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Is the driver behind environmental spend reasonable given changes in regulation, risk management philosophy and key personnel?  Allen Peterson has a passion for questioning status quo and pressing for supportable change that satisfies all stakeholders while saving money, expediting schedule, eliminating waste and improving long term outcome to create sustainable competitive advantage.

The following are actual case studies where Peterson identified and confronted unsupported environmental drivers and saved millions.

Floreffe, PA

Floreffe

Floreffe, PA – 1988

In 2008, Peterson was given project management responsibility for Floreffe, Pennsylvania 20 years after an aboveground diesel storage tank catastrophically split on a cold wintry night in 1988 and caused the largest inland petroleum spill in the United States.  3.8 million gallons spilled on the ground of which 800,000 went into the Monongahela River.  An extensive site-wide remediation system continued to operate which extended the stigma of the unfortunate event and perpetuated regulator distrust.  Remediation continued to be driven by a punitive and unattainable 1988 Consent Decree between the operator, the State and the Federal government that contained strict cleanup goals that were not field proven.

Proactive research by Peterson revealed that more forgiving risk-based cleanup goals had been adopted by the State in 1997 (nine years prior), and that with confirmatory sampling, current site conditions should allow closure.  In 2009, Peterson rekindled negotiations with the State and Federal government and successfully pressed for risk-based closure.  After a final round of sampling closure was awarded, the unattainable 1988 Consent Decree superseded, and all remediation equipment removed.  The cost and stigma of this unfortunate event was gone.

New York

New-York

New York – 1960s

In 2013 as $250 million preparations to remediate this former wire manufacturing plant were being made, Peterson investigated underlying drivers which revealed that a 2003 Federal Consent Decree negotiated with the Village that was in significant conflict with a 2013 Consent Order issued by the State.  The 2003 Consent Decree was created at a time when the public demanded control amidst many unknowns, and the control they received confounded remedy design and hindered site reuse.

Additionally, the footprint of a large 2.5 acre historic building had been excluded from soil cleanup plans since all parties assumed that a federal Toxic Substances Control Act (TSCA) PCB cleanup exemption would allow the building to remain as cover.  Peterson evaluated the risks of allowing PCB to remain and reversed the responsible party’s thinking before making a public appearance to support demolition and inclusion of the building’s footprint in site cleanup.

With the aid of historic architect, Peterson successfully reversed the State’s ruling on historic listing which paved the way for demolition.  Information was prepared, education provided and negotiations held with the Village to establish an amendment to the 2003 Decree that untangled conflicting issues with the State’s remedy and removed related hindrances to site reuse.

New Jersey

New-Jersey

New Jersey – 1960s

A 2002 purchase of an industrial site on the Raritan River triggered assessment under New Jersey’s Industrial Site Recovery Act (ISRA) which revealed historic site contamination.  A large electrolytic copper plant had operated from 1899 to 1975 before it closed and was repurposed as a steel mill.  ISRA allows owners to seek contribution from other responsible parties, and the new Owner sought over $50 million from the copper plant Successor.

In 2015, Peterson led the Successor’s team to gather information, determine alternate remedial paths forward, and document historic conditions which demonstrated that much of the contamination had likely been present in indiscriminate fill used in the late 1800s.  Responsibility for the contamination wasn’t as clear as the Owner had alleged.

Negotiations resulted in settlement at a fraction of the Owner’s initial claim with the Successor’s interests protected through remedial performance bound to the Owner’s parent.

Florida

Florida – 2006

A 2006 underground diesel release at a high volume terminal resulted in drilling and assessment which discovered feet of product on the water table that was headed offsite under a busy six lane highway.  The facility had been in operation since the early 1930s, loaded 300 trucks 24 hours per day, had only one exit, and was the largest volume terminal in the United States for this particular Operator.

Peterson was brought in to assist.  Whether resulting from the 2006 releases or from routine accidental spills seeping through cracks in the pavement, to Peterson it was clear that it was in the Operator’s best interest to simply stop and recover product from all sources before offsite migration occurred.

Peterson led a team to conceive and install a $4 million underground barrier wall to skim product off the water table and allow recovery.  Excavation for the 400’ long 8′ deep wall was performed entirely by vacuum to avoid damaging unmarked utilities and shutting down the terminal.  The construction schedule was precisely maintained to keep from upsetting terminal operations.  Drilling in the center of a highway was coordinated safely without incident and demonstrated that neighboring houses were not at risk.

Florida – 2007

Kentucky

Kentucky

After structural failure occurred, Peterson determined the reduced operating pressure of a 260-mile 24” crude pipeline while maintaining flow with drag reducing agent, averting the catastrophic shutdown of a 225,000 barrel per day, $9 billion per year refinery.

Illinois

Illinois_01

Peterson led a multidisciplinary team to evaluate and modify equipment to increase capacity by 70,000 barrels per day through what was previously believed to be a fully-utilized 16” products pipeline, saving millions on unnecessary extra equipment.

Illinois

Illinois_02

Illinois

A block valve on a 10” products pipeline developed a leak and impacted 22 acres of private land and groundwater in a rural area of Illinois.  A Corrective Action Plan was implemented in June 2002 with the installation of three large in-situ biocells at a cost of over $9 million.  Planning for a $3 million biosparging system was well under way when management of this project was presented to Peterson.

Peterson took a more scientific approach by working with experts to: 1) develop risk-based cleanup criteria; 2) halting the biosparge system installation; 3) monitoring groundwater conditions, and; 4) negotiating Environmental Land Use Control (ELUC) agreements with three local residents.  Peterson obtained No Further Action approval from the State a fraction of the cost of previous plans.