Natural Gas Transmission System CERCLA Administrative Order on Consent




Kentucky, Ohio, Pennsylvania, and West Virginia

CEC Services

  • General Sampling and Analysis Plan (SAP)
  • Implementation of the SAP
  • Characterization Report/Response Action Work Plan (CR/RAWP)
  • Oversight of Response Action and Confirmation Sampling
  • Response Action Completion/Final Report (RAC/FR)

Owner Objective

The owner operates a natural gas transmission pipeline network of various facilities, including compressor stations, mercury metering stations, maintenance and repair facilities, and other ancillary facilities. The owner entered into an Administrative Order on Consent (AOC) with the United States Environmental Protection Agency (U.S. EPA) that became effective on February 23, 1995, to assess their facilities and, if necessary, perform remedial activities.

CEC Approach

To assist the client with its obligations under the AOC, CEC completed the investigative, remedial design, remedial implementation, and final report phases
of the project and order requirements.

The project required the preparation of a Characterization Work Plan for Work Scope List Facilities (CWP); preparation of a General Sampling and Analysis Plan (SAP); performance of field sampling of soils, sediments, and groundwater; preparation of a Characterization Report/Response Action Work Plan (CR/RAWP); implementation of the RAWP; and preparation of a Response Action Completion/Final Report (RAC/FR).

The SAP was implemented to investigate Potential Release Areas (PRAs) at the various sites. The media investigated included surface and subsurface soil, sediment, surface water, and groundwater. Characterization of the sediment was performed using geomorphological principles to identify areas of likely sediment deposition and then analysis of samples along transects through areas of instream and overbank deposition.

Based on the results of the site characterization, supplemental characterization and/or removal activities were recommended at potential release areas as appropriate. The constituents of concern for the sites included Polychlorinated Biphenyls (PCBs), Polynuclear Aromatic Hydrocarbons (PAHs), Volatile Organic Compounds (VOCs), and metals. Site-specific background concentrations were calculated as the target cleanup level for metals where appropriate.

After completion of the owner-selected remedies for the various site media. Human Health and Ecological Risk Assessments were performed to document that residual levels of contaminants left in place did not pose an unacceptable risk to human health and the environment.