Henkel is a German-based worldwide conglomerate. Henkel was eager to quickly resolve environmental liability issues at their site in Morenci, Michigan. Their project was full of problems from the beginning. It became more and more complicated as time went on for several reasons.
- The site was a Resource Conservation and Recovery Act (RCRA) corrective action (CA) site, and Henkel had to negotiate with both the Michigan Department of Environmental Quality and the United States Environmental Protection Agency (USEPA) Region 5.
- The regulators kept making unsubstantiated claims about “perceived contamination” of the soil and groundwater at the Site; and as a result, the cleanup cost estimates were escalating.
- The regulators’ pressure grew as they focused on contaminated groundwater reaching a creek, thereby increasing potential remediation costs and long-term monitoring.
- The regulators wanted Henkel to follow “their remedial approach,” that would have forced them to bleed money on endless investigations and monitoring which meant the site might never reach closure.
- And Henkel had a potential buyer for the property; but, Henkel risked losing a sale of the property in a depressed industrial property market if it could not close the site quickly.
In the middle of the project, Henkel hired The Dragun Corporation. How did Dragun close this Site and save Henkel one million dollars?
- First, we did not blindly follow the regulators’ approach, but instead questioned their positions and data interpretations.
- Second, we had some contentious negotiations with the regulators during which we had to “gently” correct their misunderstanding and misapplication of technical information.
- Third, we corrected the mistakes made during previous environmental investigations by other consultants.
- Fourth, we collected the correct data needed to support a different, yet appropriate, remedial approach.
- Fifth, we closed the site using risk-based cleanup criteria, which was one of the first risk-based RCRA-CA closures in Michigan.
The bottom line: We “closed the book” on additional investigations, excessive source removal, and long-term monitoring. The Site was available for sale, and Henkel saved an estimated $1,000,000.