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June 5, 2018
3:00-4:00PM

Reopening and Closing Again: A Case Study on Hazardous Waste Land Treatment Unit Closures Under TRRP

Expo A3

Speaker: Austin Cooley, Vice President, Brown and Caldwell

Seven RCRA-permitted hazardous waste land treatment units (LTUs), which totaled 16 acres, had been closed in place at an active petroleum refinery. The LTUs had been closed under prescriptive closure plans developed prior to the promulgation of the Texas Risk Reduction Program (TRRP) rule (30TAC350). A strategy was developed to migrate the LTUs into TRRP and then re-close them, taking advantage of the flexibility inherent in TRRP closures. Four of the units were closed under Remedy Standard A (RSA), which requires no continuing care. The remaining three were closed under Remedy Standard B (RSB), requiring continued capping and post closure monitoring. The RSA closures allowed those LTUs to be reused with no restrictions, while the RSB-closed LTUs, performance-based caps were negotiated under TRRP and the closure plan allowed for implementation of alternate caps, which would facilitate reuse, with a class 1 ED RCRA permit modification.

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2018-06-05 15:00:00 2018-06-05 16:00:00 America/Detroit Reopening and Closing Again: A Case Study on Hazardous Waste Land Treatment Unit Closures Under TRRP Speaker: Austin Cooley, Vice President, Brown and Caldwell Seven RCRA-permitted hazardous waste land treatment units (LTUs), which totaled 16 acres, had been closed in place at an active petroleum refinery. The LTUs had been closed under prescriptive closure plans developed prior to the promulgation of the Texas Risk Reduction Program (TRRP) rule (30TAC350). A strategy was developed to migrate the LTUs into TRRP and then re-close them, taking advantage of the flexibility inherent in TRRP closures. Four of the units were closed under Remedy Standard A (RSA), which requires no continuing care. The remaining three were closed under Remedy Standard B (RSB), requiring continued capping and post closure monitoring. The RSA closures allowed those LTUs to be reused with no restrictions, while the RSB-closed LTUs, performance-based caps were negotiated under TRRP and the closure plan allowed for implementation of alternate caps, which would facilitate reuse, with a class 1 ED RCRA permit modification. Expo A3