Evaluation of Contaminant Sources from Adjacent Facilities
Consultant conducted a forensic investigation and prepared technical materials in support of litigation and environmental cost allocation for a groundwater contaminant plume that extended approximately 4000 feet down gradient from a chemical facility. Consultant's client (plaintiff) was a chemical formulation facility that claimed that the source of the widespread groundwater contamination was emanating from an adjacent facility that specialized in metal fabrication and electroplating.
The problem involved commingled contaminants from adjacent chemical and manufacturing facilities and determination of the source for the principal contaminants, trichloroethylene (TCE) and chromium. The chemical formulation facility used small quantities of TCE in their laboratory and chromium was a minor constituent in one of their products. Neither was used in sufficient quantities to produce widespread contamination. TCE is a primary degreasing agent for cleaning metals and chromium is a primary plating agent. Large quantities of both contaminants had been used at the plating facility owned by the defendant.
Consultant reviewed the geological, hydrogeological, and chemical data for both facilities and all adjacent properties. The review included all site specific drilling and sampling data (soil and groundwater) and data for city and private water wells within a three-mile radius. Consultant recommended collection of additional data to fill data gaps identified during the data review, supervised data collection and developed a database. Consultant produced contaminant distribution maps (Figures 1 and 2) for both facilities for the years 1990 through 1995. Consultant met with client's technical staff and corporate council to develop a technical approach and determine what technical materials would be most appropriate for the trial.
Consultant developed a site conceptual model and prepared geologic cross sections and a 3-D representation of the subsurface. He then conducted groundwater and contaminant transport modeling of the organic and inorganic chemicals for both facilities using MODFLOW and MT3D. The results of the modeling clearly demonstrated that the TCE and chromium contamination originated on the defendant's property and migrated down gradient during the 40 year operating history of defendant's plant. Consultant prepared a fully animated video for courtroom presentation. Video preparation included: development of a storyboard, integration of geological, hydrological, and chemical information, and the integration of the groundwater modeling. The video was used as an exhibit during trial. The case was decided for the plaintiff.
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