Roux Associates was retained to assist in the evaluation of a facility sewer system at a food supplement manufacturer in West Virginia (EPA Region 3).  The facility sewer system was identified as a SWMU due to direct observations of discharges during the RFA process.  In developing the SWMU-specific Work Plan, Roux Associates compiled facility information into a database that included sewer locations, invert elevations, age, materials of construction and any information on repairs.  This information was compared against available groundwater data and verified that releases likely occurred.  The EPA required that an initial camera study be performed along the entire conveyance system.  If areas of breakage, misalignment or cracks were identified, then soil samples would need to be collected, and emergency repairs would need to be made within 48 hours.

The storm sewer and combined sewer system at the facility included over 20,000 linear feet of mains and over 100 manholes, some of which date back to 1914.  Existing facility records including previous videotape records and interviews with maintenance personnel suggested that additional investigations would have resulted in a significant level of follow-up repairs and investigations.  It was determined that the time required to carry out these investigations, the premium economic factors of repairing lines on an emergency basis, and the financial considerations of impact on facility operations would be prohibitive, especially given the likelihood that stabilization/corrective measures would inevitably be required for any defined impact to surrounding soils and groundwater.  Therefore, it was negotiated with the EPA to proceed directly with stabilization/corrective measures for the sewers under the following key conditions:

  • no soil samples would be collected along the sewers, and any impact would be addressed through groundwater only;
  • the rehabilitation program would be focused on process sewers only, as these sewers would result in the most significant environmental benefit;
  • the remaining sewers could be used without any rehabilitation for non-process cooling water and storm water; and
  • the implementation would be performed over a 10-year period to allow the facility to raise capital and minimize effects on production.