RCRA Corrective Action Programs

Applied Science & Technology, Inc. (ASTI) offers RCRA Corrective Action and Michigan MERA programs to assist industry in maintaining compliance with the reporting and closure plan requirements. These services include facility assessments and investigations, sampling, hazardous material identification, remediation type recommendation and report preparation. A few examples of corrective action programs completed by ASTI are provided below.

RCRA FACILITY ASSESSMENT (RFA) AND INVESTIGATION (RFI)

ASTI was retained to assess groundwater as part of an RFA for a RCRA TSD facility. The RFA is to identify actual or potential releases from a TSD facility or solid Waste Management Unit (SWMU). The RFAs' purpose is to determine whether available evidence suggests a release and if additional study is required. After it was determined that there was evidence of a release a RFI was initiated. The RFI is performed to characterize the nature, extent and rate of migration of the released contaminant.

RCRA FACILITY RFI

A permitted RCRA facility had two surface impoundments on the property which were suspected of releasing hazardous materials. A RFI which included a groundwater monitoring system was installed to characterize the nature, extent and rate of migration of the released contaminant. The RFI concluded that no plume of contamination was identified and no further groundwater monitoring was necessary.

GENERATOR SWMU INVESTIGATION

A generator facility with a large plant had more than 200 SWMUs within the plant. A program was implemented to do an RFA on all the existing SWMUs and determine if any of the SWMUs would require an RFI. After the RFAs were completed it was determined that approximately 30% of the SWMUs required RFIs. Ten Corrective Measure Studies (CMS) were indicated by the RFIs. A CMS is designed to assure that the proposed measures will effectively correct any threats to human health or the environment caused by the releases. The CMSs were approved by the state and the site remediation was successfully completed.

RCRA FACILITY RFA

A permitted RCRA facility had a series of releases from storage tanks and containers on the facility. These releases needed to be identified and a determination made if they were actual or potential sources of release of hazardous substances. ASTI completed the RFA and made the recommendation that a RFI be conducted on the facility.

RCRA FACILITY CORRECTIVE MEASURES STUDY

Soils from a tank farm at a hazardous waste treatment facility were found to be contaminated with hazardous materials. ASTI prepared a Corrective Measure Study for the decontamination and submitted it for approval. After the plan was approved the corrective action plan was successfully implemented and completed.

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