RCRA Part B Permitting, Corrective Measures Study, Interim Measures and Corrective Action
Hull was retained by a refinery client to prepare a new RCRA Part B Permit application for a 450-acre plant located in Tulsa, Oklahoma. The client was required to submit a new RCRA permit application as a result of a change in ownership of the facility. Hull worked cooperatively with multiple facility personnel to collect relevant data to complete the RCRA permit over a five-month period. Prior to the change in ownership, the facility had multiple RCRA permits. The new permit reorganization has been approved by the client and accepted by the governing regulatory agency.
Hull was subsequently retained by the same client to prepare a major RCRA Part B Permit Modification based upon a better understanding of the Conceptual Site Model after a thorough review and analysis of all available environmental site data. The RCRA permit modification was estimated to save the client approximately $120,000 annually in environmental costs once implemented.
Hull was further retained by the client to complete RCRA Interim Measures (IMs) and lead a multi-functional technical team to begin development of conceptual final remedial strategies as part of the facility RCRA corrective measure study (CMS) process. The client was required to complete IMs to eliminate sheening in a major US river resulting from LNAPL and waste materials. IMs were required as a condition of the existing RCRA permit.
Hull designed RCRA IMs and developed work plans to eliminate river sheening along two separate areas of over two miles of facility property situated along the river. Preliminary Hull work included developing site specific health and safety plans, materials evaluation and procurement, contractor scope preparation, contractor bidding, final contractor selection, and Army Corps of Engineers notifications. The IM work plans were approved by the regulatory agency with no significant changes. The IMs consisted of exploratory test pits, clearing and grubbing, installing access roads, cutting back the bank, booming and skimming, excavation of impacted sediments, chemical testing, and placement of geotextile, clay, and rip rap along the riverbank. Hull managed all yellow iron contractors and interfaced daily with client environmental staff and facility safety and security personnel while completing the two-month-long IM projects.
Hull was also retained by the client to head a technical team of multi-functional professionals for development of strategies and conceptual approaches for final remedies of more than two miles of riverbank located at the property boundary. Historical waste handling practices and multiple leaks and spills had resulted in environmental impacts to much of the riverbank. Hull identified data gaps in the Conceptual Site Model to aid in the collection of future remedy design data as part of the facility RCRA CMS process. Hull was also tasked with helping the local facility environmental staff prepare appropriate presentation documents to help the client's corporate management make informed business decisions based upon overall company project goals, life-cycle economics, and compliance with the existing facility RCRA permit.