RCRA Compliance Program Development and Implementation

Developed and implemented RCRA compliance and monitoring requirements for major hazardous waste disposal facilities. Services included:

• Regulatory requirement interpretation and applicability determinations;
• Groundwater monitoring system design and installation;
• On-going compliance monitoring and statistical data analysis; and,
• Corrective action assessments.

RCRA Closure of Industrial TSDF Surface Impoundments

Implemented the required closure of an industrial hazardous waste storage impoundment for an Indiana manufacturing facility.

• Conducted evaluation and developed removal procedures for a two (2) million gallon surface impoundment.
• Performed pre-removal evaluations to accurately predict amount of sludge and contaminated soil requiring removal and disposal.
• Developed specifications and procedures for efficient dewatering methodology and sludge/soil excavation.
• Managed transportation and disposal of all waste residuals.
• Managed entire process through completed disposal, soil replacement and capping of excavation area.
• Conducted confirmation testing and assessment of impacts to groundwater.
• Completed final report for closure and supporting documentation.

Reversing Determination of RCRA Corrective Action Requirement

Engaged to implement RCRA Corrective Action investigation and assessment at Michigan manufacturing site.

• Conducted extensive evaluation of constituents of concern (COC’s) compared to historical use of chemicals at site.
• Successfully demonstrated that COC’s released to groundwater originated from new product spill rather than RCRA listed waste.
• Regulatory action terminated and remedial activities shifted to voluntary clean-up program with successful completion allowing sale of the business.

RCRA Corrective Action for Industrial TSDF

Managed and implemented corrective action (CA) assessments and investigations at two industrial manufacturing sites for a major Fortune 100 company.

• Conducted area-wide investigations including impact to adjacent landowners, residential populations and surface water discharge.
• Established nature and extent of chlorinated solvent contamination in subsurface soil and groundwater.
• Successfully demonstrated no impact conditions above drinking water maximum contaminant levels (MCL’s) to potentially affected receptors (private wells, surface water discharge).
• Completed contaminant migration pathway assessments for human and environmental exposure potentials in support of responses to USEPA environmental indicator (EI) questionnaire and scoring evaluation.
• Contaminant plume migration demonstrated to be “contained” on-site and naturally remediated by biological and chemical attenuation.

RCRA Closure of Industrial TSDF

Developed and negotiated approved closure plans. Implemented closure of industrial hazardous waste storage facilities for multiple Fortune 500 manufacturing operations.

Conducted and managed complete closure process including:

• Waste removal;
• Tank and transfer line decontamination, decommissioning and recycling;
• Containment and storage area decontamination;
• Subsurface soil and groundwater assessments;
• Initiated corrective action assessments as required;
• Source areas requiring contaminant removal were remediated by multiple methods including: excavation and disposal; soil vapor extraction, groundwater pump & treatment, and chemical oxidation;
• Completed closure reports and supporting documentation for applicable hazardous waste management units.