EHS Support has been retained as the Supervising Consultant for a large Superfund site located in western Kentucky along the Tennessee River. The site is co-located with several active chemical manufacturing facilities, and its remedy consists of eight major remedial components:
- Lining an open ditch stormwater system to prevent erosion and discharge of impacted soils to the Tennessee River
- Closing two former wastewater ponds with a combined volume of 142,000 cubic yards
- Constructing a 3-mile-long subsurface barrier wall that will extend from ground surface to bedrock 100 to 150 feet below ground surface
- Installing a hydraulic control system with an associated water treatment plant that will work in conjunction with the barrier wall to capture contaminated groundwater and prevent it from discharging to the river
- Recovering on-site non-aqueous phase liquid (NAPL) from an estimated 1-3.5 million cubic yards of soil impacted with organic and mercury NAPL
- Dredging and capping a barge slip integral to the facility while maintaining access for daily unloading and loading during the work
- Recovering offshore organic NAPL from under the Tennessee River to facilitate remediation of the groundwater plume
- Remediating groundwater under the river
WORK SCOPE
As Supervising Consultant, EHS Support is responsible for:
- Controlling all aspects of the project, including contractors that the Respondents retain to perform the remedial design and remedial action (RA) work;
- Measuring project performance against budget, schedule, scope, and quality; and
- Ensuring all RA work is completed as specified in the Record of Decision for the Site and is acceptable to the Respondents, the United States Environmental Protection Agency, Kentucky Department for Environmental Protection, other stakeholders, and property owners.
The project presents key challenges, such as the following:
- The scope comprises a multi-media, multi-component remedy:
- Seven active on-shore components (plus one technical impracticality component)
- Two active off-shore components (river groundwater component currently deferred)
- Major capital expenditure (CAPEX) components associated with containment and exposure mitigation
- Major CAPEX and operating expenditure components associated with long-term NAPL removal and hydraulic containmenTAn active plant coupled with near-shore and in-river work adds significant complexity and impacts schedule and budget.
- Conflicts exist with the current contracting model, impacting the control of scope, schedule, and budget.