Hazardous Wastes
Hazardous Material Response to an Agricultural Structure Fire
Field Storage Warehouse, Naches, Washington
Fulcrum was retained by an independent adjuster on behalf of a national insurance company to provide inspection, assessment, and management of agricultural chemicals damaged in the course of a fire to a field storage warehouse. Damaged in the fire were three tractors and other equipment. During fire suppression, localized explosive reactions continued to occur and blue flame and gas would erupt. Investigation confirmed the presence of 12 gallon containers of a water-reactive aluminum phosphide used to control burrowing rodents in agricultural fields. Fulcrum managed a hazardous response contractor to collect, package, label, and ship the unreacted product and damaged containers from the center of a controlled arson investigation scene. Following removal of the products, the arson investigators were able to resume their work.
Fulcrum completed site activities by confirming that no impact to the surrounding site soils was present as a result of fire suppression activities.
Third-Party Hazardous Materials Remediation Oversight
Pavement Striping Company, Portland, Oregon
Fulcrum responded to the site of a facility fire on behalf of a national insurance company. The fire had occurred within the maintenance shop of a regional pavement striping company. Damaged during the fire was the large shop, adjacent office space, and the immediately surrounding area. Millions of dollars in specialized equipment was also destroyed. Principal responsibility of Fulcrum was identification and oversight during the recovery, handling and storage of more than 1,000 gallons of new oil, used oils and vehicle fluids, fuels, paints, etc. The release of these products impacted site soils, an adjacent stream, and localized areas of wetlands. Fulcrum’s third-party inspection and evaluation enabled the large loss adjuster to have an immediate understanding of site conditions, and the extent of impact associated with product release, and the ability to manage the insurance company’s exposure to the loss.
Investigation and Remediation of Pesticide Contaminated Soils
In 2008, during development of a parcel and construction of a retail building for lease, stained and discolored soils were encountered in the building footprint and stormwater detention pond excavations. The civil engineer recommended that investigation and remediation be completed by an environmental consultant and recommended that the developer consider using Fulcrum.
Fulcrum’s initial site assessment was completed on the same day as the initial phone inquiry of our office. Initial impression of the site was consistent with two primary concerns, the presence of a large area of buried white granular material, later shown to be primary spent lime and excavated due to structural instability concerns, and an area of yellow, green, and orange discolored soils. Fulcrum was directed to proceed with soil sample collection during our initial site assessment. Laboratory results, received on a rush turn-around-time, confirmed the presence of DDT, dieldrin, aldrin, and others in the area of discolored soils.
To minimize the disruption to continued site development, Fulcrum completed a series of test pits across the site to develop a general understanding of the extent of contaminated soils. With an understanding of the extent of contamination, Fulcrum directed the excavation and stockpiling of discolored soils. Waste characterization, and the understanding that the contaminated soil could not reasonably have resulted from an onsite spill, but rather as a result of imported soils, enabled the contaminated soil to be regulated as a non-hazardous waste. At one point nearly 25% of the parcel was covered by stockpiled soils. However, the stockpiled soils were strategically placed near an access road allowed for easy loading and transport of the contaminated soils to the Roosevelt Regional Landfill in Roosevelt, Washington.
Laboratory analysis also demonstrated that the area of spent lime did not require remediation. However, the civil engineer to be insufficient to support the building weight. Following a complete waste characterization, the spent lime was shown to be an inert solid waste, and was excavated from the site for offsite disposal.
At the conclusion of site investigation, more than 50 soil samples for laboratory analysis and excavation of approximately 25% of the site was required. More than 1,100 tons of contaminated soil was excavated and disposed. Although delays in the construction schedule did occur, the developers decisive decisions and Fulcrum’s effective communications with local Ecology staff allowed for the prompt removal of contaminated soils from the site. Following a review under the Voluntary Cleanup Program, the site received a No Further Action determination.
Pesticide Burial Investigation and Disposal
During pre-purchase environmental due diligence by the buyer’s consultant, a former employee recalled the presence of a pesticide container burial area. The assertion placed the multi-million dollar sale of the commercial property on hold. Compounding the site concerns, was the presence of the Columbia River less than 200-feet to the west of the reported burial area. With the area of the reported burial located between a manufactured home and the nearby site access, limitation of work space was a challenge. Pairing Fulcrum’s expertise and the services of a local excavation contractor, Fulcrum’s project staff utilized a cautious approach of hand shoveling and mechanical excavation to located cardboard boxes, glass bottles, and paper bags, consistent with the employee’s recollection.
Further investigation identified buried packages labeled “DDT” and containing new product. Laboratory analysis identified a variety of detectable pesticides in the underlying site soils. However, only Dieldren was identified at concentrations exceeding MTCA Method A cleanup levels and requiring remediation. Packaged DDT and other agricultural chemicals, totaling two 55-gallon drums, were removed for disposal and approximately 87 cubic yards of pesticide impacted soil was excavated during three separate excavation phases. While the physical location of the Columbia River was nearly adjacent to the burial area, final laboratory results, and a distance of more than 30 feet to site groundwater enabled site closure to be achieved without groundwater investigation. Following completion of remediation, the site received a No Further Action determination from Ecology under the Voluntary Cleanup Program and facilitated the sale of the property.
Drum Testing, Identification, and Removal
Fulcrum was retained by a large commercial orchardist following notice from the Washington State Department of Ecology (Ecology) and the U.S. Bureau of Reclamation of an area of illegal drum storage andpetroleum staining on an area of U.S. government land near Mattawa, Washington. As is typical in remoteareas, property boundaries are not always obvious. But the fact that nearly 200 full 55-gallon drums ofpurportedly “used oil” from farm equipment had been stored on bare soil should have been an indication thata better solution was necessary. Further complicating the situation was Ecology’s concern that the drumsmay have contained mixed equipment fluids, including used oil, antifreeze, transmission oils, brake fluid,etc. or agricultural chemicals.Following discussions with Ecology, Fulcrum prepared a sampling and analysis plan to include visualinspection and chlorinated product testing of each drum. Where indications of drum fluid layering orchlorinated products were identified through field testing, representative samples of the fluid were collectedand submitted for laboratory analysis. At the conclusion of the project, nearly 95% of all drums wereconfirmed to be used oil and approximate 5% of the drums were identified with chlorinated productcontamination from brake cleaners and similar fluids.
