Published on 01/07/2021
Hardly a project in my entire career has kept me as occupied as the remediation of the former STEIH and Ugine Kuhlmann site, for which I was responsible for more than a decade as the sponsor of the project. This period was a permanent learning curve for me, alternating between joy and hope, annoyance and disappointment. I also made misjudgments. With hindsight and based on the current status of the findings, I would certainly have made some different judgments and, in some cases, made different decisions as well.
Starting point
The STEIH redevelopment project concerned remediation of lindane under very special circumstances and on a scale that had never been achieved in the entire world. This meant that we had virtually no experience on which to base our planning. We have gained this experience in the last ten years and, in doing so, acquired considerable expertise on a highly complex topic. This publication is intended to document and pass on that knowledge. I will now briefly address the most important findings and lessons from my perspective.
Analysis and planning at the start
One of the most important findings was that such a remediation needs to be tackled with an in-depth analysis of the starting position. We certainly prepared an analysis for this project – however, it was mostly based on third-hand historical information. It is well known that this was due to the fact that it was a contaminated site that Novartis inherited and was not itself responsible for creating. The company therefore did not have any records of its own relating to the history of the site. Much of the information was not available in the degree of detail required. The results of the geological investigations were in line with the contamination that had come about in the production and storage of lindane. The network of test drilling – 20 meters apart – proved to be insufficient for our project, especially as no remediation was carried out following the production of lindane that caused the worst contamination. Indeed, a huge wastewater treatment plant was built right on and with the contaminated soil. As a result, the lindane-contaminated soil was involuntarily carried across the whole site. As a consequence, we were surprised time and again by pockets of contaminated material, even deep below clean layers of earth.
Another point that we had underestimated at the beginning of the project was that the targets were too ambitious. The target figures we set were far below the figures of the statutory provisions in terms of both the averages and the tolerable individual limits.
Finally, we gave too little consideration to the odor emissions of lindane in our planning. People sense even tiny concentrations (nanograms) as an unpleasant odor. As the remediation was conducted at the border triangle and near residential areas, considerably more importance should have been attached to this aspect from the outset.
Major and very thorough technical analysis would have made the dimensions of the remediation project clear from the start and would have allowed the time and cost factors to be calculated more realistically. If we had known the critical facts and factors at the beginning or at least had an idea of them, the remediation project and the relevant planning for it could have been designed more realistically and the communication could have been orientated to this. Saving money in the planning of such a complex project is certainly the wrong way to go about it.
Project and partners
One further key point is the way the criteria were set for selecting the partner companies commissioned to carry out the work. When selecting partner companies, there need to be clear requirements in relation to governance which include everyone involved, as well as detailed scrutiny of the financial and technical resources of a potential partner.
Unknown situations and specific risks lurk in every remediation project and can ultimately lead to misjudgments and bad decisions. It is therefore essential that all parties involved maintain an open and honest dialog in an environment based on trust. Discussions need to be controversial, animated and critical; however, they should remain constructive at all times. Only on this basis can the problems that arise be analyzed correctly and the best possible solutions be found. The ability and willingness of a company’s representatives to have a constructive discussion are just as important as its technical qualifications. Ultimately, collaboration in such a project is not restricted to the traditional relationship between a contracting entity and a contractor; it is about a partnership on an equal footing. This is the only way to create the conditions needed to identify problems in time, solve them and implement a remediation project flexibly and successfully.
In a partnership, it is crucial in particular for all concerned to agree on the right incentives. A blanket cost agreement without flexibility – which is what we had with the first company in the sense of a general contractor agreement – proved to be unfit for purpose.
Infrastructure and technologies
It is well known that the project had to be stopped temporarily owing to dust and emissions. The main reason for this was the lack of technical infrastructure in the first phase of the remediation. Contrary to all the statements made by those responsible for implementing the project, the marquees on the perimeter to be remediated were not sufficiently sealed. Loading ships for the excavated material with low levels of contamination proved to be another weakness.
The technological aspect of remediation is a key factor for success. Regrettably, our experience in this respect was not good, which led to a longer interruption to the remediation and associated financial and time-related consequences. This stop was necessary, not least in order to have time for a detailed analysis of the remediation work carried out up to then and to start a learning process. It also enabled us to carry out an updated assessment of the situation and risks, as well as to develop new specifications which contained a new and more precise description of the technical requirements and the aforementioned additional criteria that our technical partners would have to comply with. Based on this, we decided to put the remediation work out to tender a second time and continue the project with new partners.
Adjusted technologies and processes were therefore applied when the remediation work recommenced. Examples here include the use of remediation marquees with a vacuum and the consistent shielding of all transport routes for contaminated soil. The processes developed by the project team together with the new general contractor and the relevant subcontractors were key to the remediation finally being completed successfully, albeit at a cost of over CHF 300 million – many times more than originally budgeted for. The residual contamination of the soil and groundwater was significantly below the maximum and average statutory limits, and it was also possible to reduce emissions to below the defined and desired limits.
Authorities and general public
My greatest concern across all phases of the project was always the safety of people and the environment. The decision to carry out the remediation was motivated by the will to permanently eliminate existing and potential dangers resulting from lindane residue. Based on the original assessment of the situation, we proceeded on the assumption that the remediation would take considerably less time and result in much lower costs. Against this backdrop and given the fact that the site is in the middle of an industrial area, we initially attached insufficient importance to public relations. Active communication did not take place when the work began. Although the population of the region were aware of the easily visible marquees on the site by the Rhine, they did not know what was happening there for their own protection. Based on what we know now, this is a prominent example of where we missed an opportunity to proactively inform the public how Novartis was voluntarily taking action to help them and their environment.
It was not until the work was interrupted and restarted that we took this opportunity; this resulted in active communication and an intensification in public relations work, with local residents being involved. Although we were in contact with the authorities responsible in France and Switzerland from the beginning, this exchange was not formally defined in the project organization in the sense of a political project committee, and those responsible did not meet regularly. This changed when the remediation work restarted; from then on, representatives of all the authorities involved took part in periodic meetings. This platform enabled a seamless, cross-border exchange of information; moreover, any problems that arose could be discussed and solved in person, eliminating barriers and opposition. There were also regular meetings concerning the environment at a technical level between the project team and the persons responsible from the French and Swiss authorities. It therefore makes sense to formally define such committees in the project organization right from the start.
Conclusion and thanks
I am sure there are lots more findings and lessons to be learned from the history of this remediation project. Each individual involved would be able to add a point or two. Despite all the mistakes that we made, we can take great satisfaction in the fact that we have permanently remediated the soil on the site – without endangering the population or the environment. We have brought a highly complex project over ten years to a safe conclusion without any accidents, and I would like to thank everybody involved for their tireless efforts.
I look forward with interest to the future development of the entire area as part of the cross-border “3Land” project. I am convinced that the remediation of this centrally located site will make an important contribution to the development of the region as a whole.
Martin Ch. Batzer was Global Head of Novartis Real Estate Management, Facility Services, Health, Safety and Environment
