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RCRA Corrective Action for Metalworks Co

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Project Description

Hart & Hickman has assisted a metalworks manufacturer with several environmental issues since 2007. The facility operated under the RCRA regulatory program from the 1980s until 2010 when H&H successfully negotiated transferring the site into the DEQ Inactive Hazardous Sites Program. This relieved the site of RCRA requirements and importantly the financial assurance responsibilities. In the late 1980s, the site had a large release of 1,1,1-TCA with 1,4-dioxane which, though remediated at the time with SVE and pump and treat, had migrated into the groundwater and moved off-site. To complicate the situation, an upgradient groundwater contaminant plume with similar constituents has co-mingled with the release from this facility. Unfortunately, no responsible party (RP) has been identified for the off-site upgradient release. H&H completed the RCRA Facility Investigation (RFI), completed delineation of both soil and groundwater impacts and was able to eliminate several Solid Waste Management Units (SWMUs) from further investigation.
This company was in bankruptcy and, therefore, has limited ability to fund environmental cleanup. Hart & Hickman was able to demonstrate technical and financial impracticability for source area cleanup at this time due to: 1) structures over the source and 2) the chemical nature of 1,4-dioxane. H&H was able to effectively present historical data and convince the regulators the groundwater plume is delineated and migration is well understood. As a results, only limited long-term groundwater monitoring will be conducted. This has resulted in a significant cost savings to the client, allowing them to focus on re-establishing their business.