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RCRA Assessment, Corrective Action, Permitting

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Project Description

This RCRA Treatment, Storage and Disposal Facility (TSDF) was subject to an RFA in the 1980s which identified several Solid Waste Management Units (SWMUs). Two of these units were drying beds for sludges containing metals. These SWMUs were closed by removal of the sludges and capping; however, groundwater had been impacted so a pump and treat system was installed and had operated since the early 1990s. Hart & Hickman completed an extensive data evaluation and through use of fate and transport modeling convinced the regulators the pump and treat system was no longer effective and should be shut down. H&H also successfully convinced the regulators that monitored natural attenuation would be an effective remedy.
The facility’s RCRA Part B Permit was due for renewal. Hart & Hickman prepared the permit renewal which removed the pump and treat system, reduced the number of wells and constituents to be monitored, reduced the monitoring frequency from quarterly to annually, and established MNA as the groundwater remedy going forward. This reduced the company’s required financial assurance from $1.5M to $190K, thereby freeing up available credit for future company investment in capital improvements and production.