CHAPTER 4 TOWARDS MORE EFFICIENT GROUNDWATER REMEDIATION

JurisdictionUnited States
Ground Water Contamination
(May 1991)

CHAPTER 4
TOWARDS MORE EFFICIENT GROUNDWATER REMEDIATION

Adrian Brown, P.E.
Adrian Brown Consultants, Inc.
Denver, Colorado


INTRODUCTION

In the film "Network", a news anchorman, played by the late Peter Finch, throws up the window of his apartment and shouts across the skyline of New York: "I'm mad as hell, and I'm not going to take it any more!". He is mad about the state of the world, and he proposes to commit suicide on national TV to show how hopeless he considers things have become.

There have been times in the last few years that I have had the same feelings toward the environmental industry, in particular in the area of groundwater remediation. I see a considerable problem, great public and corporate desire to address the problem, an enormous amount of effort directed at the problem, yet very little effective progress. When I was invited to speak before this gathering, I thought it might be useful to address myself to the reasons for this apparent failure. I have now been trying to write this paper for more than a month, and it is proving as difficult to write as it has been difficult to achieve progress in the projects in which I am involved. I am beginning to think that the two difficulties have the same genesis.

It is easy to see villains in the environmental process. Consider the following list, with commonly cited attributes (not necessarily reflective of the beliefs of the author):

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• corporations, who are assumed to seek to maximize profits by minimizing expenditures on environmental matters, and who hate to be pushed around, particularly by environmental activists;

• consultants, who are accused of maximizing the technical difficulties of groundwater projects in order to create more work unraveling the complex situations so created;

• regulators, who appear to have no particular incentive to reach a decision on the method for achieving remediation, and who have no incentive to signify that the remediation is complete;

• politicians, who seem to delight in pointing out the problems, but whose solutions appear to have little scientific or technical merit;

• intervenors, who appear to be able and willing to capitalize on the inherent scientific uncertainties and regulatory inefficiencies in groundwater remediation in such a way as to prevent or delay progress, even when the constituency which they represent is harmed by this delay;

• lawyers, who appear to have nothing to gain by bringing any environmental matter to closure, and everything to gain by extending and complexifying the matter;

• the press, who have consistently taken the populist view of environmental matters, and have turned the decision-making process into a referendum amongst those least well qualified to render a decision; and

• the public, which frequently takes a simplistic view of contamination and its remediation, and often overlooks important secondary impacts of the "obvious" answers.

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Is there nobody of character out there, fighting the good fight? My experience is that each of the above groups considers itself to be doing exactly that, and that the above caricatures do gross injustice to the reality. It is sad that such a large group of individuals and corporations, spending such a large amount of money, cannot find enough common ground to achieve more than the current meager remedial dividend.

This paper seeks to examine what is actually going wrong with the process by looking at two groundwater remediation projects that are relatively successful by technical standards, reviewing their glacial institutional progress, and exploring the reasons that progress has been so slow. It concludes with some recommendations based on the findings of that examination, with particular emphasis on the contribution that the participants in this conference can make.

KNENERGY'S HYDROCARBON CLEANUP AT BROOKHURST

The first case history that I wish to present concerns the cleanup of a hydrocarbon discharge that occurred at the KNEnergy Inc. (KN) Gas Processing and Compressor Station in Evansville, Wyoming (just to the east of Casper, Wyoming). The compressor portion of the plant has been in operation since 1923. In 1965 KN purchased the plant, and added a gas processing module for beneficiation of the gas, and extraction of petroleum products from the gas stream. This processing module circulates a hydrocarbon product known as absorption oil to remove the petroleum products from the gas stream; the products are stripped from the absorption oil and sold. The refined gas is then compressed and shipped via KNEnergy's pipeline system.

Since the inception of the processing plant operation, some of the absorption oil has been lost from the plant, both by pipe breakages

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and by seepage from the process into the soil beneath the plant, and thence to the water table. As a result, the soil has been contaminated1 by hydrocarbons, the groundwater has been observed to contain measurable levels of petroleum product constituents (in particular benzene), and there has been observed a floating product on the water table which occasionally exceeds one foot in thickness. It is estimated that a total of 100,000 gallons or more of petroleum product has been lost to the environment in the 25 years since the plant was commissioned.

The KN facility was listed on the National Priority List under CERCLA in 1987, as part of a site known as the "Highway 60/Mystery Bridge Road Site", which is generally known as the "Brookhurst Site". Following the listing, in 1987 KN eliminated the two practices which resulted in long-term leakage of absorption oil: disposal of used absorption oil to an unlined "flare pit", and use of absorption oil for cooling bearings. In 1988 KN initiated a detailed investigation of the extent of petroleum product contamination at and near the site. This study disclosed that an area of about 4 acres had been contaminated, including soil and groundwater. At the time no floating product was discovered; subsequently product has been observed on the water table. The principal contaminant of...

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