Martti Suominen, Neste Marketing Ltd

1
Martti Suominen, Neste Marketing Ltd
Site Characterization ( SC ) at Fuel Retail
Stations, Experiences in
Finland
2
Site Characterization ( SC ) at Fuel Retail
Stations, Experiences in FinlandContents

• 1 Background data of Finland
• 2 Retail Sites in Finland
• 3 Legislation on Soil and Groundwater
• 4 Direct legislation on Site Characterization
• 5 Several situations require Env. Permit
• 6 Site Characterization approach
• 7 Retail Site investigation program
• 8 Future developments

3
1 Background data of Finland (mostly 2000
figures)

• 1785 kt gasoline sales
• 196 kt oxygenates (MTBE TAME), 11 13 (v/v)
  in gasoline
• 9 retail chains, about 1850 retail stations
• 7141 aquifers, 2226 are in important category
• utilization of important aquifers capacity 25
  
• utilization of total aquifers capacity 12
• 57 of water service from groundwater

4
2 Retail Sites in Finland are the same as
anywhere else, i.e

• up to 70 yrs old, many of them several times
  rebuilt,
• small in area, 400 - 3000 m2
• often built on thick construction filling,
  sometimes on layers of crushed rock
• heavily developed buildings, canopies, tank
  yards, forecourt, excavations for fuel and
  utility pipelines / cables
• many rebuilt sites have abandoned tank yards and
  fuel line/utility excavations. Quite often there
  are abandoned tanks and fuel lines still in the
  ground with some fuel still inside
• often inconveniently located, seen from soil /
  ground water remediation perspective. A Retail
  Site located on the ground floor of a large high
  rise building may become a major nightmare

5
3 Legislation on Soil and Groundwater in
Finland I

• basic legislation and authority control has been
  in place since decades
• refinements since 60s, Environmental Liability
  Act 1995 (ELA) and new important Environmental
  Protection Act 2000 (EPrA) with additional
  refinements in 2001
• releases of oil products into soil are
  prohibited and very strictly so into ground water
  (authority likes to interpret it as an "absolute
  prohibition")
• remediation liability follows the "polluter pays"
  - principle and is strict, no matter whether the
  release was accidental or due to negligence or
  gross negligence. The next in the liability line
  are the site operator, site owner or lease holder
  and sometimes the community and even the state.

6
3 Legislation on Soil and Groundwater in
Finland II

• in court (civil law, damage compensation) ,
  conclusive evidence against the potentially
  liable party is not necessary any more (ELA),
  circumstantial evidence based on educated,
  logical reasoning is enough
• the EPrA allows the Government to release
  additional requirements and instructions in
  decrees, which have an impact on the SC
• law enforcement has not been proactive in the
  past, recently we have began to feel the grip
• the Finnish legal system fortunately does not
  include the "punitive damage"- principle

7
4 Direct Legislation in Site Characterization,
not very much of that I

• land owner's permission is needed to drill a hole
  into ground
• otherwise, there are very few constraints or
  requirements on SC written directly into law,
  except saying, that soil and groundwater
  remediation needs an Environmental Permit
• Obviously, there must be a catch To obtain the
  Environmental Permit, one has to apply for it
  using a comprehensive form, which includes a long
  list of key elements of release investigation,
  such as

8
4 Direct Legislation in Site Characterization,
not very much of that II

• time and reasons of the release and site history
• chemicals released, their characteristics,
  volumes, concentration in soil and / or ground
  water
• information on contaminated soil and / or ground
  water area and volume
• soil stratigraphy, hydrogeological information
  and type of aquifer
• potential sensitive receptors, drinking water
  abstraction wells and surface water
• detailed maps of the release area and
  surroundings, information on neighbors,
• etc, straight from any instruction book on SC

9
4 Direct Legislation in Site Characterization,
not very much of that III

• Should the competent authority not be happy with
  the SC data given in the Permit application, the
  applicant has to improve it, which takes time and
  money gtgtgt a delay in receiving the applied
  permit. The authority can also stop an
  initiated remediation in case something
  unexpected surfaces.
• The other indirect control is the limit values in
  soil contamination. The authority has applied
  those since early 90s although those values are
  not of a status of a law or a statue. There is
  also some risk based flexibility available in
  applying those values
• Essentially, the authority has all the leverage
  it needs to quide the SC. The proceedure is well
  established and the risk to get in trouble with
  the authority works just fine for the authority.

10
5.1 Several situations require Env. Permit, i.e
SC needs to be performed, e.g when a Retail Site
is to be

• renovated big time
• if tank capacities, solid waste load or
  emissions into waste water or air materially
  increase, a new Env. Permit is needed
• closed
• by experience, there will be contaminated soil,
  remediation needs a Permit. Land owners want
  their lot and and underlying ground water clean,
  will not accept any risk
• sold or leased
• nobody buys or leases a Retail Site these days
  unless past releases' remediation liability is
  agreed upon between the parties, needs SC. If the
  contamination is not mild, the authority would
  probably demand the site remediated anyway, even
  if the new owner would not ask for it.
• this element is becoming increasingly important
  in volume.

11
5.2 Several situations require Env. Permit, i.e
SC needs to be performed,

• or when
• serious releases have occurred or are suspected
  to have occurred, or
• Retail Site owner/operator decides to do so
  anyway to understand the risks to receptors.
  
  This is what most of the
  Retail Companies in Finland have been doing
  extensively since early 90s

12
6 Site Characterization approach applied at
Retail Sites I

• low key approach, focus in risks to receptors,
  especially to exploitable ground water
• simple and straightforward investigations, focus
  in "hot spots" and receptors
• elementary risk assessments, mostly just an
  educated opinion by an experienced consultant

13
6 Site Characterization approach applied at
Retail Sites II

• Logic for low key approach
• a Retail Site is too small and too heavily
  developed to warrant using sophisticated e.g
  geophysical methods and computer aided flow and
  transport models. An excavator is a really cost
  effective tool in elaborating the investigation,
  it has to be used anyway in most cases in
  removing contaminated soil
• the cost of a basic investigation / SC cost for a
  retail site is not high, usually in 2.000 - 6.000
  bracket, whereas just the conceptual modelling
  desk work would be 2.000 - 3.000 . Serious
  models require lots of data
• in comparison, Neste's average for Retail Sites'
  remediation cost is about 40.000 , practical
  range 10.000 - 150.000 , maximum so far 517.000
  

14
6 Site Characterization approach applied at
Retail Sites III

• serious failures' rate in SC has been low,
  however,
• there has been a few cases, where standard
  investigation did not detect the magnitude of the
  problem, e.g.
• a serious diesel-contamination in a sandy ridge.
  The truth was revealed only when the excavation
  never ended.
• in another case a massive gasoline plume a few
  metres out of the tank yard was not detected
  until it was realized, that the remediation by
  soil venting would go on forever. New
  investigation / SC was carried out.
• however, the main reason for high remediation
  cost cases has mostly not been SC approach
  itself but delaying and /or unwise cutting of
  corners in the remediaton,

15
7 Typical Retail Site investigation program I

• Sampling focus is in known or probable "hot
  spots", in the order of probable contamination,
  i.e.
• tank yards, forecourt / pump island base, site
  tank refill areas, tank vent pipe areas, oil
  separators and discharge areas (if not municipal
  waste water system) lube, heating and waste oil
  tanks
• Site area geology, hydrogeology and areas
  sensitivity has an impact on the investigation
  planning

16
7 Typical Retail Site investigation program II

• Drilling / sampling
• on a typical site some 6 - 12 locations are
  drilled down to 5 m or so (deeper if no aquitard
  found, lower if an aquitard or rock found)
• soil, soil gas and ground/soil water samples
  taken
• soil samples from 2 - 3 depths
• contaminants analyzed TVOC, BTEX, Ethers,
  Diesel
• If concerns arise during initial sampling, more
  and deeper holes will be drilled.

17
8 Future developments in our Retail Sites' SC /
remediation look as follows

• SC will go on as we are used to, however
• even more emphasis on ground water issues, it is
  the largest potential cost risk if improperly
  perceived
• more aggressive site "hot spots'" removal, MNA to
  take care of the rest
• increased expectations on oxygen feed enhanced
  biological in-situ remediation methods
• On the technical side
• geophysical devices will be considered when we
  see something dramatically better
• better and more handy field analytical tools are
  needed to guide excavation and analyzing ground
  water