The Scioto Village-Riverview Complex is a State-of-Ohio-owned property used as a juvenile correctional facility. On December 19, 1991, one 1000-gallon gasoline UST and associated product lines and dispenser island were permanently removed. The corrective actions process was initiated during closure activities when elevated concentrations of benzene, toluene, ethylbenzene, and xylenes (BTEX) were discovered in soil.
BUSTR requested additional assessment in a letter dated April 10, 2003. In response, BJAAM installed three soil borings in the area of the former UST cavity. Soil analytical results exceeded applicable action levels and further evaluation was deemed necessary.
BJAAM submitted a Tier 1 Evaluation Notification to BUSTR on December 14, 2004, which summarized the installation of two soil borings and one additional monitoring well (to supplement eight pre-existing monitoring wells). Laboratory results revealed elevated concentrations of BTEX in soil, while benzene and methyl tert-butyl ether (MTBE) exceeded action levels in ground water. BUSTR was informed that the Ohio Department of Youth Services intended to conduct further tier evaluation under the BUSTR 1999 corrective action (CA) rules. BUSTR responded with a request for an additional monitoring well installation, the results of which were submitted to BUSTR in a report dated December 17, 2004.
A Tier 2 Evaluation Report was submitted to BUSTR on July 14, 2005, providing the results of two additional monitoring well installations, developing site-specific target levels (SSTLs) for exposure pathways that exceeded Tier 1 default risk-based action levels (RBALs), and, ultimately, recommending a No Further Action (NFA) for the release. BUSTR responded with a request for further evaluation of impacted soil and the migration of chemicals of concern (COCs) in ground water. The requested information was reported to BUSTR on February 22, 2006.
On July 26, 2006, BUSTR requested the submittal of a ground water monitoring plan in order to validate the predictions of the Tier 2 fate and transport model. The Ground Water Model Validation Monitoring Plan was submitted to BUSTR on August 28, 2006, and subsequently approved on September 5, 2006. At the conclusion of the monitoring period, BUSTR requested an additional two quarterly monitoring events due to an observed spike in ground water concentrations during the October 2006 sampling event. The second of these additional monitoring events was completed in December 2007.
In October 2008, BUSTR requested the installation of twelve additional monitoring wells, which were installed in April and May 2009. Analytical results revealed that soil concentrations were below Tier 2 SSTLs, while ground water showed benzene concentrations remaining above its SSTL in MW-9. In response to a letter issued by BUSTR on February 25, 2008, the Ohio Department of Youth Services has opted to conduct a Remedial Action Plan (RAP) to address remnant ground water impact.
Corrective actions at former Certified Oil Company (Certified) station #199 in Pataskala were initiated following an explosion resulting from gasoline vapor accumulation in the facility basement in September of 1977. Corrective actions were overseen by the Ohio Environmental Protection Agency until oversight was assumed by the Ohio Bureau of Underground Storage Tank Regulations (BUSTR) following its creation. Certified elected to apply BUSTR's 1999 corrective action rules to the release on March 12, 2002.
BJAAM was contracted by Certified in 2002 to ascertain the scope of impact, complete free product recovery and initiate necessary corrective actions. Initial intrusive study included the strategic installation of a number of ground water monitoring wells and associated soil and ground water sampling. Discussion of these activities was included in the Tier 1 Notification Report published by BJAAM on April 26, 2002. Based on the acquired analytical data, ground water and land usage, corrective action proceeded into the Tier 2 phase. In addition, a recovery plan was implemented in 2002 in response to sporadic free product observations at the site. Free product recovery was discussed in the series of monthly Free Product Recovery Reports published through 2006.
The Tier 2 phase included additional intrusive study and delineation in conjunction with exposure pathway evaluation and conceptual modeling. Site-specific target levels (SSTLs) were then developed for applicable chemicals of concern in soil and ground water. Derivation of target levels was accomplished through the use of the BIOSCREEN analytical fate and transport model and BUSTR pathway target level spreadsheets. These activities were presented in the Tier 2 Evaluation Report published by BJAAM on October 18, 2002.
A ground water monitoring program was completed between June of 2003 and May of 2004 for the purpose of validating the predictions and assumptions of the analytical model and resulting SSTLs. These results were presented in the series of Fate & Transport Verification reports published by BJAAM in 2003 and 2004.
In November of 2005, a plan to implement interim response action (IRA) activities was jointly formulated between BJAAM and BUSTR personnel. An onsite pre-planning meeting was completed in early December of 2005 to discuss proposed interim response activities. These activities would be completed in three phases, the first included de-watering of the area of concern through the use of a dual-phase extraction system. The second phase consisted of the closure of the existing underground storage tank (UST) system and removal of the soil source area and free product. The second phase included a BUSTR-approved variance to excavate beyond twelve inches into native soil should the need arise for removal of impacted soil. Excavation and UST removal activities would be completed by a licensed subcontractor under BJAAM oversight. Phase 3 involved the manual installation of confirmatory monitoring wells, a soil aeration/injection piping system and backfilling the excavation to grade with un-impacted soils.
IRA activities were initiated on December 13, 2005. An orphan UST was encountered during excavation of a ground water sump pit to facilitate phase one of the IRA. Excavation was quickly resumed due to the close cooperative relationship enjoyed between BJAAM and BUSTR personnel. This allowed for successful and on-time completion of de-watering, UST removal and soil source area excavation activities. IRA activities generated approximately 1,134 tons of impacted soil and overburden and approximately 7,650 gallons of impacted ground water and free product. These materials were transported to licensed facilities for disposal. A number of confirmatory monitoring wells and a network of soil aeration piping were installed as the excavation was backfilled. Resulting soil and ground water confirmatory sample analysis indicated that concentrations of all chemicals of concern in both media were not in excess of the applicable cleanup target levels. Results of these activities were discussed in the Interim Response Action Report dated June 6, 2006 and the Additional Information Response report dated July 18, 2006.
As a direct result of BJAAM's expertise, no further action status was granted by BUSTR in regard to the N00001 release (which was at the time one of BUSTR's oldest documented incidents) on July 25, 2006. BJAAM's efficient approach opened the door for eventual property sale and re-development for public benefit.
A Tier 1 Source Investigation consisting of the installation and sampling of four ground water monitoring wells was completed by BJAAM in June 2008. The chemicals of concern (COCs) associated with the release include benzene, toluene, ethylbenzene, xylenes (BTEX), methyl tert-butyl ether (MTBE), polynuclear aromatic hydrocarbons (PAHs), and total petroleum hydrocarbons (TPH) carbon ranges C6 to C12 and C10 to C20. The Tier 1 Source Investigation determined that further delineation of both soil and ground water was necessary.
Additional monitoring wells were installed at the site in October 2008, February 2009, and April 2009 as part of the delineation phase of the Tier 1 Investigation. The results of these monitoring well installations were submitted to BUSTR in the Draft Tier 1 Investigation Report dated March 18, 2009 and the Second Draft - Tier 1 Investigation Report dated June 8, 2009. The reports concluded that soil and ground water concentrations remained in excess of both action levels and delineation levels.
In September 2009, BJAAM obtained access to adjacent properties in order to conduct further delineation of chemicals of concern (COCs) in soil and ground water. On October 5 and 6, 2009, eight additional delineation monitoring wells were installed, and two Shelby tubes were subsequently collected on October 6, 2009 in order to provide site-specific geotechnical data for use in eventual ground water fate and transport modeling. At the conclusion of Tier 1 delineation, it was determined that soil and ground water concentrations were in excess of their respective action levels for one or more COCs, and the completion of a Tier 2 Evaluation was recommended.
The corrective actions at former Certified Oil Company (Certified) station #270 in Grove City were initiated following an underground storage tank (UST) system replacement in 2003 which resulted in release N00001. UST removal activities were discussed in the Closure Assessment published by BJAAM on June 18, 2003. This release was given no further action (NFA) status on October 16, 2003.
A second release file (N00002) was opened in regard to a soil stockpile that had been generated during UST system removal and spread behind the station building. An N00003 release was opened following complete removal of the UST system in June of 2006. The landfarmed stockpile from the previous closure was also re-sampled. Stockpile re-sampling activities were discussed in the Sampling and Analysis of Excavated Fill Material report submitted by BJAAM on June 5, 2006. UST removal activities were discussed in the Closure Report published by BJAAM on June 28, 2006. The N00002 release was granted NFA status on June 6, 2006.
Analytical results acquired as a result of a Phase 2 Environmental Site Assessment indicated that concentrations of chemicals of concern (COCs) were present in excess of BUSTR 2005 rule action levels in August of 2006. As a result, a Tier 1 phase was initiated and intrusive study was completed. Following discussions with BUSTR personnel, it was agreed that the Tier 1 Source Investigation and Tier 1 Delineation phases would be merged and a single report would be published summarizing the entire Tier 1 phase. BJAAM published a Tier 1 Investigation Report on October 10, 2006 indicating that a Tier 2 Evaluation was necessary.
The Tier 2 phase included the installation of additional ground water monitoring wells for delineation and analytical modeling purposes. The impact plume geometry and potential affect to human health was evaluated through extensive site conceptual exposure modeling, drinking water evaluation, land usage determination and potential point of exposure identification. Based on these factors, chemical impact was modeled using the BUSTR-Screen fate and transport model and BUSTR's pathway-specific target level spreadsheets. All Tier 2 activities and subsequent conclusions were detailed in the Tier 2 Evaluation Report published by BJAAM on November 1, 2006.
Additional delineation was attempted and one additional ground water monitoring well was installed in the months leading up to February 2007 per BUSTR's request. As a result, the ground water analytical model was revised to reflect the newly acquired plume geometry data. The subsequent site-specific target level (SSTL) calculations indicated that concentrations of chemicals of concern in soil and ground water were not present at the site in excess of allowable levels. These activities were discussed in the Additional Information Response report published by BJAAM on February 19, 2007. After discussion with BUSTR personnel regarding utilization of institutional controls in the surrounding area to forgo analytical model validation through ground water monitoring, NFA was requested for the N00003 release.
As a direct result of BJAAM's expertise, no further action status was granted by BUSTR in regard to the N00003 release (which was completed over multiple phases in less than one year from the discovery of the release) on March 5, 2007. BJAAM's rapid completion of multiple corrective action phases that are typically completed over the course of years rather than months allowed the client to move forward with property divestment proceedings.
Due to the permanent closure of a gasoline Underground Storage Tank (UST) system at the Brown Lumber facility in 1992, corrective actions were initiated as soil concentrations underneath the former gasoline dispenser were discovered above the Site Feature Scoring System (SFSS) Category 2 action levels. As a result, an Initial Site Assessment was completed to discern the presence or absence of elevated chemical concentrations in both soil and ground water. Soil samples collected at boring locations surrounding the former dispenser revealed chemical concentrations at the 18 to 20 foot interval were significantly above action levels. Ground water analytical results at these three boring locations also indicated the presence of elevated chemical concentrations.
In February 2001, the Campbell Oil Company elected to conduct corrective actions in the 1999 rule set. BJAAM subsequently published a Tier Evaluation Site Status Update Letter on August 23, 2004. This letter detailed the completed delineation activities from February 2000 through August 2004. Due to the observed chemical concentrations in both soil and ground water, the letter also apprised the Bureau of Underground Storage Tank Regulations (BUSTR) that a Tier Evaluation was necessary to complete a site-specific conceptual model to define the site-specific characteristics and relationships among the source area, the transport mechanisms, and all potential receptors and exposure routes for both current and potential future activities and land uses.
BJAAM completed chemical impact modeling and calculations by utilizing the BUSTR-Screen fate and transport model and BUSTR's pathway-specific target level spreadsheets. The Tier 2 Evaluation Report was submitted for BUSTR review on March 10, 2005. Pathway evaluation results prompted the recommendation to perform four quarterly ground water sampling events at select wells. BUSTR approved the ground water monitoring plan on November 25, 2005. During the course of the sampling regimen, the source area well and perimeter wells demonstrated increasing concentrationss. On December 28, 2006, BJAAM submitted the final Ground Water Sampling Report for BUSTR review.
In order to address a BUSTR inquiry dated January 18, 2007, four borings were advanced to investigate soil depths at the former gasoline dispenser location and surrounding area. Laboratory analytical results indicated several chemical concentrations at distinct soil depths were above their respective Tier 2 site-specific target levels (SSTLs) and/or RBALs. All activities, analytical results, and conclusions associated with this investigation were detailed in the Tier 2 Addendum Report dated April 23, 2007. Due to the elevated analytical results at extreme depths and locations, communication between BJAAM and BUSTR increased in order to effectively proceed with additional corrective actions.
On June 16, 2007 and August 2, 2007, BJAAM published reports detailing additional delineation activities that were requested by BUSTR. On September 19, 2007, BUSTR conducted a site visit to review the facility and to further discuss corrective actions with BJAAM personnel and the Vice President of Campbell Oil Company. Based upon discussions during the on-site BUSTR visit and the acknowledgement that the plume geometry and characterization had significantly changed since the Tier 2 Evaluation Report was published, all BUSTR-Screen fate and transport models and BUSTR SSTLs were redeveloped. All pathways were evaluated with up-to-date analytical results and newly-acquired geotechnical data.
Comparison of redeveloped SSTLs with new concentrations revealed the 4 to 6 foot interval at the former gasoline dispenser location warranted further evaluation. However, through the redevelopment of SSTLs, BJAAM was able to significantly reduce the scope of the investigation based upon the observed chemical concentrations at greater depths. All activities and conclusions related to the pathway re-evaluations for both soil and ground water COCs were detailed in the Tier 2 Pathway Re-Evaluation Report dated October 17, 2007. On December 4, 2007, BJAAM issued an Interim Response Action (IRA) Notification which discussed proposed soil removal at the former gasoline dispenser location. On January 2, 2008, BJAAM published the IRA Report which documented the soil removal process and the analytical results from the confirmatory sampling.
On January 25, 2008, BUSTR issued a No Further Action (NFA). This determination was a direct result of the redeveloped pathway-specific SSTLs and the increased communication with BUSTR. Redevelopment of SSTLs demonstrated that soil source area removal was only necessary at shallow depths. Consequently, BJAAM was able to greatly reduce the scope of corrective actions.