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Permitting and Compliance

     TechLaw has supported the EPA and state agencies, including New Mexico, Connecticut, Utah, and Texas, in all RCRA program phases since 1985. In this time, we have primed six EPA RCRA contracts. This work has included permitting support, closure plan assistance, and corrective action oversight. TechLaw’s related credentials include the following:

  • Review or preparation of more than 1,500 Part B Permit Applications, closure plans, trial burn plans, and risk assessments for RCRA-regulated facilities, including landfills, surface impoundments, tanks, treatment units, and BIF and Subpart X units
  • Presentation of training for all 10 EPA regions and state staff on RCRA permit writing, identification of regulated hazardous wastes, Corrective Action, groundwater regulations, and other topics
  • Conduct of over 1,000 RCRA Facility Assessments (RFAs) and Preliminary Assessments/Visual Site Inspections (PA/VSIs)
  • Review of over 400 RCRA Facility Investigation Work Plans and Reports
  • Assistance to EPA with oversight of Interim Measures (IMs), Corrective Measures Studies (CMS) and Corrective Measures Implementation (CMI)
  • Corrective action support for remediation and closure activities, including evaluation of engineering specifications and designs
  • Technical assistance reviewing over 700 closure/post-closure plans and post-closure permit applications for interim status or permitted units where closure is imminent
  • Evaluation of CMI Reports and conduct of Operation and Maintenance (O&M) Inspections
  • Completion or review of human health and ecological risk assessments, including combustion risk assessment
  • Performance of inspections and file reviews in support of RCRA Corrective Action Environmental Indicators under GPRA
  • Sampling and analysis of all environmental media, as well as data validation to confirm data are acceptable for use
  • Guidance and checklist preparation
  • Organization, establishment, and maintenance of administrative records
  • Meeting support, which includes negotiation support and expert witness testimony at public hearings
Projects
 
Hamilton Standard Division of the United Technologies Corporation

Since 1953, Hamilton Standard’s activities at this facility have included the design and manufacture of air, spacecraft, and marine control systems and components. EPA requested that TechLaw provide technical support for RCRA Corrective Action oversight activities at Hamilton Standard in the form of document review, risk assessment support, field oversight and sampling of environmental media, data interpretation, and meeting support that ultimately resulted in the proposal and implementation of a Corrective Action Final Remedy. TechLaw conducted technical reviews of deliverables that included RFI Work Plans, Interim Measures Stabilization activities, a Corrective Action Management Unit (CAMU) permit application, reports for PCB and other contaminated areas, and the Site-Wide Human Health Risk Assessment. TechLaw conducted surface water, sediment, and seep sampling in Rainbow Brook and in an off-site area, and provided oversight of PCB remediation efforts adjacent to Watts Pond and Rainbow Brook. TechLaw also performed meeting support related to the RCRA corrective action activities at the site.
RCRA Border Compliance Evaluation Inspections (CEIs)
As part of a special initiative, several industry sectors have been identified by EPA Region 6 as being significant solid and/or hazardous waste handlers. Information gathered from EPA inspections and by Region 6 states indicates that solid and/or hazardous waste handlers have had and continue to have environmental problems. To establish compliance and reduce the environmental and human risk posed by these industries, TechLaw is supporting EPA Region 6 in compliance monitoring and evaluation, facility inspections, and sampling and sample analysis by performing RCRA CEIs with sampling at designated facilities along the Texas – Mexico border. TechLaw also provides support for this EPA special initiative with public involvement and outreach activities such as facilitating outreach to local industries, including announcements and informational materials prepared in both English and Spanish.
 
General Electric (GE) Pittsfield, Massachusetts Site
TechLaw has 16 years of comprehensive RCRA experience at this site. In 1987, TechLaw staff conducted site inspections and prepared the RFA for the site. We were also integral to the development of the Hazardous and Solid Waste Amendments (HSWA) Permit for GE. TechLaw performed comprehensive technical reviews of all RFI proposals, RFI Reports, Current Assessment Summary Reports, Preliminary CMS Reports, and four expanded risk assessment work plans submitted by GE. TechLaw staff participated in two sediment sampling activities in the Housatonic River and Silver Lake that involved the collection of more than 400 sediment samples and coordination with state regulators to update a geographic information system (GIS) database with global positioning system (GPS) coordinates and analytical data.
     
     
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