Past Performance

Challenge: Twelve Army installations were operating legacy cooling tower programs using chromate-based corrosion inhibitors — a listed hazardous waste under RCRA — with no automated monitoring, inconsistent service intervals, and documented scale deposits reducing heat exchanger efficiency by an estimated 18–22%. Multiple installations had received Legionella-positive culture results in the preceding 24 months with no formal Water Management Plans in place.

Technical Approach: GSS conducted baseline water chemistry analysis at all 12 installations, calculating LSI and RSI values and characterizing existing scale and corrosion deposits through coupon analysis. Legacy chromate programs were replaced with Chem-Aqua phosphonate/azole inhibitor programs — using HEDP and PBTC-based scale inhibitors combined with tolyltriazole for yellow metal protection — sized to each system's water chemistry and heat load. Chem-Aqua aquaDART® automated feed and control systems were installed at all cooling towers, providing continuous conductivity blowdown control, pH monitoring, and ORP-based biocide dosing with real-time data logging. ASHRAE 188-compliant Water Management Plans were developed and implemented at all 12 installations.

• Cycles of concentration increased from average 2.8 to 5.2 — reducing makeup water consumption by 35% across all installations
• Chromate waste stream eliminated, removing a RCRA listed hazardous waste generation obligation from all 12 facilities
• Heat exchanger efficiency restored to design specifications following chemical cleaning and new inhibitor program startup — reducing chiller energy consumption to pre-fouling baseline
• Zero Legionella-positive culture results in 36 months following WMP implementation across all installations
• $2.3M in documented annual savings from reduced water consumption, chemical costs, and maintenance labor

Challenge: A 500-bed VA Medical Center had received a Notice of Violation (NOV) from the state environmental agency citing three RCRA violations: improper hazardous waste characterization for pharmaceutical waste streams, satellite accumulation area containers exceeding the 55-gallon limit, and missing weekly inspection records. The facility faced potential civil penalties and was under a 90-day corrective action deadline.

Technical Approach: GSS conducted a comprehensive RCRA compliance audit within the first week, characterizing all waste streams generated at the facility using both process knowledge documentation and TCLP testing for borderline waste streams. A corrective action plan was submitted to the state agency within 30 days, addressing all three NOV citations with specific procedural corrections, staff training, and documentation system upgrades. GSS served as the facility's regulatory liaison throughout the corrective action process.

• All three NOV citations formally closed by state agency within 75 days — 15 days ahead of the regulatory deadline
• Pharmaceutical waste streams properly characterized and segregated: hazardous (P-listed and U-listed), non-hazardous, and RCRA-exempt categories
• Satellite accumulation area program redesigned with compliant container sizing, labeling, and weekly inspection documentation system
• RCRA training program developed and delivered to 47 facility personnel responsible for waste generation and management
• Civil penalty reduced from proposed $85,000 to $12,000 through demonstrated good-faith corrective action and compliance history documentation

Challenge: GSA Region 9 needed to develop and implement building-level sustainability plans for 15 government buildings totaling 5 million square feet across California, Nevada, and Arizona — meeting EO 14057 requirements for Scope 1/2 GHG reduction, net-zero water, and ENERGY STAR certification. The portfolio had an average Energy Use Intensity (EUI) of 112 kBtu/SF/yr against an ENERGY STAR median of 78 kBtu/SF/yr for comparable office buildings.

Technical Approach: GSS conducted ASHRAE Level II energy audits at all 15 buildings, developing building-specific ECM packages with calculated savings, simple payback periods, and NPV analyses. Water audits identified cooling tower optimization, fixture replacement, and irrigation reduction opportunities. Scope 1 and 2 GHG inventories were developed per GHG Protocol methodology, establishing baselines for EO 14057 reporting. LEED certification documentation was prepared for 12 buildings meeting certification thresholds.

• Portfolio average EUI reduced from 112 to 83 kBtu/SF/yr — a 26% reduction — through BAS optimization, lighting retrofits, and HVAC improvements
• Cooling tower cycles of concentration increased from 3.1 to 5.8 average across the portfolio, reducing makeup water consumption by 30%
• 12 of 15 buildings achieved LEED Silver or Gold certification; 3 buildings achieved ENERGY STAR certification
• Scope 1 and 2 GHG emissions reduced by 31% against the 2008 baseline, exceeding the EO 14057 interim 2025 target of 25%
• $4.5M in documented annual utility cost savings across the portfolio, with full ECM implementation cost recovery within 3.2 years

Challenge: A former underground storage tank (UST) area at an Air Force base had documented petroleum hydrocarbon contamination in soil and groundwater — total petroleum hydrocarbons (TPH) as diesel at concentrations up to 18,400 mg/kg in soil and benzene at 2.3 mg/L in groundwater monitoring wells, exceeding the state MCL of 0.005 mg/L by a factor of 460. Three separate source areas had been identified through previous Phase II investigation work.

Technical Approach: GSS designed a dual-phase extraction (DPE) system targeting the highest-concentration source area, combined with in-situ chemical oxidation (ISCO) using sodium persulfate activated with sodium hydroxide for the two secondary source areas. A groundwater monitoring network of 14 wells was established to track contaminant plume response. All remediation activities were conducted under a state-approved Remedial Action Plan with quarterly progress reporting to the state environmental agency and Air Force Installation Restoration Program (IRP) manager.

• Soil TPH concentrations reduced below the state residential cleanup standard of 100 mg/kg in all three source areas within 14 months
• Groundwater benzene concentrations reduced from 2.3 mg/L to below the 0.005 mg/L MCL in all 14 monitoring wells within 18 months
• State regulatory closure letter issued 2 months ahead of the projected schedule — eliminating ongoing monitoring costs estimated at $180,000/year
• Zero regulatory violations or permit exceedances during the 18-month remediation program
• All remediation waste characterized, manifested, and disposed at licensed facilities with complete chain-of-custody documentation

Challenge: A state capitol complex operating 8 cooling towers across the legislative campus had no formal Legionella Water Management Plans, was operating at average cycles of concentration of 2.4 (well below the water-efficient target of 5.0+), and had documented scale deposits in two towers causing measurable reduction in chiller efficiency. The state's facilities director had received a directive to implement ASHRAE 188-compliant WMPs within 90 days following a Legionella outbreak at a nearby government building.

Technical Approach: GSS conducted a complete water system survey, developing schematic diagrams of all 8 cooling tower systems and associated distribution piping. Baseline Legionella culture sampling was performed at all towers and associated risk devices. Dead legs, low-flow zones, and other physical risk factors were identified and remediated during the survey. ASHRAE 188-compliant WMPs were developed for each system, with control measures, monitoring frequencies, and corrective action procedures tailored to each tower's specific configuration and water chemistry. Chemical programs were redesigned using Chem-Aqua chemistry to optimize CoC while maintaining effective scale and corrosion control, with aquaDART® controllers providing automated monitoring and dosing.

• ASHRAE 188-compliant WMPs implemented at all 8 cooling towers within 60 days — 30 days ahead of the directive deadline
• Baseline Legionella culture results: 3 of 8 towers positive at >100 CFU/mL; all cleared to below detection limit following hyperchlorination and program startup
• Average cycles of concentration increased from 2.4 to 5.1 through chemical program optimization and controller installation — reducing makeup water consumption by 45%
• Annual water cost savings of $1.2M documented through utility meter comparison against pre-program baseline
• Zero Legionella-positive results in 24 months of quarterly monitoring following WMP implementation

Challenge: GSA Region 4 selected an 8-building government campus as a pilot site for EO 14057 Net Zero Water implementation. The campus consumed 42 million gallons of municipal water annually, with cooling tower makeup water accounting for 58% of total consumption. The Net Zero Water target required reducing net municipal water consumption to zero through a combination of conservation, on-site water harvesting, and water reuse — while maintaining all regulatory compliance obligations.

Technical Approach: GSS conducted a comprehensive water audit quantifying all end uses and identifying conservation and reuse opportunities. Cooling tower programs were redesigned to operate at CoC of 6.5+ using Chem-Aqua's Resourcefully Green® high-efficiency inhibitor formulations with aquaDART® automated control, reducing tower makeup demand by 38%. A 2-million-gallon annual capacity rainwater harvesting system was designed and installed to supply cooling tower makeup water. Greywater from restroom hand washing was treated and reused for toilet flushing, reducing potable water demand by an additional 12%.

• Net Zero Water status achieved — first government campus in GSA Region 4 to meet EO 14057 Net Zero Water definition
• Municipal water consumption reduced from 42 million gallons/year to 16.8 million gallons/year — a 60% reduction
• Rainwater harvesting system captures and treats 2.1 million gallons annually for cooling tower makeup water supply
• Greywater reuse system reduces potable water demand for toilet flushing by 5.1 million gallons annually
• Project selected by GSA as a model implementation for the EO 14057 Net Zero Water program — featured in GSA's annual sustainability report