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The Kentucky Chamber of Commerce’s upcoming 12th Annual Kentucky Environmental Conference on Feb. 20-21 in Lexington, KY

The Kentucky Chamber of Commerce's upcoming 12th Annual Kentucky Environmental Conference on Feb. 20-21 in Lexington, KY will include two presentations by Linebach Funkhouser, Inc. (LFI) personnel.  On February 21st, Bill Johnston, Principal Geologist, will speak on Soil and Groundwater Remediation Issues and Case Studies. Also on the 21st, Roy Funkhouser, Principal, is teamed with Shawn Cecil of the Kentucky Department for Environmental Protection and Kelly Bartley of Bingham Greenebaum Doll to give a Keynote Presentation on Liability Protection Under Kentucky's Brownfield Redevelopment Program.

A Happy Ending at KY Landfill

Happy Hollow

By Mary Jo Harrod

In 1962, the city of Middlesboro granted a household garbage franchise to Roy Shoffner and Sam Mars to operate a landfill in Happy Hollow, a narrow valley of 14 acres. Though the city made garbage pickup mandatory, illegal burning and dumping were constant problems at Happy Hollow.


Bulldozers covered garbage and burned materials, but vegetation grew until trees were 20 feet tall. By 1974, the two business partners decided to sell the franchise and garbage trucks back to the city and close the landfill.

 

Though it was closed and posed no immediate threat to human health and the environment, Happy Hollow was still on the state's list of uncontrolled landfills and considered to be a brownfield. In 2007, Shoffner & Mars, LLC voluntarily began the appropriate regulatory landfill closure process.

 

"There was never a threat to the water supply and no methane was ever detected," says Sammy Mars, son of one of the original owners of Happy Hollow. "We contacted Linebach Funkhouser Inc. for assistance in proceeding with the remediation of the landfill and bringing the site into compliance for closing. We wanted to protect the environment and later chose to develop the site."

 

Phase I consisted of adding 20 more feet of soil cap, implementing a passive vapor barrier and constructing a landfill cap. A monitoring well extends to the bedrock in the hollow and is checked every six months, though it has been problem-free. Phase II entailed removing 150,000 yards of dirt from a hillside to raise the property level and create flat areas for business. A communal asphalt parking lot for the hotels sits on a portion of the site.

 

Being a privately held company, Shoffner and Mars, LLC is ineligible for U.S. Environmental Protection Agency brownfield cleanup grants. However, the company recognized the potential and spent its own money for the project. The earth-moving cost alone for Phases I and II was $1.2 million.

 

The property had a 60-room Holiday Inn-Express that stayed at capacity and could not be expanded. But at the project's end in 2010, a second hotel, a 50-room Sleep Inn, opened on the site. The property is located on the border of Middlesboro's central business district at the town's main stoplight. Between the two hotels, they now generate 60 percent of tourist tax revenue for the area.

 

Middlesboro is in a flood-prone area. Before the project, the hilly land was valued at $10,000 per acre. After moving dirt to create level areas higher than the flood zone, the land's value is $200,000 per acre.

 

"There were project challenges, such as with the leachate collection system, which had to be re-engineered," says Charles Leachman, senior geologist from Linebach Funkhouser. "The state wanted us to use a specific type of stone, which was difficult to find, to set around lines to improve drainage. Also, we encountered waste further down the hill than we anticipated and had to be careful to keep it from rolling down the hill."

 

In redevelopment cases such as this, Leachman recommends bringing a good conceptual project plan to the regulatory agency and asking for advice in case something has been overlooked. Working proactively in this manner makes a project go more smoothly and often prevents delays in the redevelopment process.

 

Middlesboro is an economic hub for the Tri-State region of northeast Tennessee, southwestern Virginia and eastern Kentucky. The new hotel and parking lot fill a need for the area, which is near the Cumberland Gap Tunnel. With a shortage of hotel rooms before the Sleep Inn was built, the community's response has been positive.

 

"For Middlesboro, this project has the Wow! Factor," says Mars. "The landfill is gone, and a new hotel is on-site. The community has pride in the results of the project, which is a prime example of the state working with private industry."

 

Though no chemicals or hazardous wastes were ever known to have been accepted at the property, Shoffner & Mars went beyond what was required by law to protect the environment. The community has benefited from the revitalization of the area and creation of jobs.

 

Mary Jo Harrod is Public Information Officer, Energy and Environment Cabinet, Division of Compliance Assistance, Frankfort, KY.

In-Situ Remediation

By Bill Johnston, PG

InSitu

Linebach Funkhouser, Inc. (LFI) personnel performed permanent closure, assessment and corrective action activities on (UST) systems at a former retail petroleum facility located in Louisville, KY. Three gasoline/diesel USTs were removed from the subject site in 1997.  During the removal of the USTs, a large amount separate phase product was observed leaching into the common tank pit area.  Product recovery procedures were immediately initiated to mitigate the contamination concurrent with notifying the appropriate agencies including the Kentucky Department for Environmental Protection (KDEP), Division of Waste Management, Emergency Response Section and the State Fire Marshal's Office.  Following the completion of the removal and initial abatement procedures, several documents including Initial Abatement, Product Recovery and UST Permanent Closure reports were filed with the KDEP, DWM, and Underground Storage Tank Branch (USTB) on our client's behalf. Several assessments were completed to define the horizontal and vertical extent of the separate phase and dissolved petroleum contaminant plumes identified in the shallow groundwater.  LFI personnel enrolled our client in the USTB Petroleum Storage Tank Environmental Assurance Fund (PSTEAF) in an effort to recover eligible costs for assessment and remediation.

 

A corrective action plan (CAP) was written for the site with the assistance of AST Environmental (AST) of Midway, Kentucky that proposed utilizing a "cutting edge" in-situ remediation technology. The technology developed by Remediation Products, Inc. (RPI) of Golden, Colorado known as BOS 200® is a Trap & Treat® Bacteria Concentrate applied with a high velocity/high pressure delivery system designed and implemented by AST. This combined product-delivery remediation technology was outlined in the CAP that was submitted and approved by the USTB.

 

Prior to implementation of the CAP, subsurface impacts consisted of petroleum hydrocarbons in soils, accumulation of light non-aqueous phase liquids (LNAPL) in three monitoring wells and aqueous phase (dissolved) benzene in groundwater as high as 11 milligrams per liter (mg/L). The impacted area immediately surrounding the former tank pit, occupied approximately 7,000 square feet of the approximately 3-acre site.

 

LFI and AST teamed to develop a remedial approach to address the LNAPL and dissolved phase petroleum hydrocarbon impacts at the site.  Specifically, an injection design was prepared and implemented to address LNAPL and dissolved phase petroleum hydrocarbons. The goal was to inject BOS 200® to remediate the site for removal all the LNAPL and reduce benzene concentration to below 0.005 mg/L in the on-site monitoring wells.

 

On Friday, August 19, 2011, 20,400 lbs of BOS 200® was delivered to the subject site.   On the morning of August 22, 2011, AST mobilized personnel and equipment to the site and setup for the injection effort to begin that day.  The injections were completed in 8 workdays with AST injecting the 20,400 pounds (lbs) in 150 injection points to approximately 14' below grade surface. AST prepared BOS 200® slurries and injected it into the subsurface through probe rods. The slurry is pumped through the probe rods using a positive displacement diaphragm pump capable of delivering 1,200 pounds per square inch (psi) at 35 gallon per minute (gpm).  The injection pressure varied from 200 to 600 psi.  The pressure injection scheme created extensive "fracturing or soil lifting" of the soil to create preferential pathways within the fine grain clay which are filled with BOS 200®. The injection effort was completed on 8/31/2011.

 

The post injection monitoring reports from July and October 2012 reveal that the full list of analytes and all constituents of concern (COCs) were well below the CAP and EPA defined clean-up goals. Based on these results KY-USTB issued a No Further Action for the site on December 20, 2012

The Flow Below

By Brendan Merk, Senior Hydrogeologist

In February of 2013, as part of LFI's ongoing professional training and development program, the LFI staff was provided a technical presentation by Mr. Joseph Ray, a certified Professional Geologist and published author of many papers dealing with dye tracing and subsurface flow. A renowned karst specialist, Mr. Ray provided information on the flow of groundwater below actively running rivers - water features typically considered natural barriers to subsurface flow.

 

Kentucky features one of the most famous karst areas in the world, and much of the State's manufacturing base overlies it. Karst environments are well known for topographic features such as sinking streams, caves, and springs. In areas of well-developed karst, such as the Mammoth Cave area, subsurface flow is considered the norm and surface water streams and rivers are rare.

 

Geologists and engineers are routinely taught that water will flow downhill to join a river or stream at the surface, even when that water flows underground. Conventional wisdom is that the river will act as a natural barrier - the stopping point where groundwater flow becomes surface water flow. The only rule with karst though, is that normal rules just don't apply. Failure to understand and property interpret subsurface flow can lead to significant errors in determining where contamination may be going, and how much it's going to cost to clean it up.

 

Mr. Ray presented compelling evidence that the flow of groundwater through fractured rock beneath overlying rivers and streams is more commonplace than has been historically believed. Pathways of preferential flow make it possible for water to disappear underground for a distance, only to appear again later as a spring. These subsurface pathways are not connected to flow at the surface however, making it possible for the water sink and the spring to be on opposite sides of the river.

 

Karst environments with fractured rock flow occur in varying degress in all the states surrounding Kentucky. Mr. Ray emphasized that geologic knowledge of such features is important, as is the ability to apply that information to a given situation. He provided an example of a city in Kentucky where a municipal water supply at a spring turned out to be originating from a water sink just downhill from the city's sewage treatment plant.

 

Following his presentation, Mr. Ray entertained several questions from LFI staff. Mr. Ray's presentation is one of several technical lectures and training sessions in which LFI staff will participate in 2013. Training and continuing education are a part of life at LFI, and a cornerstone in producing exceptional work for our clients.

Linebach Funkhouser Receives Subcontracts for Ohio River Bridges Project

Linebach Funkhouser, Inc. (LFI) was recently awarded two subcontract agreements with Walsh Construction Co. and Jacobs Engineering Group, Inc. to manage environmentally affected materials that may be encountered during upgrades to Spaghetti Junction and the new Downtown Crossing over the Ohio River in Louisville, Kentucky. LFI will serve as the Contaminated Materials Manager under the subcontracts. Affected soils and other materials resulting from historical operations of various industrial and commercial properties within the footprint of the construction must be properly characterized and managed in accordance with regulatory requirements.

LFI will provide project-wide management of affected materials including development of Site Management Plans, Materials Management Plans, Corrective Action Plans, Construction Monitoring Plans, and Environmental Health and Safety Training, as needed, for site workers.

 

Call Before You Dig

By: Russell H. Brooks, P.G.

Senior Engineer

The federally-mandated, national "Call Before You Dig" number, 811, was created to help prevent unintentionally hitting underground utility lines while working on excavation, drilling, or similar subsurface projects. People often make risky assumptions regarding marking utility lines due to concerns about project delays, costs, and experience (or luck) with other projects in which utilities were not marked. These assumptions can be life-threatening.

Every excavation/drilling job requires a call - even small projects like planting trees or shrubs. Hitting an underground utility line while digging can seriously harm you or those around you, disrupt service to an entire neighborhood or industrial park, and potentially result in significant fines and repair costs.

Waterline on top of USTs

The 811 system will notify member utilities; however, in many cases small local municipalities are not members of the 811 system.  Therefore, it is your responsibility to identify and contact non-member utility providers.

Typical environmental jobs often include subsurface activities, such as drilling soil boring and groundwater monitoring wells, and excavating to remove impacted soils, waste materials and underground storage tanks (USTs).  The 811 call should be made 48 to 72 hours prior to commencing work on all subsurface operations.  Depending on individual state laws, you must account for holidays and weekends, so do not call on Friday and expect the utilities to be located on Monday.

Soil boring 4 inches from gas line marking

An 811 utility locate request will only mark utilities up to the service meter for the property. It is the responsibility of the contractor to ensure that all utilities beyond the meter are properly located and marked prior to the start of work.

In cases of large coverage areas, the utility clearance company has the right to request work area demarcation prior to marking the utilities.  Identifying work areas on large sites helps to minimize the locator's time on-site, and also confirms that utilities in work areas have been marked.

Site utilities will be marked with paint and flags.  The following universal color system indicates what is buried below the surface:

  • Red - ElectricMultiple lines
  • Orange - Communications, Telephone/CATV
  • Blue - Potable Water
  • Green - Sewer/Drainage
  • Yellow - Gas/Petroleum Pipe Line
  • Purple - Reclaimed Water
  • White - Area of Intended Excavation/Subsurface work (marked by contractor)

Once the utilities are marked it is the excavator's/driller's responsibility to avoid damaging the utilities.  Although no specific "hand-dig" zone is outlined in the Call Before You Dig law; the American Public Workers Association and several industry-accepted Best Practices recommend hand-digging 18″ on either side of the utility markings to a depth of 24". It is recommended that shovel excavation or a similarly gentle method of excavation take place in the hand-digging zone to uncover utilities prior to proceeding with more powerful equipment.

For more information about the national 811 system, visit http://www.call811.com

Linebach Funkhouser Awarded Multiple, Two Year Environmental Contracts with the Kentucky Transportation Cabinet

Linebach Funkhouser, Inc. has been awarded two contracts with the Kentucky Transportation Cabinet-Division of Environmental Analysis.  One is a two year contract for Statewide Underground Storage Tank/Hazardous Materials Services (UST/HazMat).  This is a work order-based contract with a value of $2,000,000. Services for this contract include investigating and remediating UST/HazMat sites on highway right-of-ways prior to highway construction.  Linebach Funkhouser has been providing these services as a pre-qualified consultant since 2003.

The second is a two year contract for Statewide Environmental Investigations and Remediation Services for Kentucky Transportation Cabinet-owned facilities.  This is also a work order-based contract with a value of $2,000,000.  Services for this contract include Comprehensive Environmental Response, Compensation, and Liability Act (CECRLA) and Resource Conservation and Recovery Act (RCRA) based site assessments, evaluations, remedial plans and compliance reviews in accordance with RCRA, CERCLA, the Clean Water Act and related US EPA regulations, and Kentucky UST regulations.  This contract covers facilities located in Highway Districts 1-6.  Linebach Funkhouser has been providing these services as a pre-qualified consultant since 2006.

Linebach Funkhouser is a pre-qualified consultant with the Kentucky Transportation Cabinet in the following areas:

  • HAZMAT Preliminary Site Assessment
  • HAZMAT Site Reconnaissance
  • HAZMAT Remediation Services
  • UST Preliminary Site Assessment
  • UST Leak Detection/Monitoring
  • UST Removal/Disposal
  • UST Site Remediation Services

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Mr. Russell Brooks, manager of these contracts, has worked with Linebach Funkhouser, Inc. for nearly 10 years.  In his current role, Mr. Brooks leads the government services group assisting various local, state and federal clients with soil, water, and waste issues.  Mr. Brooks can be reached by calling 502.895.5009.

Successful Year of Groundwater Remediation

By: Russell H. Brooks, P.G.

Senior Engineer

 

Linebach Funkhouser had a successful year in 2011 remediating petroleum and mixed chlorinated/petroleum contaminated groundwater plumes at several sites across Kentucky. Through the efforts of 4 project managers, LFI has received, or is soon to receive, "No Further Action" letters from the Kentucky Department for Environmental Protection, Underground Storage Tank Branch and the Superfund Branch on a total of eight sites. Six of the sites were the result of petroleum contamination due to historical operations and one site had a release of a combination of chlorinated solvents and petroleum compounds. At six sites, LFI utilized BOS200® and Trap & Treat® a product sold by Remediation Products, Inc. (RPI), which is a specially-formulated blend of activated carbon, sulfate reduction media, micronutrients, and facultative microbes. The seventh and eighth site involving chlorinated solvents was remediated using FMC, Inc's. Klozur®CR, which is a single, formulated product consisting of high pH - activated Klozure Persulfate and PermeOx® Plus engineered calcium peroxide. The addition of the remedial products was through the use of Geoprobe® borings and high pressure injection as well as open-hole soil mixing. Based on groundwater sampling activities, LFI found that BOS200®rapidly reduced or eliminated the identified BTEX contamination to below MCLs at 5 of the 6 sites, with the 6th site being reduced to below its site-specific screening limits based on sampling approximately 3 to 4 months following injection. Long term monitoring (1 year after injection) at the sites did not indicate contamination rebound. LFI conducted long term monitoring (two years of quarterly sampling)of the Klozur®CR site and it also did not indicate contaminant rebound. Below is a chart showing a summary of the sites, area of impact, and material used to successfully obtain closure.

Summary of Sites and Material Applied

Site Location

Area in square feet

Constituents of Concern

Material Applied

Louisville*

5,525

BTEX/PAH

BOS200®

Louisville

3,000

BTEX

BOS200®

Lebanon

3,155

BTEX

BOS200®

Shelbyville

4,000

BTEX

BOS200®

Campbellsville

2,650

BTEX

BOS200®

La Center

570

BTEX

BOS200®

Elizabethtown

1,225

Chlorinated Solvents/BTEX

Klozur® CR

Louisville

5,000

Chlorinated Solvents

Klozur® CR

*= Separate Phase Product Present

Ozone Standards Postponed - A Good First Step

BY: Bradley L. Coyle, CHMM

 

President Barrack Obama may have actually inadvertently saved jobs recently when he asked EPA's administrator, Lisa Jackson, to withdraw the agency's draft for more stringent ozone National Ambient Air Quality Standards (NAAQS).  By some estimates, the new ozone standard may have cost as much as $700 billion in negative economic impact as well as potentially costing as many as 7 million jobs by the year 2020(1).

It's obvious that no one wants to breathe dirty air but, the reality is that the ozone standards are already pretty tight.  I'm neither a health nut nor a toxicologist but, it's likely getting to the point that the cost to bring the NAAQ down is not likely to have a significant positive effect on human health.   In short, the costs of tightening the standard would likely outweigh the benefit.  This particular NAAQ falls in to the law of 'Diminishing Returns'.

I've read where the numbers of asthmatics has increased by 70%+ over the past 15 years(2).  Odd, isn't it?  We've made HUGE strides to better the air quality through the addition of various pieces of legislation and stringent permitting programs over the past 40 years yet these types of air quality-driven illnesses rise?  Sure…some of it is diagnosis and understanding of the ailments but, will driving an ozone NAAQ further towards the floor be actually advantageous from a health standpoint, or will it simply continue to slow economic growth and reduce the United State's overall economic well-being?

The tip of the iceberg was revealed by allowing the proposed ozone NAAQ to be shelved.  This, in my opinion, was a very good thing in today's economic times and offered a level of recognition that many of the regulations in the pipeline or coming out are BAD for the overall good of Americans.  What has failed to be recognized is the cost of many other burdensome pieces of air regulation that are still 'in the wild' and will be law (or may have already become law); these will cost Americans more in nearly every aspect of their lives.  The boiler MACT, the utility MACT, transport rule… the list goes on and on in to what has even been called the regulatory 'Train Wreck'(3).

Again, we all want great air(4).  We all want to be healthy.  We all want to live long and prosper (yes, I'm giving the Vulcan Salute while typing)… but, where's the line and is there a line?  So far, this administration's focus has been at the edge of overly burdensome, in my opinion.  Further though, it is my opinion that President Obama should be recognized for shelving this legislation while in the heart of an economic downturn.  Overall though - the bulk of the iceberg is still below water and poses a SIGNIFICANT threat to how we operate as Americans(5).

 

(1)     http://www.mapi.net/Filepost/ER-707.pdf

(2)     http://www.ncpa.org/pub/ba598/

(3)      http://www.alec.org/docs/EPA-TRAIN-WRECK-2011-Final-Full-printres.pdf

(4)      http://www.aei.org/article/energy-and-the-environment/a-clean-air-regulation-  hazardous-to-health/

(5)      http://www.whitehouse.gov/the-press-office/2011/09/02/statement-president-ozone-national-ambient-air-quality-standards

 

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Mr. Coyle has worked with Linebach Funkhouser, Inc. for nearly 10 years.  In his current role, Mr. Coyle leads the environmental compliance group assisting various nationwide clientele with air, water, and waste issues.  Mr. Coyle can be reached by calling 502.895.5009.

EPA's Boiler MACT Rules

By: Bradley Coyle, CHMM

 

EPA has, yet again, been tasked with a reissuance of a very controversial rule - the Boiler MACT.  The DC Circuit Court mandated that EPA issue a proposed rule and, as such, they have.  MACT, of course, is an acronym for Maximum Achievable Control Technology and is designated by utilizing the top performing 'units' in the country.  Normally, EPA will take an individual unit (boiler, in this case) and assess its emissions.  Quite different on this round though - EPA, rather, took the top 12% of boilers operating 'in the wild' and cherry-picked their constituents of concern.  Fine, right?  Not this time - they actually took the best performers on INDIVIDUAL CONSTITUENTS rather than the entire sweep of chemicals that they are wishing to regulate under this MACT.  In short, if Boiler A had great numbers for mercury emissions but lousy numbers for particulate matter, they only took the mercury emissions in to account for promulgation of the rule.

Like it or not, the MACT is in the pipeline and will plop out the end in due time - in fact, the latest word is as early as the beginning of next year with the final rule also going in for the 2012 year.  Here's who will be snagged by this MACT:

  1. Major sources of HAPs that burn coal, biomass, natural gas (or equivalent) or liquid fuels.  Needless to say, if you're a major for HAPs and have a boiler, you're likely in…
  2. Minor sources of HAPs that burn coal.  Nope, not a worry for you if you're a natural gas burner.  You're not in this round… maybe later but, not yet.

Of course, there are twists and turns within the MACT - for example, emergency fuels and such but, for the most part, you're in if you're one of the above.

But, wait a minute - didn't EPA 'stay' the Boiler MACT?  Yep.  They did but, ONLY FOR MAJOR SOURCES.  The JJJJJJ MACT (Boilers for minor HAP sources) is still out there, coming down the pipe, and will require you to conduct an energy audit and will establish a few additional hoops to jump through depending on if you're above or below the 10 million BTU threshold.

For Minor Sources only - a reporting deadline is RAPIDLY approaching and will be upon you before you know it.  Simply put, it's a reporting deadline to declare applicability to the MINOR SOURCE MACT.  The due date to have this to your regulatory agency (federal, state, local) is September 17, 2011.  This means it's time to get on the ball and get your notification in if it is applicable to your source.

For more information on the Boiler MACTs - or any of the other 130+ MACTs, let us know.  We are currently assisting major and minor sources from metal cutting to surface coating and a variety of other source categories subject to 40 CFR Part 60 (NSPS) and 63 (MACT).

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Mr. Coyle has worked with Linebach Funkhouser, Inc. for nearly 10 years.  In his current role, Mr. Coyle leads the environmental compliance group assisting various nationwide clientele with air, water, and waste issues.  Mr. Coyle can be reached by calling 502.895.5009.