Children playing patty-cake in the discharge of the discharge of a remediation recovery well: this article reveals first-hand challenges to landowners and responsible parties when a remedial piping fails. As the task group chair for ASTM’s Continuing Obligations Guide, Terradex’s Bob Wenzlau shares his personal encounter with a failed remedial system, the difficult to report the failure, and the lessons learned as all involved parties made improvement to both the physical system as well as communication protocols. The incident provides lessons learned toward the upcoming guidance for landowner continuing obligations.
While the release later proved to have dissolved volatile organics below drinking water standards, it generated several lessons for maintenance and communication at long-term cleanup sites, especially those with off-site migration.
What were these lessons learned? Off-site landowners are not sophisticated toward duties associated with recovery wells, emergency contact information should be up to date, permanent labeling on well heads is essential, the fire department should be informed of recovery systems, and the integrity of mechanical systems degrade across the years. This a a brief summary of the story, and how these lessons were learned, and how they can be applied to upcoming guidance by ASTM for continuing obligations at contaminated properties.
The University Club is encompassed by a regional volatile solvent plume. The setting of the club around a creek also causes it to be impacted by the migration of contaminated groundwater from an adjoining property. The remedy placed several recovery wells to various depths, and they have become an unobtrusive fixture within the club’s setting.
The discovery of the release occurred on Sunday May 16, 2010 when there was the “summer swim team party” with about a hundred young children and their parents. As indicated in the photo, one enters the club across several below-grade recovery wells. Discharge piping had failed in one of the well, and contaminated groundwater was puddling on the walkway. At the time children were playing in the puddled water.
On that Sunday I knew broadly that these were recovery wells, but not the specific contamination hazard. I looked around for any signage, and there was none. I tried calling the club manager, and he was gone. As such, I had no other option than to notify Palo Alto Fire, and direct the children away from the contamination.
Lesson 1 – some form of signage should be placed at or near recovery wells to indicate a communication protocol in event of a failure.
Upon calling Palo Alto Fire, the emergency center had no interest in an immediate response. The dispatcher thought it was the landowner’s issue likening it to a broken sprinkler, and not a release. I advised they provide notice to their hazardous material team in the morning. No follow-up was received from the fire department.
Lesson 2 – a city emergency operation should have some basis to discover and respond to a release.
I later learned that the club manager had separately tried to provide notification of the event, but the phone numbers and contacts had fallen out of contact.
Lesson 3 – remedial system operators should maintain current call procedures for off-site property owners.
I then opted to follow-up by email with the California Regional Water Quality Control Board, as it was not at the time clear whether Palo Alto Fire would respond. After notice was provided to the Water Board, and ultimately brought to the attention of the Department of Toxic Substances Control who oversee the site cleanup, thorough attention was brought to the matter.
A principal and comforting finding was that the discharged groundwater was below drinking water standards, and as such did not pose great hazard to the children. Still, none of the involved parties took comfort that the release occurred, and that the plans were out of date.
The release I encountered on Sunday, turns out to have been the second failure of this well. Since then, there have been two more failures. According to the engineer, the system was installed in the mid 1990s, and the PVC is fatiguing and failing. The engineer shared his perspective, that I denote as lessons.
Lesson 4 – Aging remedial systems can suffer material fatigue.
Lesson 5 – Some form of local overflow detection is appropriate for well heads (a feature lacking in this recovery system).
This failure illuminates challenges emerging with long-term remediation projects. While many cleanups are complete, other cleanups will persist for decades. Institutional knowledge will be lost as the years pass — in the case of the University Club several club managers have interceded since the recovery systems installation. There is no institutional memory. Equally, the integrity of materials in recovery systems have begun to fail across years.
So how does this play into Continuing Obligations?
Continuing obligations has evolved as the phrase used to refer to duties and reasonable steps landowners should take, in order to remain non-responsible for contamination releases caused by other parties (such as neighbors or prior owners). What exactly must be done to fulfill continuing obligations remains a topic debated, perhaps most loudly in the ASTM continuing obligations task group that I chair. However the contours of continuing obligations become defined, I think most would agree that taking measures or at least taking reasonable steps to maintain recovery wells, prevent children from being exposed to contaminated groundwater, and establishing steps to respond to the recovery well leaks would qualify. True, these obligations fall to the off-site owner but it is also seems reasonable that the off-site property owner would rely on the responsible party to help them fulfill their obligations, and any responsible party should share an interest that landowners succeed in their duty. I think a more systematic approach, involving off-site and source property owners, would help avoid events like the one here, and that’s precisely why the forthcoming continuing obligation guide will prove valuable. This event showed numerous apparent shortcomings in satisfying continuing obligations.
- Lack of a current continuing obligations plan at the University Club.
- Poorly maintained recovery wells.
- Lack of signage at or near the recovery wells.
Again we were fortunate that there were no exposures. Failures like this are rarely captured, and when captured, we must apply their lessons. As environmental professionals we should focus on the different types of challenges imposed by long-term remediation projects – burdens of communication, planning and system maintenance. The lesson seems to be heeded as other local remediation systems will have their integrity tested, and likely assure that communication plans are up to date.