The Monitor: A Terradex Blog

NAESIP and Terradex Introduce Brownfield Loss Control Services

Brownfield Loss ControlOwners and developers of brownfield properties need assurance that they will meet their obligations to maintain institutional and engineering controls (IC/ECs) over known contamination left in place. These “continuing obligations” often last in perpetuity. Terradex can provide that assurance. Our exclusive loss control services support NAESIP’s Site Pollution Liability (SPL) coverage for owners and developers of brownfield properties subject to IC/ECs. Combining Terradex loss control with NAESIP risk financing services can result in surprisingly low premiums by reducing the costs of underwriting and the likelihood of a claim.

Terradex embraces that  the value of its LandWatch services as a loss control service for SPL coverage can be validated in the marketplace. The value can be measured in economic terms through premium reduction, or measured by additional comfort for sellers and buyers of brownfields as claim occurrence is reduced and compliance satisfied. Please download an overview of Terradex’s Brownfield Loss Control Services.

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A Proposal To Improve Institutional Control Effectiveness Through Better Mapping

IC ProposalTry to read a typical institutional control (IC) and locate its boundaries. We bet you can’t. You will find a complicated legal description referring to metes and bounds, but not a map of the restricted areas that you can actually see and understand. Only licensed surveyors can decipher these legal descriptions, but all the parties who need to comply with the restrictions – developers, excavators, well drillers, etc. as well as environmental agencies and others who want to build online maps cannot readily know the area where the IC’s health and safety precautions apply.

Consistent with common environmental compliance practice, IC practitioners routinely recognize that communicating ICs to affected parties is the key to success. And at the core of communication is easy access to IC boundary location. Without IC boundary maps, an IC could inadvertently be breached causing health impact or remedy damage. The lack of IC maps weakens the force of ICs and undermines future IC compliance.

In this post, we propose a process for supplementing conventional legal descriptions with the addition of information describing a geographic map, including latitude and longitudes, of IC boundaries. This proposal would not impact the longstanding requirements for legal descriptions, but rather would add the requirement that all recorded ICs also include IC boundary location in a geographic map format. This would enormously improve the ability of environmental agencies and others to make online IC maps widely accessible – a key component for improved IC compliance.

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DigClean is Protecting Excavators Across Delaware From Buried Chemicals

Excavations are a common event around contaminated sites as each flash of light signifies.  This map shows flashes for each excavations around contaminated sites in New Castle County, Delaware.  Try  adjusting the map, the date may be adjusted on the slider, and the coverage area adjusted by the zoom control.  

You are watching about 3,500 excavation clearances resulting in over 1,000 advisories automatically sent to excavators by Terradex’s DigClean service. Terradex’s client since 2012 is Delaware Department of Natural Resources and Environmental Protection (DNREC).  A one minute video overviews how the excavation clearance system can not only protect buried pipelines, but also convey health and safety information to workers about to dig.

Construction excavations threaten remedies, breach institutional controls, create circumstances where contaminated soils are mismanaged, and introduce health hazards to construction workers.  The value of DigClean is to bring tangible information to excavators so that they can make timely, smart decisions to control these threats.  Avoiding chemical contamination in the field is manageable once DigClean transmits an advisory. Read More »

Conversation with Bob Wenzlau, Terradex CEO

Terradex’s WhatsDown launched in the Summer of 2014. The release of WhatsDown coincided with concerns across Silicon Valley about public health related to volatile organics. Terradex has sought to play a constructive role while offering useful commercial services including indoor air testing.

A more detailed article is at this link to the Palo Alto Weekly.

Environmental Protections – A Proposal for Public Branding of Institutional Controls

In and OutThrough WhatsDown, we maintain a catalog of “institutional controls”.  However, in the app there is one big change – we replaced the term ‘institutional control” with the term “environmental protection”. With WhatsDown serving the public, we were compelled to generate an intuitive mapping application.

The term “institutional control” is a general umbrella term that captures various devices including environmental covenants, land use restrictions, deed restrictions, activity and use limitations (AULs), governmental controls and often engineering controls.

The term “environmental protection” carries the inspiration behind the terminology.  When an environmental protection is applied, the stakeholder knows that there is a device in place that is protective in nature.  While the term environment is broad, within the context of land contamination, the meaning is relatively implicit. As an environmental professional would establish an “environmental protection” the duty associated with that is embedded in the term.  The term “environmental protection” is both trustworthy and efficient.

As our environmental  industry and the agencies embark on the stewardship of installed remedies, the priority shifts to promoting the discovery of institutional controls.  By design an institutional control must communicate to diverse stakeholders who heed their guidance. These stakeholders do not carry the domain expertise of an environmental professional, yet their decisions are critical to an institutional controls effectiveness.  For example, a local government land use planner should respect controls that affect zoning, an excavator should understand controls that affect actions damaging a liner, and a community member should be aware of notices that affect food crop production.

Labeling these controls as “environmental protections” immediately engages the user with their relevance. We tested the term, and found most recognized the intent and purpose – especially when compared to the terminology commonly applied within our industry.  Following is the FAQ from WhatsDown where we strive to introduce Environmental Protections.

What Are Environmental Protections?

Environmental Protections are legal or physical controls, sometimes dubbed “institutional controls” by regulatory agencies, that guard people from unsafe exposure to contaminants at spill sites. Environmental Protections are put into place when government agencies allow spill site cleanups to occur under so called “risk based” standards, which allow some contamination to remain in place if environmental protections are added to guard against exposure. Environmental Protections limit activities and future uses that could pose health or environmental hazards. These protections ordinarily last for as long as contamination remains in place, which could be for many many year, even permanently in some cases.

WhatsDown shows Environmental Protections in “caution” yellow, indicating proceed with care. Environmental Protections often address a single parcel of land, but also can cover much larger areas when, for example, groundwater or soil contamination spreads across multiple properties. WhatsDown increasingly attempts to map the boundary of the Environmental Protection. Otherwise, WhatsDown shows the Environmental Protections as a point on the map.

Government agencies ordinarily require Environmental Protections to be tailored to the hazard. For example, if contaminated groundwater would inadvertently be used for drinking, the protection could be a drinking water restriction. If there were chemicals harmful to children, then protection could restrict use for schools or daycare. The protections are assembled based upon specific risks posed by the spill site. Not all spill sites have protections associated with them, especially those where cleanup has not been completed.

We hope that in the future we might find some shifts.  When remedies are described to the public, the term “environmental protection” can be used to provide quicker assimilation.  We might find state websites saying “Download Environmental Protections” when public repositories of institutional are engineering controls are maintained.  What are your thoughts?

Long Term Stewardship at Vapor Intrusion Sites – Looking at the End Game

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Long term stewardship (LTS)  is the “end game” of any vapor intrusion problem. Any smart player, considers the “end game” at the start and during play. Knowing the “end game” sets a smart direction for any stakeholder of a vapor intrusion – a responsible party, landowner, environmental agency staff, and the public.

Mr. Henry Schuver in today’s presentation invited  focusing on the  “end game”. Mr. Schuver has led a number of national conferences on vapor intrusion for the USEPA. Terradex’s services have always been an element of the end game, and Mr. Schuver invites bringing this forward.

This video is to be shared at the March 18, 2014 workshop on Vapor Intrusion (VI) Exposure – the Challenges of, Need for, and Benefits of Long Term Stewardship sponsored by the United States Environmental Protection Agency.

So what is the rationale for LTS?  If the public is protected in the short term, then responsible parties and agencies are offered needed time to address the underlying problems in groundwater that pose vapor intrusion problems, while taking comfort knowing workplaces and residents are protected. According to remarks by EPA, LTS is necessary when residual contamination remains.

LTS embeds protections for the impacted parties – tenant or worker. Protection typically involves engineering controls and smart choices. The engineering controls – active blowers or passive liners – are vulnerable to damage and poor operation. LTS involves making sure the blower stay active, and liners are not damaged. This is where smart decisions come forward, and where Terradex’s technology plays a role.

Fortunately, most individuals come wired to make smart decisions given timely information. LandWatch, as the video shared, brings that information to stakeholders – responsible party, agency, landowner and public. The information we bring is that a liner might be breached, a new excavation might pose a new pathway, a new occupant or tenant is moving in who might not know how to protect the remedy.

So this invites bringing the “end game” forward, implement LTS services such as Terradex’s LandWatch, and have more comfort knowing that remedies are protected now and into the future.

Mapping Shallow Volatile Groundwater Plumes in Silicon Valley

Volatile organic groundwater plume are shown underlying childcare sensitive uses in Palo Alto, CA. Clicking the map image will show open a new window, showing the plume within the interactive CleanupDeck. Other plumes in Silicon Valley can be viewed.

Volatile organic groundwater plumes are shown underlying childcare sensitive uses in Palo Alto. This map can be viewed at this link to the CleanupDeck. A public view of the same data is within Terradex WhatsDown

Silicon Valley prides itself as a leader in environmental sustainability, but opportunities for improvement are ever present.  This post introduces new map-based services showing contaminated groundwater areas in Silicon Valley, helping to provide intuitive environmental data meant to inform all interested stakeholders.

The Valley has evolved from former industrial areas that held semiconductor industry that discharged carcinogens to groundwater. Over the past thirty years industry has transformed to new office parks hosting businesses like Google and Facebook.  The workforce is smart, growing and young – but also vulnerable to carcinogenic vapors from shallow contaminated groundwater plumes from legacy businesses.

Former industries, gas stations and dry cleaners spilled  chemicals in shallow groundwater plumes that persist as well as migrated  beneath newly constructed workplaces and homes.  The residual chemicals can vaporize into the soil gases and migrate to structures.  One key chemical, trichloroethene (TCE), is carcinogenic and poses an impact to a young fetus, thus any young woman is particularly vulnerable.   The circumstance might be a “perfect storm” where a young workforce  unknowingly inhales vapors from unknown underlying groundwater plumes containing potential carcinogens. Terradex is building a map service called the CleanupDeck that seeks to communicate this information in a form intuitive to a public user.

At Silicon Valley’s Mountain View Google campus, vapor intrusion from groundwater plumes was found to be migrating into the underlying structures of some of the office buildings.  As reported in the press, the halogenated vapors migrated based upon inadvertent actions by a contractor.  The outcry framed a vulnerability – the young working women at childbearing are vulnerable to these vapors.

One ingredient to assessing vulnerability is knowing where these plumes are in relation to homes and offices.  Hundreds of groundwater plumes exist across Silicon Valley, and many contain volatile chemicals that could migrate upwards to occupied structures, and then be inhaled by occupants.

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This post introduces a mapping resource that shows where groundwater contamination plumes are located as well as basic information to begin to judge their impact.   The map is presented using Terradex’s CleanupDeck – a web mapping service. We describe the challenges faced when assembling a groundwater plume maps, the maps relevance and relation to USEPA’s attention to vapor intrusion hazards in Silicon Valley, and we describe the impact of a subset of these plumes – the ten that are deemed Superfund sites.  Terradex is working to complete and build upon the mapping accessible via links further below within this post.

Since this post, Terradex has released WhatsDown that shares the same information for public consumption.

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Mobile Web Tool for Excavators in Delaware Helps Plan for Subsurface Chemical Hazards

A mobile web tool helping excavators learn of chemicals of concern at a future excavation location.

A mobile web tool helping contractors and engineers learn of chemicals of concern at a future excavation location.

Terradex is testing a mobile web tool to assist excavators and engineers working near spill sites. Now under testing by several utility companies, the web tool permits an excavator to learn chemical information at cleanup sites in Delaware.

The tool addresses a common need in the field:  “How in advance of an excavation, can we learn of chemicals of concern, an thereby bring appropriate personal protective equipment (PPE) to the job site?”

This DigClean mobile and desktop web tool differentiates chemicals of concern, and provides links to NIOSH and ASTDR to highlight chemical-specific health and safety information. As the application can be used in the field, even emergency excavations can be informed of chemical information or the presence of institutional or engineering controls.

A short demonstration as a webcast follows. The web application can be requested by email.
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Forecasting an Engineering Control or Institutional Control Breach, A Study of Third-party Excavation Activity

Excavation activity in one year period near Oakland California

Third party excavations by utility companies, developers and contractors are routine and frequent in urban areas. Excavations are shown intersecting cleanup sites that have institutional and engineering controls. The potential excavation extents are reported by utility protection systems, and the actual excavation limits are smaller. Shown are excavation notifications for a one-year period near Oakland, California. An overlay shows higher population densities associated with this urban area.

Excavations by third-parties are inevitable near any cleanup site. Of concern to cleanup site managers, these unexpected events can breach institutional or engineering controls relied upon in a site’s cleanup remedy. Third-party excavators include utility companies, developers and contractors whose work is not part of the site cleanup process. Terradex completed an analysis of excavation records for 313 sites in California from utility clearance centers during a one year period, July 1, 2012 through June 30, 2013. The 313 sites cover about 250,000 acres. The findings offer a formula for reasonable predictions of annual excavation frequency near cleanup sites.

Excavation activity near cleanup sites can unwittingly exacerbate residual contamination, violate the requirements of institutional or engineering controls, or expose workers to hazardous chemicals. Excavations range widely from small disturbances – such as for sidewalk construction and utility repair – to large projects for parking garages, basements, development site grading, water well development and many others.  The importance of controlling excavations and monitoring excavation activity has recently been reinforced in USEPA’s  Final Guide to Planning, Implementing, Maintaining and Enforcing (PIME) Institutional Controls at Contaminated Sites, a topic discussed earlier by Terradex.

How likely and how often will excavations actually occur? Site management or continuing obligation plans should estimate third-party excavation likelihood and arrange for risk mitigation methods. A broader goal within this posting is to introduce an empirical approach to stewardship. Too often, the planning and evaluations of stewardship are anecdotal.  While an empirical method is offered, Terradex recognizes numerous qualitative factors ultimately resolve the actual excavation occurrence.  With more empirical methods, stewardship duties can be better calibrated to the site setting and its unique risk factors. Read More »

The Release of an Institutional Control Data Schema and Flow

 

The released IC XML schema and flow operating within the Environmental Exchange permits IC providers and users to share and apply institutional control information for public heath and remedy protection.

The released IC XML schema and flow operating within the Environmental Exchange permits IC providers and users to share and apply institutional control information for public heath and remedy protection.

Marking a big step forward in the “institution” for institutional controls (ICs), on June 10, 2013 the Environmental Information Exchange Network (EIEN) announced the release of an IC Data Exchange. The IC Data Exchange provides a standard means for sharing IC information between separately-owned computer systems – including sharing among different levels of government and between government and private systems.

This standardized approach will help bring sorely needed IC information into land activity and use decision-making, improving IC compliance and, therefore, cleanup remedies. The IC Data Exchange includes an IC XML data schema, which sets standard rules for “packaging” IC data and, in turn, allows “query and response” data flows where requestors receive standardly-packaged IC data from data owners via “REST” or relatively more complex “SOAP” methods. The IC Data Exchange, as it becomes implemented, could significantly improve long-term IC management.

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