TRW Saves Tens-of-Thousands of Dollars in Environmental Remediation Costs and Achieves the Improbable: An Approved RAP

TRW operated a manufacturing facility in Sterling Heights, Michigan. TRW’s environmental consultant gave their approval for a test track to be built on top of several former surface impoundments that previously stored oily waste. Soon after construction, oil began to seep into a drainage way, apparently squeezed out by the weight of the test track. In response,

  • The regulators revoked the pending remedial action plan (RAP) and made TRW clean up the soil and surface-water damage caused by the seep.
  • TRW then had to spend more time and money developing a revised RAP.
  • The previous consultant had TRW build a deep, more than 100-foot-long collector trench to capture the discharging oily waste and pipe it to their waste treatment plant, which was extremely costly.
  • TRW was required to conduct annual groundwater monitoring and operate their remediation system indefinitely. In short, they were bleeding money with no end in sight.

TRW asked The Dragun Corporation to peer review and assess Site conditions.

  • First, we determined that the monitoring well network built and designed by the previous consultant was incapable of indicating whether or not subsurface oil was present. They got it completely wrong.
  • Second, we discovered the shallow hydrogeology consisted of a thin permeable soil over a thick low permeability soil, very little groundwater, and only very small, isolated areas of free oil. Their consultant missed these “little” details that were extremely important to design the appropriate remediation.
  • Third, we excavated a shallow, exploratory trench across the former seepage area. The trench confirmed the hydrogeology we reported and more importantly, revealed the oil discharged from a single, car-key size seep at the base of the permeable soil. The previous consultant substantially over-engineered the existing remediation system. This meant TRW was needlessly collecting groundwater and spending tens-of-thousands of dollars annually on operations and maintenance (O&M).
  • Fourth, we re-engineered the exploratory trench to effectively collect oil only from the oil seep.
  • Fifth, we explained the problem and our solution to State regulators, who agreed with our analysis and proposed remediation plan. This was important because we now saved TRW tens-of-thousands of dollars in annual monitoring and O&M.

Finally, we prepared a RAP that the State approved, despite a regulatory climate which approved few RAPs. The new, approved RAP includes operation of the simple oil collector, annual oil and groundwater monitoring, and regular visual inspections. It no longer includes needless collection and costly disposal of discharge unrelated to the oil discharge.

We not only saved TRW tens-of-thousands of dollars associated with the old, over-engineered remediation system, we convinced the State our simple and cost-saving remediation plan addresses the problem.