The Corrective Action and Permitting Task Force within the Hazardous Waste Subcommittee provided comments on February 11, 2022 regarding EPA’s Modernizing Public Notice for RCRA Hazardous Waste Permitting and Other Actions.
The Compliance Monitoring and Enforcement (CME) Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to comment on the draft memorandum, “Applicability of Resource Conservation and Recovery Act (RCRA) Organic Air Emission Standards to Equipment and/or Closure Devices, Subpart BB versus Subpart CC”, from the Director of the Office of Resource Conservation and Recovery (ORCR) within the U.S. Environmental Protection Agency (EPA). The Task Force received the draft memorandum that was circulated via e-mail on August 4, 2021, for a 60-day public comment period. These Task Force comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition to these comments, individual State or Territorial hazardous waste programs may provide input directly to EPA based on their own perspectives and experiences.
The State of Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) Hazardous Waste Program (HWP) conducts a Corrective Action Monitoring and Maintenance (CAMM) program that involves inspecting all RCRA Treatment, Storage, and Disposal (TSD) facilities that have completed corrective action. The CAMM program helps ensure facility compliance with the requirements of legal agreements in place. The presentation also discusses how Drone Photometry tools have assisted the CAMM program to the benefit of the Department and the facility.
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.