As part of a potential business acquisition, an agricultural chemical distributor retained Geosyntec to perform Phase I and Phase II Environmental Site Assessments (ESAs) at an agricultural chemical facility in Iowa. Operations at the facility include the bulk storage of pesticides, herbicides, and fertilizers, loading and unloading to and from rail cars and semi-trucks, and fueling and maintenance of vehicles and equipment. Our client's main goal was to make the acquisition without becoming entangled in a previously unidentified environmental issue.
Geosyntec began by conducting the Phase I ESA in accordance with the ASTM Method current at the time (E1527-05). We then conducted a limited environmental compliance assessment with respect to on-site storage tanks and containers; Spill Prevention, Control and Countermeasures (SPCC) plans; wastewater and stormwater management; air emissions; and other areas, even including Homeland Security reporting requirements due to the volume of anhydrous ammonia. Based on our observations, we developed lists of action items for our client and the owner. In order to meet the strict acquisition deadline, Geosyntec subsequently conducted a next-day Phase II ESA, developing and implementing a comprehensive, real-time sampling and analysis plan (SAP) to expedite the process. Conducting the ESAs and implementing the SAP in this expedited manner took advanced planning to ensure that, among other things, underground utilities were properly located and marked before drilling began. We received the electronic data deliverables (EDDs) from the analytical laboratories and assessed the quality of the data and advised the client and the owner on the significance of detected concentrations. Our Phase II ESA revealed shallow groundwater in the area had detectable nitrogen levels that were generally below the drinking water standard, but that some groundwater on-site had elevated levels. It also revealed that shallow groundwater was used as a drinking water source and that a municipal well field was located near the facility. Geosyntec conducted additional site assessment to confirm the well field was not hydraulically downgradient of the facility. Based on our results, the Iowa Department of Natural Resources (IDNR) required a Corrective Action Plan (CAP) to address the elevated nitrogen levels at the facility. We prepared the CAP, that IDNR approved, that included a site-specific cleanup goal for nitrogen in soil that was protective of groundwater and that identified areas of soil that exceeded the cleanup goal. It also called for excavating shallow nitrogen-impacted soil and applying it to crop land at agronomic rates, installing a concrete cap over nitrogen-impacted soil too deep to excavate, and quarterly groundwater monitoring. We are currently implementing the CAP, with soil excavation and concrete and asphalt capping to be completed within the next several months.
Geosyntec worked hand in hand with both our client and the owner to conduct a full range of environmental site assessment and compliance services, much of it in a compressed timeframe. Our willingness to do all we could to get the job done efficiently and thoroughly allowed our client to avoid becoming entangled in a previously unidentified environmental issue, collect additional data and consult with the IDNR, and consider different scenarios on how best to proceed. Ultimately, our client decided to postpone the acquisition until the owner corrects the issue to the IDNR's satisfaction. We are currently working with the owner to do just that by implementing the CAP.