Regulatory Process
The Maine Board of Environmental Protection Order, which became effective in April 2014, requires the removal of two landfills and the recapping of three others. Certain site soils within the former manufacturing area must also be removed and sediment both on site and in the adjacent cove in the river will also be addressed. Due to the scope of remedial activities required in the Order, it was a challenge to find a remedial project management firm that could meet all the selection criteria, which included experience with mercury and chlor-alkali plants, sediment remediation, landfill excavation and capping as well as an understanding of Maine regulations and a history of working successfully with the Maine Department of Environmental Protection.
While selecting a team of different firms requires significant communication and coordination for this type of project, CDM Smith, Geosyntec and Anchor QEA joined together because they recognized that each firm contributes unmatched proven experience in the most important facets of the program – successful design and construction of projects in Maine and successful completion of large-scale mercury remediation sites. The three firms have complementary skills and respect the others’ areas of expertise.
Overview of Regulatory Process
Environmental agencies such as the Maine Department of Environmental Protection (Maine DEP) and the United States Environmental Protection Agency (USEPA) have the authority to regulate and oversee the remediation of contaminated sites based on laws and regulations that have been enacted by federal and state legislatures to insure that the environment and the human health are protected.
The Orrington Site Remediation is being conducted under an administrative order (Order) issued by the Maine Department of Environmental Protection (Maine DEP) and the Maine Board of Environmental Protection to Mallinckrodt US LLC (Mallinckrodt) as a former owner and operator of the facility. When HoltraChem Manufacturing Co was operating the facility, the Site clean up was being investigated under the Resource Conservation Recovery Act (RCRA) Corrective Action program under the oversight of USEPA and Maine DEP which requires sites that have managed certain types and quantities of hazardous waste to be remediated at the cessation of operations. When HoltraChem ended operations, the Maine DEP issued an Order to Mallinckrodt to complete the same type of remediation obligations under the terms of the Order. The Order outlines the specific areas of the site that need to be cleaned up and generally describes the requirements for investigating and remediating these areas. There are generally three phases of work which need to occur when conducting a clean up at a former manufacturing facility, regardless of the contaminants of concern, including investigation, remediation and confirmation that remediation has been completed to agreed upon standards. The process of cleaning up an abandoned site is an iterative process that requires coordination and cooperation between the party conducting the work and the agency overseeing the clean up.
Maine DEP has a more detailed description of the process at the Maine DEP website.