As a solution to an integrated oil client’s liability reduction goals, Antea Group executed a liability transfer contract for the known and unknown pre-existing environmental liability for a portfolio of 146 active retail fuel outlets in the Mid-Atlantic. Of the 146 facilities, 38 had active incidents being managed by others at the time of the liability transfer. Most of the active incidents had been open for at least ten years prior to the liability transfer and were at various stages of assessment and remediation. In addition to the 38 active incident facilities, four new incidents were opened at four different facilities subsequent to the liability transfer that became a part of Antea Group’s overall liability to manage.
Solution
Upon execution of the liability transfer, Antea Group immediately engaged the designated project team with senior level technical experts to perform a technical review of each active incident site to complete a technical data gap analysis and clearly define regulatory closure end points and the scope of work and schedule to achieve those end points. Inefficiencies and existing remediation technology failures were identified and revised corrective action strategies were developed to reduce project cost and lifecycle. Face to face meetings with each of the state agency case managers took place to discuss each active incident site and obtain regulatory agreement on incident closure end points and the path to achieve those end points. By involving the regulatory case managers as stakeholders in the decision making process with Antea Group, project lifecycles and incident closure rates were accelerated.
Result
For those active incidents that could not be closed using risk-based arguments, Antea Group implemented various methods of localized corrective action such as in-situ bio-enhancement, in-situ chemical oxidation, excavation source removal, and mobile air sparge/soil vapor extraction to reduce contamination levels to incident closure end points. Localized remediation combined with detailed risk-based closure arguments have allowed Antea Group to close 36 of the 42 active incidents within a six year window, with the remaining active incidents on a clear path to achieving closure within the next few years.