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 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
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.
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.