We have previously discussedspill responseactivities for sites where an active release occurred and identified key factors in addressing spills. For historical release sites that were not addressed or sites which have undergone insufficient remediation of contaminated media (soil, surface water, groundwater), it is important to formulate a complete site remedial strategy to establish what the end goal will be for site clean-up. Utilizing regulatory guidance, along with identified site-specific characteristics, allows for flexibility in site clean-up approaches.
Consistent Remediation Strategy
It is very important to establish what the key drivers are for the site-specific contaminants. Whether it is crude oil, condensate, refined product, produced water, or stored materials on Site — developing a sampling program to address the extent of affected media will allow for consistency in evaluating data and presenting information to the regulatory agency. It is equally important to develop consistent field screening methods and action levels to determine the extent of excavation or assessment. The goal is to determine what action levels will address Site concerns while balancing remediation costs to minimize the volume of contaminated media being taken off site.
Site Conditions
Additional considerations in evaluating the remediation process are conditions at the site, such as the areas accessible to complete controlled work. Can you pursue a permit and treat affected media on-site to reduce disposal costs? Is it feasible to create Land-Use Restrictions and negotiate alternate clean-up levels with the regulatory agency? What are the closest waste disposal facilities and where are they located? The potential for on-site remediation needs to be evaluated against loading, hauling, and disposal costs. At many sites, it is easier to dig and haul out than it is to address affected media on-site; however, there are cases where the long-term solution would be for on-site treatment rather than a large trucking bill.
Communication
Lastly, communication is key. Know what your action levels and end goals are, communicate with regulatory officials, and know what scope your contractors are performing. There are a lot of aspects to manage during Site remediation and leaving affected media in place results in an unexpected future liability that you will have to address again.
在处理修复项目时,必须考虑许多因素以确保顺利运行。项目经理必须了解现场条件,以保持项目安全,高效和经济。为该项目的范围开发一致的行动计划和现场筛选方法也是会议和维护清理目标的关键。请记住,与监管官员,承包商和其他利益相关者频繁和彻底沟通,这是一个成功的修复项目的基础。
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