Greens Bayou Sediment Investigation and Remediation

Project Summary

Strategic remediation turned complex litigation into complete liability resolution with tens of millions in cost savings.

When an industrial company faced a lawsuit from the Port of Houston Authority concerning contaminated sediments in Greens Bayou, they needed strategic environmental consulting that could address litigation, regulatory requirements, and technical challenges simultaneously. In 6 years (2003–2009), our client resolved their liability, met all regulatory requirements, and achieved tens of millions in cost savings through a precisely targeted remediation approach.  

Location: Houston, Texas

The Challenge

Industrial contamination required resolution of legal liability and regulatory compliance while maintaining operational continuity. 

The industrial company faced a lawsuit from the Port of Houston Authority claiming that historical DDT and pesticide contamination allegedly caused by our client had rendered a 2-mile stretch of Greens Bayou unsafe for essential maintenance dredging. The company needed to address: 

• Ongoing litigation with significant financial exposure 

• Regulatory penalties and extensive remediation requirements 

• Natural resource damage claims from state and federal trustees for DDT’s persistent environmental impact 

• The complexity of site-specific contamination within a heavily industrialized urban estuary with multiple contamination sources 

• Regulatory deadlines following litigation resolution. 

Resolution required a strategic approach that could handle legal requirements while controlling remediation costs and meeting regulatory standards. 

Our Role

Integral served as our client’s comprehensive technical partner, providing expertise across litigation support, regulatory compliance, and environmental remediation.

Our team brought the complete spectrum of expertise needed to navigate every aspect of this complex challenge. We provided technical expertise in litigation, regulatory strategy, and remediation implementation. From expert testimony to construction oversight, Integral guided technical decisions with authority built on deep environmental knowledge and understanding of business requirements. 

Key expertise and innovations delivered: 

• Litigation support and expert testimony that contributed to the settlement agreement 

• Advanced statistical analysis to differentiate our client’s contamination from widespread urban background contamination 

• Site-specific bioaccumulation studies that documented limited contaminant bioavailability, challenging conservative default models 

• Comprehensive ecological risk assessment using detailed toxicological evaluation rather than conservative default benchmarks 

• Full-service remediation from design through postcompletion monitoring. 

What We Delivered

A strategically designed solution that addressed legal requirements while controlling remediation costs.

Integral’s risk assessment determined that no remediation was required to protect human health or the environment—a finding that changed the project’s scope and cost. However, the litigation settlement with the Port of Houston Authority required specific dredging to enable continued port operations. Our solution managed these requirements efficiently. 

We delivered: 

• A focused remediation plan targeting only settlement-required areas, not broader environmental risks 

• Removal of approximately 500,000 yd3 of contaminated sediments through hydraulic dredging up to 26 ft below mudline 

• Construction of a 30-acre upland confined disposal facility located up to 2 miles from the dredging site 

• Strategic thin-layer enhancement capping for areas where slope stability prevented complete removal 

• Comprehensive postremediation monitoring program with statistical validation of success. 

Our approach to the Natural Resource Damage Assessment characterized the degraded urban baseline conditions and limited bioavailability, resulting in settlement terms that were more favorable than initial projections. 

The Result

Our client achieved complete liability resolution while controlling costs through focused remediation.

Through Integral’s strategic approach, our client resolved every aspect of their environmental challenge. The litigation was settled, regulatory requirements were met ahead of schedule, and natural resource damage claims were resolved quickly. 

Measurable outcomes included: 

• Complete legal resolution: All litigation and regulatory requirements satisfied 

• Tens of millions in cost savings: Focused remediation approach eliminated unnecessary work 

• $5–10 million in additional savings: Strategic natural resource damage assessment (NRDA) settlement 

• Operational success: Port of Houston Authority able to resume essential dredging operations 

• Environmental benefit: Creation of new wetland and upland habitat through NRDA settlement 

• Schedule performance: All engineering and risk assessment tasks completed on accelerated schedules 

Our client resolved significant liability while achieving substantial cost savings through strategic environmental management.