Soil and Groundwater Nerds

We are captivated by soil and groundwater.  Absolutely nothing brings us more excitement than to be confronted by extraordinarily complex soil and groundwater issues.  The more complicated, the more exciting we find it!  We get downright giddy when we face a soil or groundwater problem that no one else can solve…we cherish the opportunity to have a crack at the problem.

We may not be the most exciting people to chat with at a party, but if you (or your client) are “in a jam” because of contaminated soil or groundwater, sidle up next to us at the vegi-tray and grab our attention.

We are well aware that not everyone shares our passion for such seemingly tedious and boring subjects as impacted soil and groundwater, but it is our life!  Fortunately, there are those who seek people with such passion, and they won’t settle for someone with a passing fancy or a keen interest…they want someone with passion!

Perhaps you (or your client) are knee deep in the proverbial doo-doo and you are thinking to yourself, “I need someone that lives, eats, breathes, and sleeps soil and groundwater…”

You just found the nerds that fit the bill.

If you would like additional information, call Dr. Michael Sklash (groundwater nerd) at 248.932.0228 or by email (


Teacher’s Complaint Leads to EPA Investigation and Sub-Slab Sampling for TCE

A site with an historic release of TCE isn’t exactly news.  However, what prompted the EPA’s investigation into an Illinois site was an email from a concerned teacher at nearby St. Luke’s School.

According to the February 17, 2012 news release from the EPA, “The River Forest Dry Cleaners Site (Site)…had…documented TCE contamination in the groundwater and subsurface soil surrounding the Site and through the storm sewers.”

Based on the inquiry from the teacher and previously documented TCE contamination, the EPA conducted indoor air and sub-slab sampling in the facilities around the Site in November 2009 and in February and March 2010.  However, according to the Federal Register Notice, “The results did not indicate any level of contamination that warranted a removal action.”

The owner of the Dry Cleaners agreed to voluntarily conduct additional sampling, but had limited means.  And on December 28, 2011, the EPA signed an Administrative Order on Consent (AOC) with the Respondent.  Pursuant to the terms of the AOC, the Respondent agreed to pay $39,926 of costs incurred by the U.S. EPA at the Site.

As it relates to the potential impact of subsurface vapors, gathering sufficient information before a vapor intrusion (VI) investigation is critical. Information about the contaminant, the concentration, the geology, the potential pathways, etc…are all very important considerations.

As this story indicates, vapor intrusion (VI) issues are increasing on the forefront of environmental site investigations and remediation.  But they can be a “Pandora’s Box” if you don’t understand VI.   In discussing this issue with one of my colleagues, Dr. Khaled Chekiri, he said, “The science of vapor intrusion is very complex and includes a number of variables that can have a significant impact on the fate of vapors in subsurface conditions.”

Vapor intrusion is an “environmental hot button” and you should be aware of it and enter investigations with caution. Like many environmental issues, a complaint from an employee, a neighbor, or even a teacher could bring you and your company into regulatory focus.

To read more about vapor intrusion, see our article (March 2011) in ESE “Vapour intrusion from soil and groundwater: A challenge for property owners”

Also, two Dragun Associates will be speaking at the Michigan Safety Conference on April 18, 2012 “What EH & S Managers Need to Know About Vapor Intrusion.”  

If you have any additional questions or concerns about vapor intrusion, contact Dr. Khaled Khekiri, P.E. ( at 248-932-0228.

Soil and Groundwater Remediation Seminar Returns to Toronto Area

Essential Information You MUST Have BEFORE You Begin Soil/Groundwater Remediation.

If you missed our seminars in April and October 2011, don’t miss this next opportunity!

 “I was pleasantly surprised by the seminar. I usually attend this sort of thing with some degree of trepidation because it is usually 90% biased sales pitch wrapped in 10% useful information. Your seminar was almost 100% useful or potentially relevant. I wish I had seen it seven years ago, before we started our remediation.”

-A CEO who attended our Soil/Groundwater Remediation seminar

What’s worse than realizing you have to spend time and money on soil or groundwater remediation?  Spending the time and money and getting no closer to the end point!

There is no doubt that there are many proven remediation methods and many contractors who can execute these remediation technologies…but…this should NOT be your starting point!  Before you focus on solutions, make sure you clearly understand the problem and how the myriad of potential solutions apply to your specific situation.  That is where our seminar will prove valuable to anyone who is now, or in the future, tasked with site remediation.

We will spend two hours helping you understand the fundamentals of site characterization and remedy selection.  We will also discuss how to avoid common mistakes in site assessments and subsequent costly remediation.


  • The basics of site characterization: What factors control what happens to releases?
  • The fate and transport of releases in the subsurface: What’s with LNAPLs, DNAPLs, sinkers, floaters, retardation, etc.?
  • Basics of site remediation: What is best for my site?
  • How to reduce groundwater remediation efforts and expense
  • Site remediation options
  • How changes in O.Reg 511 affect site activities
  • Mini-Case Studies

Senior Dragun associates, Dr. Michael Sklash, P.Eng. and Matthew Schroeder, M.S., will co-present.  Mike and Matt have worked on site assessment and remediation projects together for more than 15 years.

 Thursday, March 22, 2012

9:00 am to 11:00 am

(please arrive between 8:30 am and 9:00 am)

Best Western (Octaviens)

559 Bloor St. W.

Oshawa, ON L1J 5Y6

There is no cost to attend, but space is limited!

To reserve your space, contact Agnes

( at 519-979-7300

EPA’s 2013 Budget

According to a release from the EPA “… the Obama Administration proposed a FY 2013 budget of $8.344 billion for the U.S. Environmental Protection Agency (EPA).” Among the FY 2013 budget highlights are

  • Protecting America’s Waters: $2 billion for Clean Water and Drinking Water State Revolving funds
  • Cleaning Up Contaminated Sites in Communities: $755 million in funding for the Superfund Cleanup
  • Investing in Cutting Edge Research: $576 million to conduct research in key areas such as hydraulic fracturing, potential endocrine disruptors, and green infrastructure
  • Protecting Americans from Harmful Chemicals: $68 million to reduce chemical risks, increase the pace of chemical hazard assessments
  • Next Generation Compliance: $36 million to support “Next Generation Compliance” a new enforcement model designed to enhance EPA’s ability to detect violations that impact public health

To see more detailed information regarding the proposed budget, go to the EPA’s website

Correlation Does Not Equal Causation

Twisted logic:  You used chemical A.  Chemical A is found in the groundwater; therefore, you are responsible for the contaminated groundwater.

Correlation does not equal causation. Those involved in science and statistics are familiar with this phrase.  Correlation between two variables does not automatically imply that one causes the other. Correlation might provide us a clue, but all of the variables must be examined.

Examining all the potential causal factors is work, but it is where truth is found.

EPA Enforcement: $1.5 Million Clean Water Act Fine

According to a news release (2.9.12) from the USEPA, Union Pacific Railroad Company will pay $1.5 million for violations of the Clean Water Act and the Oil Pollution Act in Colorado, Utah and Wyoming. The alleged incidents date back to 2003 and 2004 along railroad lines in all three states.

Among the alleged violations were, oil spills, coal spills and inadequate SPCC plans and/or inadequate SPCC plan implementation.

In our October 6, 2011 blog, we discussed some of the common SPCC violations. One year earlier, in our October 26, 2010 blog, we discussed the amendments to the SPCC rules and the importance of implementation of the SPCC plan.

It does appear there is more environmental enforcement and settlement information making “headlines” in the past few months.

If you have questions or concerns about your SPCC plans and/or environmental compliance issues, contact Matthew Schroeder, P.E. ( at 248-932-0228.

Link to the EPA Release


Ohio Chemical Company to Pay $1.4 Million for TSCA Violation

According to a news release from the USEPA,The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice announced that Dover Chemical Corporation has agreed to pay $1.4 million in civil penalties for the unauthorized manufacture of chemical substances at facilities in Dover, Ohio and Hammond, Ind.”

The release goes on to say, “The settlement resolves violations of the Toxic Substances Control Act (TSCA) premanufacture notice obligations for its production of various chlorinated paraffins. Dover Chemical produces the vast majority of the chlorinated products sold in the United States.”

The proposed settlement agreement, lodged in the U.S. District Court for the Northern District of Ohio, is subject to a 30-day public comment period and approval by the federal court.

2012 is a reporting year for TSCA and as we stated in our January 26th blog, what makes this reporting cycle more noteworthy is that in August 2011, the EPA issued amendments to the TSCA Inventory Update Reporting (IUR) rule, so there may be increased focus on TSCA issues this year.

If you have questions regarding TSCA reporting or environmental compliance, contact Matthew Schroeder, P.E. ( at 248-932-0228.

Science vs. Scare

“The battle to feed all of humanity is over. In the 1970s hundreds of millions of people will starve to death in spite of any crash programs embarked upon now. At this late date nothing can prevent a substantial increase in the world death rate.”  Paul Ehrlich, in his 1968 book, “The Population Bomb”

Modern science and agriculture have proved Malthusian predictions of mass starvation wrong.

The ingenuity of men and women has served us well, let’s not allow junk science and scare mongers to thwart the advancements in agriculture.

GHGs at Livestock Agriculture Back in the Spotlight

“…factory farming in the U.S. is responsible for more GHG emissions than the entire transportation and industrial sector combined; including cars, trucks, buses, airplanes, trains, boats, and factories.”  That is the contention of authors of an article in “Counterpunch” (see link to the article at the bottom of this page).  The article has some other negative comments about large farming practices as well.

As it relates to regulation of GHGs, you may recall that in 40 CFR Part 98, the Greenhouse Gas Reporting Regulation Subpart JJ addresses Manure Management.  You may also recall that the EPA is not implementing Part 98, Subpart JJ due to a Congressional restriction prohibiting the expenditure of funds for this purpose.

And yet, there may be reason to keep an eye on the global warming debate as funding for “research” on the impact of GHGs continues. 

In a recent NASA study (January 2012), researchers suggest that 14 key air pollution control measures could, “slow the pace of global warming, improve health and boost agriculture production.” 

NASA goes on to say that, “While carbon dioxide is the primary driver of global warming over the long term, limiting black carbon and methane are complementary actions that would have a more immediate impact because these two pollutants circulate out of the atmosphere more quickly” (Black carbon is essentially the particulate matter from the combustion process, what might be called “soot”).

Of course, the next logical questions are what are the sources of methane & black carbon and what are the suggested control measures?

The NASA study offers seven measures to control methane emissions and seven measures to control black carbon emissions.  One of the seven suggested methane control measures is “Control of methane emissions from livestock, mainly through farm-scale anaerobic digestion of manure from cattle and pigs.”  The suggested measures for reduction in black carbon include “Diesel particulate filters for road and off-road vehicles…” and “ban on open burning of agricultural waste” (there was no further explanation of what is included in open burning).

Will this NASA study help influence EPA’s policy decisions? Who knows.  But certainly the interest in agriculture, whether as the focal point of studies and research or simply ad homonym attacks, has not waned. 

Keep a watchful eye on the GHG issue along with the countless other environmental regulations and court cases that can potentially have a significant impact on agriculture.

Article in “Counterpunch”