PCE Soil and Groundwater Contamination Review
Bellingham,
Washington
In 2001,
G-Logics was retained by a law firm
representing the property owner to perform a
peer review of several reports pertaining to a
property in Bellingham, Washington that
historically operated as a dry-cleaning business.
Tetrachloroethene (PCE) contamination was
confirmed to be present in the soil and
groundwater on the site. The reports detailed
contamination explorations and remedial actions
performed on the site over a three-year period.
However, despite the performed cleanup actions, groundwater concentrations were
still well above the default cleanup levels. Because of
this remaining contamination, the original consultant proposed

additional and expensive remedial technologies to further address the contamination, but with no assurance of success.
Given the
recommendations of the first consultant, the client asked G-Logics
to review the
site status to determine if another alternative could be applied.
G-Logics found that
additional remedial expenditures gave no guarantee that the cleanup level
could be met
within any definite period. Furthermore, an attempt to restore the site
to its original condition
would have cost hundreds of thousands of dollars. Therefore, G-Logics
recommended that
the reasons for performing the cleanup be reviewed and the cleanup goals
be revised
(including cleanup levels, points of compliance, and cleanup standards).
This included a
review by the property owner of the possible business problems with land-use
restrictions. In
addition, G-Logics suggested that a site-specific risk assessment
be performed for the site
using actual site-exposure conditions. Risk-assessment findings could then
be used to
develop remediation levels that supported more appropriate cleanup levels
and actions.
G-Logics also suggested that the collected site data be presented to
Ecology under their
Voluntary Cleanup Program (VCP) and that an "No Further Action" (NFA) determination be requested.
With the
guidance of G-Logics, the original consultant prepared a VCP submittal
containing
assembled site data and requesting an NFA determination from Ecology. Our
client then
asked G-Logics to edit the VCP submittal in order to place an emphasis
on project
accomplishments rather than remaining site unknowns. G-Logics also
emphasized the fact
that the site was now a paved parking area, groundwater was not used in
the area, and that
the nearest surface water would not be negatively impacted due to groundwater
discharge.
The revised VCP was provided to Ecology, who granted the NFA determination
with only a
simple land-use restriction. G-Logics' efforts in getting this NFA
determination ultimately
saved the client more than $100,000 in additional site remediation efforts.
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