Comments on Alternative methods
of remediation that are non-invasive
 
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Alternative methods of remediation that are non-invasive
From City of Berkeley to L A Wood, January 26, 1994

This is in response to your letter dated January 3, 1994 to the City Council and a recap of the meeting held on Friday, January 21, 1994 with Denise Barndt and Nabil Al-Hadity of the Emergency and Toxics Management program.

Based on the discussion at that meeting, staff would like to expand on the two issues that concerned you most:

1. Alternative methods of remediation that are non-invasive.

As you correctly pointed out, it is apparent that the primary method of remediation for contaminated soils seems to be excavation and disposal or recycling of contaminated or polluted soils. Alternative methods are available, such as bioremediation, bioventing, vapor/water extraction and a combination of the above. It should be pointed out that some vapor extraction methods are capital intensive technologies and bioremediation may prolong the remediation time. As discussed, there are technical reasons that limit the application of bioremediation and vapor extraction, but it does appear that the methods can be used more frequently.

The Toxics Management Program staff do not specify the methodology for remediation, the City is charged with reviewing the choices made by the responsible party (tank owners or operators) and their technical/ environmental consultants. It is only on occasion that we reject the method suggested because our experiences prove the method unworkable. The City has always been interested in promoting pilot schemes for bioremediation and we will continue to do so.

It was also suggested that the Community Environmental Advisory Commission may be interested in asking certain questions of environmental consulting /engineering businesses that would encourage them to focus on non-invasive methods of remediation. The staff will supply you with a list of companies that are active in environmental remediation in the East Bay and we suggest the following list of questions:

1. What do you consider to be non-invasive and environmentally acceptable remediation methods?
2. On how many sites are you the lead contractor in such remediation methods?
3. What is this as a percentage of overall sites you administer?
4. What percentage of sites using non-invasive methods have received closure in California and outside California?
5. What are the drawbacks of the non-invasive methods?
6. What are the advantages of the non-invasive methods?
7. What is the main reason why non-invasive technology is not more popular?
8. What can be done to promote applicable non-invasive technology to your prospective clients?

2. Contractor incompetence during tank removal and site remediation.

The staff is again in agreement that there are occasions where risks are taken and jobs are left incomplete. The staff has been pro-active on requiring written site safety plans for any excavated site involving hazardous materials. Jobs have been stopped due to the inadequacy of site safety. However, incomplete or inadequate work is more difficult to control.

The recently reestablished State Tank Funds program (SB 2004) has given the City a greater control of reimbursement of State funds for clean-up programs. If incompetence is witnessed, the City is able to recommend to the State that the job did not meet our standards and that the responsible party should not receive any compensation. The City is also insisting on the presence of State certified geologists and engineers and we will insist in the future that such a professional be present on site if we are not satisfied with the professionalism of the contractor.

Should you require further assistance, please call Denise Barndt at 644-6644 or Nabil AlHadithy at 644-7719.
Weldon' Rucker Acting City Manager

cc: Tamlyn Schafer-Bright, Chairperson, Community Environmental Advisory Commission Denise Barndt, Assistant to the City Manager, Emergency and Toxics Management Program Nabil Al-Hadithy, Hazardous Materials Specialists, Toxics Management Program
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