Transitioning from an “active” to “passive” remediation system
Do you have a long term environmental O&M commitment that your company’s not happy with?
Since the early 1980's, corporations have had a legal obligation to respond to various environmental programs. Whether CERCLA, RCRA, State, or other regulations there are commonalities in the lifecycle costs and the dynamic of the government agency/regulated community interaction.
Many former manufacturing or operational legacy sites have had a long tortured history of contentious/litigious negotiations that have left long term environmental O&M requirements that none of the stakeholders are particularly happy with.
Also, given how much time and expense was spent on outside consulting and legal assistance during the original enforcement action, that experience has left many PRPs unwilling to go back to the table with the regulators to try to negotiate something new, with the potential of going from bad to worse.
We at TEA have been successful leading the change of old remediation systems from “Active” to “Passive.” It can be done in one large step or alternatively, many baby steps can be taken to establish proof of concept and develop definitive financial forecasts.
Regulatory acceptance must be gained and in our experience many times the regulators are waiting for some new consultant to come in and to act as the change agent.
We have developed some guidelines for this phase of O&M optimization:
- Assure the site remains in compliance.
- Protect the receptor
- Effectively shut down routine maintenance
- Eventually run all “necessary” remediation passively
- Continue contaminant mass reduction
- Reduce expenditures
- Keep the same level of performance
Using insitu techniques that TEA has pioneered over the last two decades we can help you craft a new remediation strategy that will meet approval from your regulators and senior management while driving your compliance costs down.
For more information contact: Michael Tischuk, Director of California Operations at email@example.com or by phone at 925.247.5333.