Kiran K. Srinivasan and Christina Robinson, ENTRIX, Inc.

A risk-based program was developed to address numerous crude oil leaks from a multi-state pipeline system. The risk-based program replaced a system where untrained local operations managers were in charge of responding to leaks. Due to the lack of a coordinated program, leak response and remediation activities were being conducted in an ad hoc and inconsistent manner. Millions of dollars were being spent on the leak sites with very few site closures on record. The sites were being characterized and remediated using dig-and-haul and chemical treatment techniques, without regard to site-specific contamination and exposure conditions. Landowners were also expressing dissatisfaction at the response to leaks on their land. More importantly, risks to human health and the environment were not being adequately addressed in the current approach. Due to a lack of health risk-based prioritization, many leak sites were being cleaned up to overly conservative standards, while other sites with greater health concerns were not receiving any attention. The authors were involved in developing a consistent and defensible, data quality objectives (DQOs) and risk-based, site characterization and remediation program to efficiently achieve regulatory closure and address landowner concerns. This effort included evaluating existing remediation contractors and analytical laboratories, and forging a contractor alliance that would result in cost savings and consistent work. A risk-based general remediation work plan was developed to address the leak sites. This plan was approved by the state agencies. Consistent site investigation and reporting standard operating procedures were developed and implemented to support risk-based closure. Presentations were made to the involved agencies and remediation contractors before implementing the program. The program allowed the use of site-specific, risk-based clean-up standards at the leak sites. The program was accepted by the agencies and resulted in a consistent, defensible, and cost-efficient risk-based approach to site closures.