Challenge: To renew and amend a Resource Conservation and Recovery Act (RCRA) hazardous waste permit and compliance plan for a 23-acre closed hazardous waste land disposal facility.
Solution: INTERA prepared an application for renewal and major amendment of the facility’s hazardous waste permit and compliance plan. The facility is comprised of four closed hazardous waste land disposal units. INTERA staff have been assisting with RCRA permitting, groundwater detection monitoring, groundwater compliance monitoring, site remediation and groundwater corrective actions, and other engineering and compliance related services since the 1980s. The application preparation activities included:
- Completion of the applicable portions of the Part A and Part B application forms and attachments
- Update and/or revision of the facility management plans, including personnel training plan, security plan, and inspection plan and schedule
- Update and/or revision of the engineering reports, including general engineering report and landfill report
- Update and/or revision of the post closure care plan and associated cost estimate
- Development of a preliminary review to address releases from solid waste management units
- Update and/or revision of the compliance plan portion of the application, including preparation of a Response Action Plan (RAP) to address affected groundwater at the facility
The application preparation activities included an in-depth review and incorporation of historical design and construction information, operational information, closure activities, and regulatory status for the closed land disposal units. In addition, a permitted unit was removed from the groundwater detection monitoring program, a site-specific background value was established for arsenic, concentration limits were updated for the organic monitoring parameters, and various changes were made to data evaluation procedures. Also, a compliance monitoring program was proposed for a newly confirmed release to groundwater. Additionally, the existing corrective action program was revised to establish a plume management zone, change certain alternate concentration limits, develop attenuation action levels; incorporate in-situ anaerobic bioremediation as a supplemental corrective action to enhance natural attenuation, and replace the active groundwater contaminant recovery program with a contingent program. After submitting the application to the Texas Commission on Environmental Quality (TCEQ), INTERA facilitated TCEQ approval and assisted with negotiating permit language.
Results: The facility’s new hazardous waste permit was successfully negotiated and issued by TCEQ.