Closure Strategies & Agency Negotiations
AMO’s business involves helping clients make informed and responsible decisions regarding their environmental concerns. Through our collective years of experience, we have successfully closed or achieved other significant outcomes on projects in Florida, Kentucky, Michigan, New Jersey, New York, Pennsylvania, Texas and other sites in North America. We have similar consulting experience in Australia, Canada, China, England, Hungary, and Mexico.
Although environmental decisions can be difficult, we believe that most project-specific strategies fall into place by looking at the “big picture”. For example, answers to questions such as: When and how much agency involvement do we want/need?; Is regulatory review and approval wanted or necessary for this project?; How large is the area of potential concern?; What are the potential environmental pathways and potential receptors at risk; How much potential future 
liability are we (the client) willing to bear?......often result in focused, cost-effective work assignments that are (from the start) specifically geared toward closure of the project.
Discussion of realistic alternatives and determination of a client’s closure objectives in the beginning of a project leads to tighter, better defined scopes of work. This translates to more timely completion of the project and bottom-line savings.
Brief: PADEP Act 2 Closure
Messrs, Ash and Malmquist met with representatives of the printing/publishing company within 24 hours of client’s discovery of a 12,000-gallon no. 2 fuel oil spill. A conceptual plan was developed during this meeting, which considered properties of the fuel, and geologic and man-made features of the area. Due to the presence of clay surrounding gravel fill in which the spill occurred, it was determined that migration of the fuel would be limited if product recovery was possible from within the gravel. Nearly 100% of the product was ultimately recovered through vacuum extraction and other methods. AMO scientists were also able to negotiate closure (PADEP’s Release from Liability under Act 2) without a costly groundwater investigation by: 1) demonstrating attainment of PADEP Statewide Health Standards in soil; and 2) showing incomplete pathways to potential groundwater receptors.
Brief: KDEP Site Redeployment
Directed closure activities associated with former chemical manufacturing facility in Louisville, Kentucky. Project tasks included: collection and analysis of soil samples; assimilation of historic data into a site-specific database; development of site-specific, health-based cleanup criteria; evaluation of soil and groundwater impacts relative to Kentucky Department of Environmental Protection's (KDEP's) most stringent cleanup criteria and site-specific health-based cleanup criteria; negotiation of site closure strategies with KDEP; and the preparation of the Site Closure Assessment Report submitted for KDEP review and approval. Client received KDEP-approved NFA for site.