The 78-acre Pharmacia & Upjohn Company LLC site had a long history of industrial use, including the manufacturing of products used in dyes and pigments, photographic chemicals, consumer products and pharmaceuticals, among others. For more than a decade, investigations and interim measures were performed under Resource Conservation and Recovery Act (RCRA) 3013 and 3008(h) Administrative Orders. Prior to 1995, limited progress and minimal stakeholder outreach led to community frustration, distrust and legal entanglements.
This presentation focused on the stakeholder-driven approach to corrective measures that successfully turned public opinion around, achieved full community support for the remedy, and addressed site impacts in a sustainable manner. Remedy construction was deemed complete on September 30, 2019.
Today, all that remains is long-term operation, maintenance and monitoring of the final remedy. The Connecticut Department of Energy and Environmental Protection, following a 45-day public comment period, where public support and appreciation of the future vision of land-use for the property was heard, issued a Stewardship Permit, a form of RCRA Corrective Action post-remedy permit to ensure long-term stewardship at the property, on March 9, 2021.
Director – Environmental Engineering, Remediation & Transactions
The ASTSWMO Hazardous Waste Subcommittee provided comments to the EPA Hazardous Waste Electronic System (“e-Manifest”) Advisory Board for the Board’s public meeting on March 2-4, 2021, on the meeting theme, “Looking Ahead: Setting E-Manifest Program Priorities and User Fees for FY2022 and FY2023.”
Compliance Monitoring and Enforcement Task Force within the ASTSWMO Hazardous Waste Subcommittee provided feedback regarding the fiscal year performance data that the U.S. Environmental Protection Agency (EPA) proposed to use in conducting State Review Framework (SRF) reviews in FY2021.
The North Carolina Department of Environmental Quality has been working to assess and mitigate PFAS emissions from the Chemours facility in Fayetteville, NC, for several years. PFAS compounds were first discovered in the Cape Fear River by EPA researchers. Various PFAS compounds, including HFPO Dimer Acid, or “GenX,” have since been discovered in surface water, rain, soil, sediment, fish, foam on surface water, and in private drinking water wells more than 12 miles from the facility. Join staff from the NC DEQ to learn more about the PFAS investigation in the area and how impacted resources are being addressed to protect human health and the environment.
This webinar, the first in a series of follow-on webinars from the September 2020 ASTSWMO RCRA Corrective Action Conference, will feature two presentations, described below.
First Speaker: Vrushali Gandhi, Virginia DEQ
Topic: Virginia Unified Risk Assessment Model (VURAM) Unleashed
Summary: The Virginia Unified Risk Assessment Model (VURAM) is a risk assessment tool developed and maintained by VA DEQ to conduct quantitative human health risk assessments. This presentation will include a demo of the software and how to interpret the results. We will further discuss how its application could be useful for regulators, consultants and various other stakeholders.
Second Speaker: Diana Marquez, Project Manager with Burns & McDonnell
Topic: Risk Assessment and Decision-Making in Corrective Action
Summary: Risk management is one of the most challenging parts of a corrective action project. Effective risk management requires understanding a variety of considerations including the technical complexities of a site, risk drivers, and stakeholder concerns. In this presentation, we will discuss 1) Current frequently-used approaches to risk management; 2) Strengths and weaknesses of the frequently-used approaches; and 3) Alternative ways of approaching risk management to achieve the same goals.
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The 2020 ASTSWMO RCRA Corrective Action Conference was held on September 1-3, 2020 as a virtual event. The Conference featured the theme, “RCRA Corrective Action: 2020 and The Road Ahead”, to acknowledge 2020 as the milestone year for achieving RCRA corrective action goals and the work that remains beyond 2020.
On the first two days, two sessions were separated by a break. There was a continuous session on the last day.
EPA RCRA Corrective Action Program Vision / Mission / Goals for 2030
EPA Hazardous Waste Corrective Action webpage
The ASTSWMO Hazardous Waste Subcommittee hosted two State-EPA Hazardous Waste Roundtable webinars in May and in June 2020. Subcommittee Chair Paula Bansch (IN) moderated both Roundtables.
The first Roundtable was held on May 14, 2020. The webinar recording features presentations by U.S Environmental Protection Agency (EPA) Office of Resource Conservation and Recovery (ORCR) staff on State and Tribal Assistance Grants (STAG); Small Quantity Generator (SQG) Re-Notification/Update re: Executive Order on Guidance Documents; updates on RCRAInfo and Capacity Assurance; and a Demo of Data Visualization.
The following EPA presentations were part of the second Roundtable, held on June 10, 2020: Corrective Action Beyond 2020; National RCRA Permitting Priorities; the Open Burning/Open Detonation Alternative Technologies Report; the National Permit Oversight Policy; and an update of the Corrective Action Module in RCRAInfo Version 6.
The Materials Management and Hazardous Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate the opportunity to jointly provide comments on the U.S. Nuclear Regulatory Commission’s (NRC’s) Proposed Interpretive Rule, Transfer of Very Low-Level Waste to Exempt Persons for Disposal NRC-2020-0065, published in the Federal Register on March 6, 2020 (85 FR 45). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial radiological, solid waste, and hazardous waste programs may also provide comments based on their own perspectives and experiences.
The Corrective Action and Permitting Task Force within ASTSWMO’s Hazardous Waste Subcommittee is hosting a webinar on Inspecting Permitted Facilities & Following Permit Conditions. It is critical that RCRA Permit Writers and Inspectors work together to ensure permitted Treatment, Storage, and Disposal Facilities are following the requirements of their permits. This webinar will discuss how permit writers can prepare for Compliance Evaluation Inspections and the types of hazardous waste storage units they might encounter. The presentation will mostly focus on tanks and containers, but will also discuss other topics including treatment and corrective action. Permit Writers and Inspectors working together make for more thorough inspections, more accurate permits, and hopefully safer and more compliant Treatment, Storage and Disposal Facilities (TSDFs). There will be time following the presentation for questions.