The importance of the site history
Selecting the right remediation contractor
Environmental monitoring and management
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Sharing experiences

In 2019 the author of this contribution met the team managing the STEIH remediation project to find out more about the work being done at the site. He wanted his findings to be taken into consideration by the people in charge of another remediation project in Central Europe. They show that the experience gained by Novartis can give crucial momentum to future remediation projects.

Text by John Vijgen, photos by Gregory Collavini

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Published on 01/07/2021

At the end of January 2018, I was approached by a Central European public authority to assist with the implementation of the clean-up of a large HCH waste site at a former lindane production facility. My task was specifically to assess the technical scope of the tender documents, i.e. the framework for the implementation of the project by the successful contractor. After reviewing my files and the cases I had been involved in, including my compilation of HCH case examples, I could see that much of the available information was outdated, and for many of the cases with high-level descriptions only. So, despite all my 30 years’ experience, I lacked proper, well-documented records about the detailed problems which I knew would occur on the site of my client during clean-up.

The situation was not new to me. HCH sites are some of the most complicated and costly sites to analyze and clean up. Sharing information on HCH-contaminated sites is therefore not top of the list of problems faced by owners, whether public authorities or private companies. Yet these are sites where both human health and the environment are under significant risk.

Contact with Novartis

At the time of my new assignment, I already knew about the clean-up at Novartis through the STEIH newsletters, and I had already been in contact in February 2018. They kindly provided me with technical data on the extent and cost of their clean-up activities at the STEIH site. The information was to be disclosed in a report I was planning to publish with colleagues about the extent of the HCH problem in the member states of the European Union.

On that basis, I wrote a request to Novartis at the end of November 2018 to discuss the possibility for a technical exchange on all the expected practical issues my client would face during his project. We were mainly interested in specific implementation approaches for odor and dust emissions and the experiences made with environmental enclosures (i.e. tents around the excavation works). We hoped to transfer specific experiences and possibly also new developments in work approaches. A whole lot of “hot and not always pleasant issues” were highlighted, such as:

– How do we ensure we have adequate information on the contamination to guarantee the remediation project is efficiently executed?

– How would we ensure that we avoid a contract being awarded to a party with insufficient knowledge of the complexity and severity of HCH problems?

– How can we manage dust and odor emissions of HCH and degradation products, an area with very little published experience?

– How can we most efficiently communicate with project stakeholders?

To be honest, I had expected a standard politely written excuse that such a technical exchange would not be possible. But I was proven wrong! At the beginning of January 2019, I received a message from Novartis that they were willing to share their experiences and were open to discuss all issues on our list. Our discussions were held shortly afterwards on-site at a two-day meeting with representatives of Novartis, the consultant company and the contractor, along with my Central European client and myself. During these two days we received every possible input, and everyone involved showed a genuine interest in assisting my client and me as much as possible by sharing their own experiences. This was much more than we could have expected.

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The im­port­an­ce of the site his­to­ry

It cannot be repeated enough. The site history is of utmost importance, as are a knowledge and understanding of the activities that may have redistributed the historic contamination over time. At the remediation of the STEIH site the history is unclear, and it was particularly unclear whether the whole area had to be remediated.

Historical records of the existing contamination during construction of a wastewater treatment plant at the site (in 1973) were not kept, if they had ever existed at all; and a 2011/12 drilling campaign with between 70 and 80 drillings was insufficient for the very complex and redeveloped site. In hindsight, the Novartis colleagues shared their assessment that the investigations may not have been detailed enough to conduct an efficient remediation project. The experience of resuming the remediation in 2015 as a consequence of the missing information on the contamination was an important lesson learned for sharing, and one we took with us back to our site.

Looking at my own experience, soil and groundwater investigations are often looked upon as a time-consuming but necessary exercise. As a result of it, such projects are often implemented very quickly with limited scope and not always focused on providing future remediation works with the necessary overview. This leads to unexpected and often considerable increase in costs during remediation. Even when pressure for future building activities is high, proper historical investigation needs to be done. The provision of a detailed understanding of the contamination on the site cannot be left to a remediation contractor to discover during execution – especially in the case of a complex issue such as the production of technical HCH and later of lindane generating huge amounts of HCH waste.

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Selec­ting the right re­me­dia­ti­on contrac­tor

Assigning the remediation works and responsibilities to a capable contractor is one of the most important decisions in the whole clean-up process. At the ARA-STEIH site the contractor assigned to the first phase of the remediation was not perceived to be very well organized. This despite the contractor’s extensive international experience and excellent reputation within the field. Naturally, one had relied on the contractor having full control over the works. But due to the complexity and maybe also novelty of the operations, the contractor had insufficient control over the tent structure to prevent emissions from the site, and the emissions treatment was deemed inadequate. Also, emissions were too high during transport, and continuous monitoring was needed. This situation needed to change and, in September 2013, a time-out was called, and all activities were stopped. Almost a year was then utilized to improve the situation.

In writing this article, I must admit I find it strange that the selected contractor had not insisted on having more information about the contamination on the site, or at least ensured that its tender provided for more investigations to be carried out in order to limit all existing risks and uncertainties. The insufficiencies with the tent structure and tent placement could for example have been addressed if there had been more information.

It should, however, be pointed out that, in my experience, the complexity of HCH sites means that a close collaboration needs to be established between client, consultant and contractor. Without insight into the specifics of the contracting format from this first phase, it is my experience that many sites have been remediated within standard contract frameworks often resting on the principle of the lowest price. The contractor is thereby reduced to a “doer.”

After the resumption of the remediation works, a new tender was launched built on functional requirements. The specifications did not extensively describe how the works should be carried out, but had very clearly defined objectives and requirements for the bidders, including a description of how proof-of-concepts should be established. In this way, the real experiences of the most expert bidders came to the table.

When the second phase was started, 68,000 cubic meters had already been excavated and partly treated on-site or exported for treatment. This left around 168,600 cubic meters to be additionally excavated and around 193,000 cubic meters still to be disposed of. At our meeting in January 2019, this estimate had risen to 502,000 cubic meters.

Many of the remediation works that have been in trouble suffer from a lack of proper understanding of the contamination at the sites. As mentioned above, this is crucial for HCH sites. Based on the excavation works implemented and the acknowledged insufficient investigation in 2011/12, the question is whether, between the time-out and the resumption of work, an additional detailed investigation could have had a beneficial effect on the whole project. This could also have included a renewed review of the historical records.

The new Novartis contract framework introduced a testing phase prior to the main contract works, showing a way to generate site-specific evidence and confirm the selected approaches and methods by piloting and tests. This significantly ensures the efficiency of the overall site clean-up. In the testing phase required in the tender documents, all unit operations of the remediation undergo on-site tests for their planned functionality. This ensures that weak points in the practical set-up are identified and that the fully operational remediation works are functioning on-site after the testing period according to plan. Such an achievement can only be reached through a close cooperation between the consultant, the contractor and the client. And during my visit, I observed a positive team atmosphere among contractor, consultant and client. They appeared to have a common interest in solving all the problems.

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En­vi­ron­men­tal mo­ni­to­ring and ma­nage­ment

Meeting the highest requirements of health and safety and avoiding emissions into the environment by using better-quality tents and (wherever possible) capping the old tents ensured containment of the emissions, including strong benzene emissions. Application of the latest technologies, such as docking stations for excavation and transport equipment, container overloading, a new ship-loading facility and installation of air and wastewater treatment plants. The Contingency Plan Air Monitoring for the site includes Decision Tree Air Monitoring Values and provides the necessary HSE Action Criteria, and it has proved to be an excellent management tool. This experience is new and unique and worth transferring to all other HCH sites. Over the period from 2013 to 2019, the STEIH project with its present team has certainly obtained the most important experiences yet on the remediation of HCH.

Transparency and communication

Communication is vital for the success of all projects, but even more so in an area where many stakeholders from several countries are involved (France, Germany and Switzerland), and where remediation criteria, risk assessment tools, etc. had to be agreed. Public awareness is considerable in HCH cases, so transparency is essential. It is therefore noteworthy that the initiative was taken to install a website “sanierung-steih.ch” at the end of October 2013 as a tool to inform stakeholders and the public at large on a continuous basis. All public meetings were announced there, and technical presentations were made available. Also, the fact that Novartis has taken the initiative to publish the unique experiences and disseminate them in this book shows a willingness to share experiences that can be used by others facing similar HCH remediations now and in the future.

Acknowledgement

As a final remark, I would like to express my sincere gratitude for the openness in our discussions in January 2019, and the valuable information on contracting formats, emissions management and controls that was offered to us. In this respect, too, the Novartis HCH remediation project is unique and worth copying in other projects.

John Vijgen is Director of the International HCH & Pesticides Association and has dealt with numerous lindane remediation projects in the past 30 years. Novartis would like to thank him for his honest assessment of the STEIH remediation project.

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