Streamlined Corrective Action Completed in Five Years
In 2009, Cox-Colvin was retained by a national solid waste disposal company to address RCRA Corrective Action requirements at an operating midwest Subtitle D recycling and disposal facility. The facility is listed on the RCRA 2020 list, with Corrective Action obligations stemming from the disposal of hazardous waste in a closed interim status RCRA landfill. Through an RFA, EPA and the State identified 35 SWMUs and 5 AOCs requiring further action. Working closely with a forward thinking State regulator, Cox-Colvin utilized much of the flexibility afforded the Corrective Action program through the Advanced Notice of Proposed Rulemaking and the RCRA Reforms to complete Corrective Action within five years.
Beginning with a comprehensive Description of Current Conditions (DOCC) Report, approximately half of the SWMUs were shown to have been excavated and removed as part of landfill expansions. Rather than an often drawn out RCRA Facility Investigation (RFI), a Release Assessment was used to determine if releases had occurred at remaining individual units. Cox-Colvin used land use controls, a realistic conceptual site model, and the results of the Release Assessment to conclude the need for further action at two units; a large grandfathered municipal waste landfill and a series of soil piles containing characteristically (D018) hazardous waste.
Rather than conduct a formal CMS, the facility relied upon the presumptive remedy for CERCLA municipal landfills as a source control element for the grandfathered landfill and RCRA closure requirements for the soil piles. Risk-based clean closure of 21,000 tons of characteristically hazardous soil was achieved through bioremediation. Through an O&M and Performance Monitoring Plan for the landfill, Cox-Colvin demonstrated the facility had implemented the required components of the presumptive remedy including leachate collection, landfill gas collection, cap maintenance, and groundwater monitoring activities, and where necessary, developed procedures to document and further enhance the activities.