Our experienced team has a demonstrable track record with respect to helping industrial and other clients understand, rationalise and manage residual liability issues associated with contaminated land.
At old industrial sites, where hazardous chemical storage and use is core to production, some contamination of land (including groundwater) will have been inevitable. Even smaller scale or simpler manufacturing sites can have a significant environmental footprint, particularly if they have a protracted industrial heritage.
Our expertise lies in designing and implementing targeted site investigation and assessment programmes to define and prioritise what really matters. This may involve negotiating (on behalf of the client) with regulatory authorities to ensure an appropriate way forward and avoid unnecessary or too onerous corrective action.
Risk assessment is used to guide investigation programmes and ultimately this leads to more focussed and cost effective sloutions.
Where corrective action is required, whether as a result of regulatory, corporate or other drivers, we are expert at carrying a project forward through this next, crucial step. Managing and dealing with residual liability issues has to be done in the same way clients make other expenditure or investment decisions. It must be understood, costed and programmed within the budgetary framework that the client operates.
We provide a range of services designed to take the site investigation knowledge base (whether provided by Ford Consulting Group or a third party) and give clear direction as to the way forward. These include regulatory engagement support, feasibility study, design and implementation of pilot-scale remedial testing (if needed), outline or full-scale design, remedial contractor identification, tendering and selection, and project management and validation of the corrective action programme.
We use the term Corrective Action rather than Remediation because it includes a broader range of potential solutions, including typically lower cost options such as Monitored Natural Attenuation (MNA) and simple pathway elimination. We are retained by our clients to apply proven technologies to often complex problems, whilst offering solutions that are technically better, cost effective and more manageable at the implementation stage.
Trouble shooting may be linked to a client's need to get to the bottom of an issue that has been concerning them for some time, or a more reactive situation that may need understanding and addressing as quickly as possible.
There may be a need for a second opinion or third party scrutiny to ensure a particular programme of work (e.g. corrective action programme) is on track and is reasonable in terms of scope, time frame and/or cost to the client. What clients need, but do not always get, in this situation is access to a true expert who can quickly understand the important issues and come up with an answer, and confirm the appropriateness of what is being done.
Similar qualities are needed in a reactive emergency response situation (e.g. sudden hazardous material release). Our track record in dealing with such situations is exemplary.
Contaminated land and residual liability issues are becoming increasingly contentious as the number of sites that are classified as either Contaminated Land or Special Sites continue to increase and regulators issue more remediation notices or planning related controls.
Understanding contaminated land issues is not always an exact science, and it is common for there to be more than one way of interpreting the information available. The better knowledge and experience one can apply the more likely the correct path will be taken.
Ford Consulting have the expertise and experience to provide a robust assessment of the issues and expert advice or testimony if necessary in the case of potential litigation.
Permitting (PPC) support takes the form of assisting clients with the characterisation of their hazardous chemical and waste storage, transfer, use and generation on-site, focussing on containment and control. In the UK these have been initially reported to the regulatory authority in the form of an Application Site Report [ASR], followed by a recommended Site Protection & Monitoring Programme [SPMP]. There may have been a need to collect initial reference data designed to establish a baseline site condition with respect to contamination of soil and groundwater, as part of the improvement programme embedded in the PPC Permit, or later followed by ongoing monitoring. In the case of site closures there will be a need to collect a repeat set of data to compare with the original baseline and undertake corrective action as needed.
Residuals Management Planning (RMP) is all about protecting corporate client needs (including reputation management) during a site rationalisation and closure scenario. RMP auditing is focussed on managing the residuals in terms of chemicals and wastes, treatment and abatement systems, during plant closure.
Whilst it is usually straightforward to manage emissions and waste generation during normal production, this is not the case during closure when ramping down of production and high levels of system flushing and cleaning take place. There can be significant unnecessary cost and regulatory non-compliance issues to deal with if management of the closure scenario is not robust.
Transaction support is another core service offering. A significant proportion of industry is rationalising its business in the UK & Ireland. Part of this process involves divesting certain business units, sites, or landholdings to third party buyers, providing cash injection to the remaining operations.
Ford Consulting can support such programmes, by assessing and quantifying environmental liability issues, whether for the vendor, the acquirer, or both. The high level of knowledge and practical experience vested in the founding directors and company principals allow rapid wood-from-trees type assessment and reporting to the interested parties on the main issues of potential concern. These are often linked to residual contaminated land issues.