REMEDIATIONBattelle Conferencespotlights BC experts

UARTERNOTES

Leader in remediation

“The conference demonstrated our

capabilities and further branded BC as a

leader in the environmental services

industry,” says Vice President Steve

Figgins, who coordinated BC’s partici-

pation with Principal Engineer Jim

Claffey and Senior Technical

Coordinator/Analyst Maria Albert.

“It was a great opportunity,” he adds,

“to show our major and potential clients

that Brown and Caldwell is exceptionally

solutions-oriented and on the cutting

edge of remediation technologies.”

For more information, contact

Steve Figgins at (714) 689-4863

or [email protected].


SIMPLIFY - Brown and Caldwell

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